Clean Arctic Alliance Recommendations: In submissions to the IMO during the finalisation of the regulation, the Clean Arctic Alliance (CAA) has previously proposed that the need for exemptions to the provisions of clause 43A(1) be reviewed, and clauses 43A(4) and (5) allowing waivers to the special requirements for the use and carriage of oils as fuels in Arctic waters be removed. [...] The IMO’s definition of “Arctic waters,” which is the definition that applies to Regulation 43A of MARPOL Annex I, was developed to improve the safety of ships operating in ice-covered waters which led to the adoption of a Polar Code. [...] With these criteria in mind, the Arctic region covered by AMAP includes terrestrial and marine areas north of the Arctic Circle (66°32’N), and north of 62°N in Asia and 60°N in North America, modified to include the marine areas north of the Aleutian chain, Hudson Bay, and parts of the North Atlantic Ocean including the Labrador Sea. [...] Under port state control, a country can inspect a ship docked in its port to verify that the condition of the ship and its equipment comply with the requirements of international regulations (under the Safety of Life at Sea Convention and the MARPOL Convention amongst others) and that the ship is manned and operated in compliance with these rules. [...] The CAA does not have any specific information on Russia’s plans to adopt the Regulation 43A of MARPOL Annex I, however Russia has notified the IMO that the amendments to MARPOL Annex I introducing the Arctic HFO ban will not enter into force for the Russian Federation on 1st November 2022 (the deadline for adopting the regulation).
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Table of Contents
- Clean Arctic Alliance Recommendations 1
- Summary of action by Arctic States 2
- VIII. 2
- Country Action taken 2
- Denmark Implemented ban but RAL vessels have protected fuel tanks so are exempt from the ban till 1 July 2029 allowing the continued use of HFO scrubbers. 2
- Iceland The ban does not extend to Icelandic waters. It is believed that Iceland has implemented the ban into domestic regulation for Icelandic flagged vessels. 2
- Norway Norway has already banned the use and carriage of HFO in all waters of the Svalbard archipelago and is introducing an emission control area in the Norwegian Sea. 2
- Russia Russia has notified the IMO that the HFO ban will not apply to the Russian Federation. 2
- Sweden The ban does not extend to Swedish waters. It is believed that Sweden has implemented the ban into domestic regulation for Swedish flagged vessels. 2
- United States It is believed that the United States has implemented the ban into domestic regulation for United States flagged vessels and is unlikely to issue waivers. 2
- Other flag states operating in the Arctic 2
- None have notified the IMO of any problems or lack of introducing Regulation 43A into domestic regulation. 2
- I. What is heavy fuel oil HFO 3
- II. Will HFO use and carriage be completely banned in the Arctic after 1 July 2024 3
- II. What was the purpose of Regulation 43A of MARPOL Annex I 3
- III. How does Regulation 43A of MARPOL Annex I compare to the Antarctic HFO ban 4
- IV. Do the fuel tank design requirements in Regulation 12A of MARPOL Annex I and 4
- Regulation 1.2.1 of Chapter 1 of part II-A of the Polar Code actually reduce the risk of an oil spill 4
- V. Does Regulation 43A of MARPOL Annex I apply to the entire Arctic 4
- VI. How will the ban on the use and carriage of HFO in Arctic waters be enforced 5
- VII. Have all Arctic nations adopted Regulation 43A of MARPOL Annex I 6
- VIII. Will Regulation 43A of MARPOL Annex I reduce black carbon emissions in the Arctic 6
- IX. What are the benefits of distillate fuels compared to HFO 7
- X. How do Indigenous communities feel about the HFO ban 8
