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Sulphur Limits For Ships in EU Ports
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From 1st January 2010 the European Parliament Directive2005/33/EC came into force. As well as reinforcing the limits
of sulphur for vessels operating in SECAs, and limiting the sulphur content of fuels used ashore in the EU, it also
introduced legislation governing the maximum sulphur content of fuels used by inland waterway vessels and ships at
berth in Ports which are part of the European Community. The limit placed is 0.1% Sulphur, which is the maximum
sulphur content of Gas Oil

The rules state that the limit applies for ships at berth in EU ports allowing sufficient time for the crew to complete any
necessary fuel change over operation as soon as possible after arrival at the berth and as late as possible before departure.
The change over must be recorded in ships log books.

It does not apply to ships in port for less than 2 hours, to vessels who "cold iron" i.e. change over to shore power in port.
Certain vessels operating in the territory of the Hellenic Republic are exempt until 1st January 2012.

Some confusion has arisen over the interpretation of the Directive. It does not mean that the main engine has to be
changed over to gas oil, but the generator engines must be changed over "as soon as possible". MIN 376 issued by the
MCA as an interim measure
gives guidance on this point for ships at UK ports. Because the directive states that ships at berth for up to two hours are
exempt it can be inferred that a reasonable time for change over can be considered as 1hour after arrival and 1hour before
the ship sails.

The MIN also gives guidance on the definition of "at berth", and states it applies to ships at anchor within port limits.
Outside port limits, then Annex VI of MARPOL applies.

Because the limit will also apply to boiler fuel used whist alongside, Companies have applied for exemptions until their
boiler burners can be adapted to burn gas oil. This affects not only burner design but also purge times for the boiler.

Vessels must arrive at the port with supplies of the 0.1% sulphur fuel on board. They cannot arrive and then take on the
fuel.

some companies have misinterpreted the directive and have issued instructions to change over to 0.1% sulphur fuel on
entry to a SECA.

It does not apply to ports within a SECA but outside the EU (for example ST Petersburg) although individual countries
outside the EU may have their own regulations. It also applies to ports within the EU but outside a SECA (for example
Lisbon).

LINKS: EU Directive 2005/33/EC MIN 376

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