Suez Canal has banned discharge of wash water from open-loop scrubbers

Overview

At the end of 2019, the Suez Canal Authority issued a circular (no. 8/2019) related to the IMO 2020 sulphur regulation, in which it also placed a ban on the discharge of wash water from open-loop scrubbers while transiting the Canal.

The circular has been read by BIMCO, and it does not say that the use of High Sulphur Fuel Oil (HSFO) is allowed while sailing in Egyptian waters. The circular only addresses that Egypt is not yet a signature state to MARPOL Annex VI and thus cannot enforce MARPOL Annex VI as a coastal state or as a port state.

BIMCO believes it is however important to remember that if the ship’s flag state is a signature state to MARPOL Annex VI, the use of HSFO is not allowed, regardless of which waters the ships is sailing in, unless the ship has an approved scrubber installed.

Furthermore, it should be emphasised that even for ships not flying the flag of a signatory state to MARPOL Annex VI, it would be a breach of the “no more favourable treatment” provision of MARPOL 73, Article 5, paragraph (4) if the ship burned HSFO without operating a scrubber when subsequently calling a port of a signatory state.

(4) With respect to the ships of non-Parties to the Convention [MARPOL], Parties shall apply the requirements of the present Convention as may be necessary to ensure that no more favourable treatment is given to such ships.

It is BIMCO’s understanding, based on the wording of the circular, that discharge of wash water from open-loop scrubbers while transiting the Suez Canal is banned, whereas fuel oil with a sulphur content exceeding 0.50% may be used in connection with hybrid scrubbers or closed-loop scrubbers while transiting the Canal, as long as no wash water is discharged. However, the use of non-compliant HSFO is not allowed without the use of a scrubber.

Download RELATED Documents

  • Download Icon

    Suez Canal Authority Circular No. 8/2019 0.7 MB

    Download now
Christian Baekmark Schiolborg
in Copenhagen, DK

Coronavirus

Access BIMCO's COVID-19 related articles and advice.

Read more

VPS Bunker Alerts

Veritas Petroleum Services (VPS) publish regular Bunker Alerts based entirely on fuel samples and have kindly permitted BIMCO’s Members to access this information.

The Bunker Alerts are not intended to be an evaluation of overall bunker quality in the port or area concerned, but usually highlight a specific parameter within the fuel which has raised a quality issue.

Latest piracy reports

 

Latest industry releasable threats

 
 

ELSEWHERE ON BIMCO

Contracts & Clauses

All of BIMCO's most widely used contracts and clauses as well as advice on managing charters and business partners.

Learn about your cargo

For general guidance and information on cargo-related queries.

More about cargo

BIMCO Publications

Want to buy or download a BIMCO publication? Use the link to get access to the ballast water management guide, the ship master’s security manual and many other publications.

About a new business partner

We can help members check new business partners. We also help to recover millions of USD (undisputed) funds every year.