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SCRUBBER-PROHIBITING COUNTRIES

This information is for guidance only, as the guidelines are constantly changing. Last updated April 2021.

 

ARGENTINA – Yes: the prohibition previously in place is currently suspended.

However, IT&L Legal Consultants advise that this resolution took effect from 3 October, 2020 and warned that this suspension is provisional and the restrictions have not been permanently overturned.

AUSTRALIA – Yes: according to AMSA Marine Notice 05/2019, washwater testing should be conducted upon commissioning of the EGCS and repeated every 12 months, as a minimum, for a period of two years.

Cruise ships capable of accommodating more than 100 passengers in Sydney Harbour are required to use either low sulphur (maximum 0.10% m/m) fuel or an alternative measure that achieves an equivalent outcome i.e. EGCS. 

Discharges from EGCS into Westernport waters are not permitted. This is a more precautionary restriction on EGCS use based on the interpretation of the port regulations by the harbor master.

Ships may be told not to discharge EGCS washwater in Australian waters if this data, or evidence that samples have been taken for analysis, cannot be provided to AMSA before arrival at the first Australian port.

Vessels must obtain a permit from the Marine Safety & Environment Protection Directorate before discharging washwater anywhere in Bahrain waters.

BAHRAIN – No: open loop operations are not allowed in port or at anchor. However, open loop operations are allowed in Bahraini territorial waters and exclusive economic zone (EEZ).

BELGIUM – No: Belgian federal law states that discharge is only allowed in coastal and open seawaters when at least three nautical miles off the coast. 

BELIZE –  No: Discharge of Exhaust Gas Cleaning Wash Water prohibited in territorial waters and port areas (Marine Circular 01/2018 – BPA/MS/23-1/2018(98) dated 12/12/2018)

BERMUDA – Yes: All ports. Ships equipped with EGCS will have to seek prior approval from the Environmental Authority before they are used in Bermuda’s territorial waters.

Washwater and residue from the EGCS shall be not disposed of in Bermuda or discharged into Bermuda’s waters, but shall be stored on board the ship until outside of Bermuda’s waters.

BRAZIL – Yes: P&I Club correspondents Brazmar advised on 23 July, 2020 that the Directorate of Ports and Coasts (DPC)/Navy had changed the previous guidance and that the discharge of washwater from open loop and/or hybrid EGCS is allowed within Brazilian jurisdictional waters until the competent environmental authority has the opportunity to better assess the situation.

BRAZIL VALE TERMINALS – No: EGCS washwater discharge is not allowed while operating in its Brazilian ports and terminals. Vale recommends that vessels should be changed over to compliant fuel before entering contiguous zone or coastal waters, 24 nautical miles from coastline.

CHINA (INLAND RIVER EMISSION CONTROL AREAS) – No: China MSA guidance prohibits the discharge of water washings from open loop scrubbers in certain areas.

The prohibited areas are:

  • Inland river Emission Control Areas.
  • Port areas within coastal ECAs.
  • Bohai Sea – the sea area within lines connecting the junction point of shorelines of Dandong, Dalian and shorelines of Yantai, Weihai.

Ships are required to keep accurate records of the stowage and disposal of the washwater. If a vessel is not able to store the washwater, it is required to switch to low sulphur fuel (not exceeding 0.5%) prior to entering the above areas.

CYPRUS –  Yes. In accordance with  CPA Regulations of CA 373/2016 Part II – Cyprus Port Authority, ships requiring to use ECGS at Cyprus’ ports or anchorage area must submit a written request for assessment and approval by the CPA at least 48 hours prior to the arrival of the ship. The written request shall provide the following detailed information:

  • the location that EGCS will be used (port, anchor); and
  • the type of ECGS

EGYPT PORTS AND SUEZ CANAL – No: The Suez Canal Authority puts no conditions or restrictions on marine fuels until Egypt ratifies MARPOL Annex VI and as such, the IMO sulphur cap is not in force.

