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Updated 13 April 2016

Ships calling at key ports in the Yangtze River Delta must use fuel with a sulphur content not exceeding 0.50 per cent whilst berthed.


This Alert has been replaced by our Alert of 26 August 2016 – http://www.gard.no/go/target/21736671/


Following the publication of our Gard Alert “China introduces 0.50 per cent sulphur cap in major port regions” on 14 December 2015, Gard’s correspondent Huatai Insurance Agency & Consultant Service Ltd. has published three further circulars with information from Chinese authorities concerning changes to the implementation of the regulation designating new Chinese emission control areas (ECAs).

Implementation plan

The regulation introducing a sulphur cap of 0.05 per cent in the three designated ECAs entered into force in the Yangtze River Delta ECA on 1 April 2016. From this date, ships have been required to use fuel with a sulphur content not exceeding 0.50 per cent whilst berthed at the key ports within the Yangtze River Delta ECA: Shanghai, Ningbo-Zhoushan, Suzhou, and Nantong. Ships must switch to compliant fuel within one hour of arriving at their berth and burn compliant fuel until not more than one hour prior to departure.

It is also understood that Chinese authorities encourages ships to exceed the mandatory requirements in the regulation by switching to 0.50 per cent sulphur fuel prior to entering the Yangtze River Delta ECA waters. Ships are also encouraged to use fuel with a sulphur content not exceeding 0.10 per cent whilst berthed.

According to Gard’s correspondent, local port authorities in the remaining ECAs, the Pearl River Delta and Bohai-rim Waters, have currently no plans of implementing the regulation during 2016.

See our correspondent’s circular No.:PNI 1601 of 29 January 2016 for additional details.

Guidelines on implementation

The China Maritime Safety Administration (MSA) has issued guidelines on the implementation and supervision of ECAs that detail how they will verify compliance with emission control measures. The methods of verification are in line with those set out in MARPOL Annex VI and include:

  • for ships using low sulphur fuel, check of bunker delivery notes, fuel change-over procedures, engine room logbook records and fuel oil quality/samples; and 
  • for ships using alternative measures, such as shore power, LNG or exhaust gas scrubbers, check of the International Air Pollution Prevention (IAPP) Certificate/Record and engine room log book records.


Penalties are imposed for non-compliance, including warnings, instruction to rectify violations, detention of ships, and/or monetary fines in accordance with the Law of the People’s Republic of China on the Prevention and Control of Air Pollution, Article 106.

See our correspondent’s circular No.:PNI 1602 of 22 February 2016 for additional details.

Recognising that some vessel operators may encounter challenges when seeking to comply with the new regulation on air emissions, the Shanghai MSA announced on 29 March 2016 that an exemption and exception scheme has been established as part of their procedure for implementation.

See our correspondent’s circular No.:PNI 1605 of 11 April 2016 for additional details.


Members and clients are recommended to take the appropriate measures when calling at Shanghai, Ningbo-Zhoushan, Suzhou and Nantong to ensure compliance with the relevant requirements and to avoid any delay or penalty being incurred by the ship.

However, as local cities and relevant authorities continue to evaluate the implementation of the new regulation and the control measures to be taken, the applicable port requirements at any given time should be verified with the agent or port authorities well before arrival.


We are grateful to Gard’s correspondent Huatai Insurance Agency & Consultant Service Ltd. for providing this information.