The 0.5% low sulfur cap will go into force in less than seven months, however, according to Trident Alliance, there is still high uncertainty on the readiness of the 91 signatory nations. This is because of the lack of transparency on the enforcement measures and the preparations they have taken so far, the alliance notes. Such a lack of transparency remains a problem for the successful implementation of the new regulation, Trident Alliance believes.
All signatory nations should be ready by the 1st January 2020 and, according to Trident Alliance, transparency is very important tool for the proper implementation of the new low-sulfur regulation, especially if combined with information about specific penalties which will apply in cases of non-compliance.
If all stakeholders are aware that the nations and port state authorities are well prepared and that non-compliance may result to specific fines or other bad consequences, there will be limited or no room for choosing to be non-compliant, Trident Alliance notes.
It is even more worrying the fact that only about one third of the 91 signatory nations have some previous experience on the implementation of similar low sulfur regulations. However, even those experience is limited in the enforcement of a low-sulfur regulation in a regional areas (ECA) and not in high-seas. This is quite different and much more challenging, Trident Alliance notes, and it is not yet clear how well-prepared these nations are in order to successfully implement a low sulfur regulation in high-seas.
The coalition believes that, overall, some positive measures have been taken. The ban on carrying non-compliant high sulfur fuel which is expected to come into force on March 2020, the requirement for bunker suppliers to accompany the BDN with a confirmation that the bunker fuel is compliant with MARPOL Annex VI and the introduction of advanced sensing technologies to test compliance are among those measures.
Despite this, the level of enforcement of the IMO-2020 and the level of compliance with the measures announced still remain unknown, Trident Alliance notes. In case the lack of transparency continues, there will be a significant trend for going non-compliant, it warns. To achieve high compliance levels, there should be clear picture that the enforcement is going to be strict from the start, the coalition concludes.