Marine Operations Note: 10/2009 - EU Directive 2005/33/EC – Sulphur Content of Marine Fuels for Ships at Berth in EU Ports

11 December 2009

Marine Operations Note: 10/2009

Subject: EU Directive 2005/33/EC – Sulphur Content of Marine Fuels for Ships at Berth in EU Ports

Ref:

(a) EU Directive 2005/33/EC

(b) Marine Operations Note 6-2009

To: Shipowners/Operators and Master’s

European Union (EU) Directive 2005/33/EC requires, beginning January 1, 2010, that all vessels, regardless of flag, will be required to use marine fuels with a maximum sulphur content of 0.1 %, while at berth in EU ports. This requirement applies to any use of fuel in auxiliary engines, main engines, boilers, or any other type of combustion machinery. Vessels are considered “at berth” when at anchor, on buoys or alongside, and whether or not they are working cargo. Vessels which spend less than 2 hours at berth according to published timetables are exempt from this requirement.

The European Commission has indicated there will be no delay of the entry into force date of January 1, 2010. The EC noted that the EU member States are only obliged to "inspect" fuel quality some 6 months following the entry into force of the new requirements. However, the EC did not define what they mean by the term "inspect".

The EC has also advised that EU member States could take into account the carrying of a class approved retrofit plan providing the necessary modifications will be completed within the shortest time frame. Whether to accept such documentation is a matter for each EU member State to decide.

The Administration encourages shipowners and operators to take action as necessary to comply before the deadline and ensure vessels calling at EU ports have an adequate supply of compliant fuel on board. Vessels passing through the Baltic and North Sea Emission Control Areas should take this into consideration as well.

There is no requirement for a vessel to have a "STATEMENT OF COMPLIANCE" or any other document indicating the vessel is in compliance with the EU Directive.

Procedures for effective fuel switching should be developed and implemented. Guidance on fuel switching may be found in Liberian Marine Operations Note 6-2009.

For questions regarding this note please email safety@liscr.com or call +1 703 251 2434.

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