China MSA Notice on the implementation of IMO 2020 Global Sulphur Limit

November 14, 2019 IMOIMO 2020

IMO 2020 Global Sulphur Limit

In order to effectively implement the IMO’s 2020 global sulphur limit, China Maritime Safety Administration (MSA) has issued the attached notice – a translation of which has been provided by the China Classification Society (CCS). The requirements are summarized in the tables below.

Table 1 – Brief on fuel oil sulphur content(m/m) limit for international ships entering China waters

Effective date
Inland waterway ECA
Hainan waters within ECA
Other waters
1 January 2020
1 January 2022
Table 2 – Ban on carriage of non-compliant fuel oil and discharge of wash water from open-loop scrubbers
Effective date
1 January 2020
ships are prohibited to discharge wash water from open-loop scrubbers in China emission control areas.
1 March 2020
international ships entering waters under the jurisdiction of China are prohibited to carry non-compliant fuel oil onboard.
In accordance with MEPC.1/Circ.881, from 1 March 2020 onward, a foreign ship carrying non-compliant fuel oil in the Chinese waters may be required to:
·  discharge the non-compliant fuel oil
·  if permitted by the MSA of calling port, to retain the non-compliant fuel oil on board with a commitment letter stating it will not be used in waters under the jurisdiction of China.
The circular mentions that the fuel oil sampling and testing may be taken by MSA for supervision and enforcement. Judgment on the testing result will be made in accordance with MEPC.1/Circ.882.
The circular also provides guidance for ships using or carrying non-compliant fuel oil due to the non-availability of compliant fuel oil and a template of Fuel Oil Non-Availability Report (FONAR).
MSA will carry out site inspection and review/examine the completeness and authenticity of the FONARs submitted by the ships. Penalty could be imposed on ships infringing this regulation or if the submitted FONAR is examined to be not compliant and true.
IMO 2020 Global Sulphur Limit


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