In addition, washwater from open-loop scrubbers is not permitted to be discharged during a canal transit. As for the ports, Kalimbassieris Maritime Egypt has advised that the discharge of open loop scrubber washwater is not permitted in Egyptian territorial waters.

ESTONIA – Yes: Restrictions are in place on discharging chemical EGCS washwater, including in enclosed ports and estuaries.

Exceptions for discharge into the sea are made if the ship operator can demonstrate that the washwater meets international requirements, required PH levels and does not cause adverse effects on human health or the environment.

The use of closed-loop EGCS is permitted in Estonian territorial waters and ports, if it meets the relevant requirements and is certified, however discharging of the washwater is not permitted.

Exceptions for discharge into the sea are made if the ship operator can demonstrate that the washing water meets international requirements, required pH levels and does not cause adverse effects on human health or the environment.

Prior authorisation is always required to discharge into the port area.

FINLAND (Port of Porvoo) – No: Ministry of Transport and Communications informs: Under Finnish legislation, the discharge of wash waters from open-loop scrubbers is allowed in Finnish ports and territorial waters. However, some ports have restricted the discharge in the port area under their own competence.

FRANCE (Ports of Cannes, Marseille, Nantes, St. Nazaire, La Rochelle, Rouen, Bordeaux, Le Havre) – 

Some large seaports such as Marseille, Nantes-St Nazaire and La Rochelle have already amended their port regulations to include a ban on open-loop scrubber discharges, and the port of Rouen is preparing to do the same. Other ports such as Bordeaux and Le Havre have a prohibition in principle.

GERMANY (INLAND WATERWAYS, CANALS AND PORTS WITHIN INLAND WATERWAYS) –  No: EGCS discharge is not permitted during navigation on the Rhine and other inland waterways (CDNI Convention).

Restrictions apply to all inland waterways intended for general traffic except for the German part of Lake Constance and the stretch of the Rhine upstream of Rheinfelden.

GHANA – No: Ghana Maritime Authority informed the CSA that the Administration does not allow the operation of open-loop scrubbers in Ghanaian waters.

GIBRALTAR – No: closed loop scrubbers are permitted in Gibraltar waters, as are hybrid scrubbers operating in closed loop mode.

Open loop scrubber are temporarily not permitted until the Gibraltar government gives a definitive policy decision with regards to the use of open loop scrubbers.

HONG KONG – Yes: a ban on EGCS washwater is not listed.

However Hong Kong regulation LN 135 of 2018 states that an exemption from use of non-compliant fuel is granted if the authorities are satisfied with the abatement technology used to reduce sulphur dioxide emissions.

INDIA (ADANI PORTS) – No: Adani Ports and Special Economic Zone has issued a circular advising that the discharge of washwater from open-loop scrubbers is prohibited.

However, vessels fitted with hybrid scrubbers should switch over to closed loop mode of operations before entering port limits, while those fitted with closed loop scrubbers can continue using the systems.

The above was due to come into force on 1 November, 2020.

IRELAND (DUBLIN, CORK & WATERFORD) – No: the Port of Dublin has issued a Notice to Mariners No 37 of 2018 Prohibition on the Discharge of Exhaust Gas Scrubber Washwater, as has the Port of Waterford.

KENYA – No: The  discharge  of  wash-water  from  open-loop  scrubbers  is prohibited in  the Kenyan Ports limits under Kenya's National Guidelines for Implementation of IMO 2020 (Dec 2019).

LATVIA – Yes: Conflicting advice has been received. P&I Correspondents Pandi Balt Ltd advised in August, 2018 that washwater discharges are currently allowed under regulations but are likely to be prohibited in future.

 Although there are no specific regulations prohibiting the use of open-loop scrubbers, local correspondents advise that national authorities are taking the general position that the discharge of wash-water from open-loops scrubbers is not permitted in territorial and port waters.

