The Trident Alliance believes robust and effective enforcement is vital if the full health and environmental benefits of the 2020 sulphur cap are to be achieved while also preserving fair competition. At MEPC 73 in October, IMO Member States must formally adopt the carriage ban on non-compliant fuels for implementation in 2020, as it is a fundamental tool for securing strong global enforcement.

The entry into force date of the 2020 global 0.50% sulphur cap is set in stone. From the 1st of January 2020 the maximum permissible sulphur content for marine fuel will be reduced from 3.50% to 0.50% for all vessels that are not equipped with a scrubber.
The 2020 regulation change will provide a reduction in the global sulphur cap of more than 80%, with considerable environmental and health benefits. The new regulation will also significantly increase shipowners’ operating costs. Therefore, robust and effective enforcement is vital to ensure fair competition is maintained.
At the next IMO MEPC meeting in October, the carriage ban on non-compliant fuel is on the agenda for formal adoption, to take effect in March 2020. There are now attempts to defer implementation due to uncertainty over fuel attributes, matters that are already being addressed by the relevant IMO bodies, and which well-prepared shipowners have already taken into consideration.
The Trident Alliance believes that the IMO carriage ban on non-compliant fuels is a crucial enforcement tool in the successful implementation of the global 2020 sulphur cap. Trident Alliance Chair, Roger Strevens, says:
“The Trident Alliance stands firm on the need for robust and effective enforcement and we view the carriage ban on non-compliant fuel as a very strong tool to secure that outcome.”
“After 1st January 2020 it is not necessary to have high sulphur fuel in the fuel tanks of vessels without scrubbers installed. Therefore, the Trident Alliance cannot accept any postponement of the carriage ban. We strongly urge all Member States to stand firm on this.”
The carriage ban on non-compliant fuel strengthens the hand of enforcement authorities by removing the requirement to prove that a vessel has been using non-compliant fuel.  Just having it in any fuel tank on board, except for vessels fitted with scrubbers, will be a breach of the regulation. This provides a needed shift in the burden of proof, making enforcement easier and stronger.
“With 450 days to 2020, preparation and commitment is the only way forward for all parties now. The industry needs to focus on the big change-over and make robust plans for this. Member states, on their side, need to focus on effective enforcement to guarantee a level playing field in 2020,” says Roger Strevens.