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SCRUBBER-PROHIBITING COUNTRIES

This information is for guidance only, as the guidelines are constantly changing. Last updated December 2020.

 

ARGENTINA – Yes: the prohibition previously in place has been 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.

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.

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. 

BERMUDA – Yes: 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 (EXCEPT VALE TERMINALS) – 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 PORTS AND 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.

PR 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.

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 – Restricted: 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.

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.

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 1November, 2020.

IRELAND (DUBLIN AND 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.

LATVIA – 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.

LITHUANIA  –  again conflicting advice has been received.

We understand that the Lithuanian authorities are studying whether EGCS washwater discharges have serious impact on the marine environment. When the results become clear, conclusions will be provided.

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.

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.

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.

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.

SPAIN (ALGECIRAS, CARTAGENA, HUELVA) – No: the use of open loop scrubbers is prohibited at the Spanish ports of Algeciras, Cartagena and Huelva.

At present, no other Spanish ports have imposed a ban.

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 — North’s correspondents advised that there is an open loop scrubber ban in Stockholm.
  • Trelleborg — Chalmers University in Gothenburg advised of a ban of open loop scrubbers in Trelleborg.
  • Petroport, Stenungsund — Vessels calling at the port are not allowed to use open loop system scrubbers.

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.

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.