LITHUANIA  –  Yes: Again conflicting advice has been received. Although there are no specific regulations prohibiting the use of open-loop scrubbers, local correspondents advise that national authorities are taking the general position that the discharge of wash-water from open-loops scrubbers is not permitted in territorial and port waters.

According to P&I Clubs, Lithuanian legislation allows to use the open loop scrubbers wash water discharges in Lithuanian EEZ as well, at the port of Klaipeda, only if those using the sodium hydroxide (caustic soda) as a main reagent and pH has to be strictly less than 8.0 in the discharged wash water. All other chemical reagents alternative to sodium hydroxide is strictly prohibited at LTU areas and has to use Closes Loop.

MALAYSIA – No: Malaysia shipping notice MSN 07/2019 prohibits the use of open loop scrubbers within 12 nautical miles from land.

Vessels calling at Malaysian ports must operate in closed loop mode or change over to compliant fuel before arriving.

MAURITIUS –  No: Except in the case of innocent passage, ships proceeding to Mauritius or other islands forming part of  the territory of  Mauritius that use high sulphur fuel oil (HSFO) in combination with open-loop scrubber shall changeover from HSFO to compliant fuel oil whenever they enter the territorial waters of Mauritius i.e. within 12 nms from the shore. Environmental legislation presently in force in Mauritius prohibits the discharge of wash water from open-loop scrubber.

MOZAMBIQUE (EXCEPT NACALA) – Conditional. Open loop scrubbers are allowed in the Mozambique territorial waters as long as they are working properly and following all the regulations.

Open loop scrubbers are not allowed and ships must operate uing compliant within ports, estuaries or bays where the water salinity values falls from the standard ones considered for salt water (1,025 or more), 

NEW ZEALAND – Yes: however, it is discouraged as per Maritime NZ (MNZ) issue “Guidance on the Use of Exhaust Gas Cleaning Systems (Scrubbers) for Ports, Regional Authorities and Ships”.

This guidance is non-statutory, but MNZ encourages the industry to implement measures until studies currently underway in respect of the use of scrubbers have been completed.

MNZ requested that all ships carrying scrubbers and operating in New Zealand’s territorial waters engage with the relevant port and regional authorities, and as a precautionary measure, where possible, they avoid discharging scrubber effluent close to shore by utilising alternate options.

NORWAY (THE WORLD HERITAGE FJORDS SEA AREAS OF GEIRANGERFJORD AND NÆRØYFJORD) – Restricted: The World Heritage Fjord sea areas of Geirangerfjord and Nærøyfjord restrict the use of open loop scrubbers, but not closed loop systems.

OMAN – No: open-loop scrubber discharge is not permitted in Oman territorial waters.

PAKISTAN (PORT OF KARACHI AND PORT BIN QASIM) – No: the Pakistan Ministry of Maritime Affairs (Ports and Shipping) has prohibited the discharge of washwater from open loop scrubbers.

If closed loop scrubbers are not in use then compliant fuel should be used and changed over before arriving in port waters.

PANAMA (PORTS AND CANAL) – No: the use of open loop scrubbers or hybrid scrubbers in open loop mode is prohibited in Panama Canal waters. Residues from the Exhaust Gas Cleaning System (EGCS) wash-water are to be collected on board. Discharging these residues into the water bodies under the responsibility of the Panama Canal or incinerating them on board is not permitted.

PORTUGAL – No: the use of open loop scrubbers is not allowed from entry of the ship into the port, along the port channel and at berth (moored), until the ship leaves the port.

Only closed loop operations are currently allowed.

QATAR – No: As per Qatari Environmental Law, wash water originated from the open loop scrubbers, containing chemicals and /or metals are PROHIBITED to be discharged in Qatari waters.

ROMANIA – No: Information from Romanian Naval Authority dated 30/03/2021 states there is no restriction of using open‐loop EGCS into Romanian territorial waters but use is forbidden within port limits.

