1. What is the enforcement orcement date for this regulation?
A. From 1 January 2012, the MARPOL Annex VI global fuel sulfur limit for fuel oil will be reduced from 4.50% to 3.50%.

2. Who is responsible for the 3.50% limit? Is the onus on the supplier or the fuel user?
A. All bunker suppliers inclusive of those supplying fuel oils outside of ECAs will have to comply with the new limit.

This is in line with Regulation 14.1 of the Revised MARPOL Annex VI. It is important for ship?owners and operators to ensure that any fuel oil on board their vessels with sulfur content exceeding 3.50% be fully consumed before 1 January 2012 and any future deliveries comply to the 3.50% limit.

3. If a ship is carrying fuel with sulfur greater than 3.50% on Jan 1 2012, will it be allowed to use up this fuel?
A. There is no provision for a period of grace as to the implementation of the 3.50 % limit. Furthermore there is no policy or period of grace as to vessels using up their stocks of fuel greater than 3.50 % beyond this date.

From the point of view of supply ? clearly if fuel is found to have been supplied above 3.50 % after 1st January 2012, it would be non compliant.

4. Will the authorities be tolerant of breaches of the limit?
A. No, we are told there is no grace period for the implementation since there has been a long notice period for the changeover.
However a specific state port may use its discretion but, to be on the safe.

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Infomarine On-Line Technical Library

File	Description	File size
BUNKER FUEL SULFUR LIMITS.pdf	BUNKER FUEL SULFUR LIMITS	187 Kb
TechUpd 2011_12_17 - BUNKER FUEL SULFUR LIMIT OF 3.50% - FREQUENTLY ASKED QUESTI	BUNKER FUEL SULFUR LIMIT OF 3.50% FREQUENTLY ASKED QUESTIONS	187 Kb