Regulatory Developments: Maritime Emissions
VANESSA C. DIDOMENICO
Maritime environmental regulations have become increasingly prominent internationally as concerns over climate change and air pollution intensify. The shipping industry is under mounting pressure from governments,
VANESSA C. DIDOMENICO environmental organizations, and the public to reduce its environmental footprint. This pressure is
ASSOCIATE compounded by the complexity of navigating a rapidly evolving regulatory landscape, making compliance a critical and challenging priority for maritime stakeholders. International cooperation has been essential in shaping these regulations, as countries and organizations work together to establish unified standards and enforcement mechanisms.
Specifically, the International Maritime Organization(“ IMO”) has introduced several amendments to MARPOL Annex VI( emissions) that are entering into force within the next few months and are expected to significantly influence vessel operations and compliance strategies worldwide. These regulatory developments are expected to have far-reaching effects on global shipping practices, driving innovation and operational changes across the industry. Below is a selection of recent and upcoming maritime emissions-related regulatory developments, which demonstrate the global impact and growing importance of these regulations.
The Mediterranean Sea Emissions Control Area The Mediterranean Sea became an Emissions Control Area(“ ECA”) on May 1, 2025, under MEPC. 261( 79), which reduced the maximum sulfur content allowed in marine fuel from 0.5 percent to 0.1 percent. The Mediterranean Sea is the fifth designated ECA, joining the Baltic Sea, North Sea, North American Area, and U. S. Caribbean Sea Area.
Looking further ahead, on March 1, 2026, under MEPC. 392( 82), the Norwegian Sea and Canadian Arctic will be designed as ECAs with respect to nitrogen oxides, and on March 1, 2027, one year after the amendments enter into force, with respect to sulfur oxides and particulate matter.
Other Amendments to MARPOL Annex VI On August 1, 2025, additional amendments to Annex VI under IMO Resolution MEPC. 385( 81) regarding fuel sampling, bunker delivery notes(“ BDN”), major engine conversions, and fuel consumption data sharing enter into force.
Fuel Oil Sampling and Bunker Delivery Notes
The fuel oil sampling and BDN requirements are of particular importance to shipboard personnel and bunker suppliers. These amendments clarify the definitions of fuel oil( any fuel delivered to and intended for use on board a ship) and gas fuel( a fuel oil with a vapor pressure exceeding 0.28 MPa absolute at a temperature of 37.8 ° C). They also provide exemptions for in-use onboard sampling points for low-flashpoint fuel and gas fuel( Regulation 14.12), and require the BDNs for gas and low-flashpoint fuels to meet the informational criteria listed in Appendix V to Annex VI( Regulation 18).
As of August 1, 2025, a BDN for low-flashpoint fuel 1 and gas fuel will be required to state:
• Name and IMO Number of receiving ship;
• Port where fuel is received;
• Date of commencement of delivery;
• Name, address, and telephone number of fuel supplier;
• Product name( s);
• Quantity in metric tons;
• Density determined by a method appropriate for the fuel, including the temperature;
• Declaration signed by the supplier that the fuel meets the fuel quality requirements of MARPOL Annex VI Regulation 18; and
• The sulfur content of the fuel specifically for use on board as tested by an appropriate method, or a statement that, when tested by an appropriate method, the sulfur content is less than 0.001 percent m / m.
The new requirement for low-flashpoint and gas fuels could lead to potential non-compliance if not carefully followed. It is therefore essential to ensure BDNs include all the required information.
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1. Low-flashpoint fuel means gaseous or liquid fuel oil having a flashpoint lower than otherwise permitted under Paragraph 2.1.1 of Regulation 4 of Chapter II-2 of the International Convention for the Safety of Life at Sea(“ SOLAS”), 1974, as amended.
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