Since the introduction of the IMO 2020 regulations, scrubbers have emerged as an option for complying with the new regulations regarding sulfate emissions. Many ship owners have installed scrubbers as a way of converting existing systems to be IMO 2020 compliant. However, differences in the rules per country regarding the use of scrubbers and the discharge of washing water are starting to have a significant impact on how scrubbers can be used.
In an increasing number of countries, limitations are being placed on where wash water can be discharged and where open loop operations can be conducted. For example, Belgium has recently introduced legislation which limits the discharge of washing water to open sea more than 3 nautical miles from the shore, and provided that there is no breach of the objectives of the EU Directive. In China, the discharge of wash water has likewise been banned in all but limited areas. Vessels which are unable to store wash water must switch to low sulphur fuels before entering any prohibited areas. In Portugal, the use of open-loop scrubbers is not permitted at all when the vessel enters the port, along the harbor channel and at the quay.
It appears that the discharge of washing water from “open-loop” scrubbers into territorial waters is increasingly being limited or banned. We recommend owners to contact their agents before entering a harbor to confirm the rules in force there. In this way breaches of IMO 2020 can be prevented.