SAUDI ARABIA PORTS – No: Saudi Port Authorities have now banned scrubber washwater discharges from open loop EGCS systems in Saudi ports until an environmental standard is issued.

SINGAPORE – No: A ban on the use of open loop scrubbers took effect on 1 January, 2020.

SLOVENIA  – No: As of 23/3/21, the discharge of washwater of open-loop EGCS is prohibited, furthermore even the use of an open-loop EGCS in Slovenian waters is prohibited (only closed-loop EGCS is allowed).

SPAIN (ALGECIRAS, BARCELONA,  BILBAO, CARTAGENA, HUELVA CANARY ISLANDS) – No: the use of open loop scrubbers is prohibited at the Spanish ports of Algeciras, Cartagena and Huelva and restrcited at Bilbao and  Cadiz. Clarification is required from Las Palmas.

SWEDEN (STOCKHOLM, TRELLEBORG AND PETROPORT, STENUNGSUND) – No: while there is no nationwide ban in Swedish waters on the use of open loop scrubbers, some ports have placed local restrictions, for example:

  • Stockholm: there is an open loop scrubber ban
  • Trelleborg: Chalmers University in Gothenburg advised of a ban of open loop scrubbers
  • Gothenburg: Only premitted in closed loop mode
  • Petroport, Stenungsund — Vessels calling at the port are not allowed to use open loop system scrubbers.

TURKEY – No: The Ministry of Environment and Urbanization of Turkey announced on 6 April 2021 that washwater discharge of open-loop scrubbers is prohibited in Turkish waters. Vessels operating with open-loop scrubber must switch sulphur-compliant fuels.

UK – Limited. Forth Ports and Port of Dundee prohibits the discharge of materials into the Forth and Tay. This applies to discharge water from an Open Loop scrubber. Therefore, as a precaution the use of Open Loop scrubbers on the Forth and Tay is prohibited until further notice.

US (CALIFORNIAN PORTS AND WATERS) – No: the Californian ARB OGV regulations stipulate only distillate fuels can be used to comply with the 0.1% sulphur limit.

A changeover to compliant distillate fuel (marine gasoil or marine diesel oil) must be made prior to entering Californian waters.

US (CONNECTICUT PORTS AND WATERS) – No: discharge of exhaust gas scrubber washwater into Connecticut waters from any vessel is prohibited.

US (HAWAII PORTS AND WATERS) – Yes: conditional — the State of Hawaii (Clean Water Branch) issued “Blanket Section 401” Water Quality Criteria (WQC).

This covers 27 categories of effluent discharge from an applicable vessel (including EGCS washwater) that have received the best control or treatment into waters of the State of Hawaii incidental to the normal operation of the applicable vessels.

US (PORT OF SEATTLE) – No: Port of Seattle Terminals Tariff No. 5, Item 4001 states that passenger cruise ships will not discharge graywater, blackwater, or exhaust gas cleaning system wash water, whether treated or not while at berth in Port Terminals.

UNITED ARAB EMIRATES (ABU DHABI PORTS) – Yes: conditional. — Abu Dhabi Ports company (ADPC) policy is:

  • Sludge generated from exhaust gas scrubber washwater discharge must not be discharged into port waters.
  • Exhaust gas scrubber washwater discharge may only be discharged in port waters if free from pollutants.
  • Any exhaust gas scrubber sludge should be discharged from a vessel to an ADPC licensed waste disposal contractor.

UNITED ARAB EMIRATES (FUJAIRAH) – No: Notice to Mariners No. 252 from the Port Fujairah prohibits use of open loop scrubbers in its waters.

UNITED ARAB EMIRATES (DUBAI) – No: Guidelines for Vessels Calling to Dubai Territorial Waters states that the use of EGCS is prohibited within Dubai territorial waters.

he  discharge  of  wash-water  from  open-loop  scrubbers  is prohibited in  the Kenyan Ports limits.