Global low sulphur fuel requirements

How to comply with low sulphur fuel requirements.

All ships must follow low sulphur fuel requirements.

Ships must:

  • use fuel oil containing a maximum of 0.50 per cent m/m sulphur. 
  • not carry fuel oil with a sulphur content of more than 0.50 per cent m/m (unless it is being carried as cargo). 

These limits aim to reduce the impacts of sulphur oxide (SOx) on the environment and human health.

This applies to all ships and vessels globally and has been in force since early 2020. 

MARPOL Annex VI, the Protection of the Sea (Prevention of Pollution from Ships) Act 1983, and Marine Order 97 implement these requirements. 

There are significant penalties for not complying with these requirements. 

How to comply

To comply with the low sulphur limit, ships can use:

  • fuel oil with a maximum sulphur content of 0.50 per cent m/m 
  • alternative fuels such as liquefied natural gas (LNG) or compliant marine diesel oil with a sulphur content of 0.50 per cent m/m or less
  • an alternative measure to reduce sulphur oxide emissions. 

An Exhaust Gas Cleaning System (EGCS) or “scrubber” is the only approved alternative measure. Ships operating an approved EGCS can use and carry fuel oil with a sulphur content of more than 0.50 per cent m/m. 

Enforcement of the low sulphur limit 

Our approach to compliance and enforcement of the sulphur limit is in line with: 

Port State Control (PSC) Initial inspection

This inspection checks if the ship is compliant with its documentation and the requirements. 

For initial PSC inspections, we rely on documentation, such as: 

  • bunker delivery notes
  • oil record books
  • shipboard procedures. 

Based on the outcomes of this inspection, we may conduct a more detailed inspection. This may include a fuel oil sample analysis to verify compliance.

There are penalties for not complying. See the Protection of the Sea (Prevention of Pollution from Ships) Act 1983 for the relevant penalties.

We may also detain or refuse access to an Australian port of non-compliant vessels, or grant conditional entry.

Fuel covered by the sulphur limit

The low sulphur limit applies to all fuel used by a ship for propulsion or operation. This includes all gas, petrol, distillates, residual and blended fuels.

Most diesel and petrol supplied as marine fuel in Australia is below the 0.50 per cent m/m sulphur content limit. But operators should confirm the sulphur content of the fuel with the supplier.

Checking the sulphur content of fuel 

Operators should confirm the sulphur content of the fuel with the supplier.

If a ship is 400 gross tonnage or above, the fuel supplier must provide:

Ships must keep copies of BDNs on board for at least 3 years. 

The supplier and the master or officer in charge must sign the provided samples. Operators must keep these samples on board for at least 12 months (or until the fuel has been mostly consumed).

In Australia, marine fuel suppliers must register with AMSA. See a list of local fuel suppliers.

Fuel carried for emergency equipment

Fuel carried by a ship for use in emergency equipment must also contain a maximum of 0.50 per cent m/m sulphur.

Fuel in Emission Control Areas (ECA)

The sulphur content of fuel oil used on board vessels operating in an ECA must not exceed 0.10 per cent m/m. See a list of IMO designated ECA’s in regulation 14.3 of MARPOL Annex VI[TE1] .

Using exhaust gas cleaning systems (EGCS) in Australian waters

Ships can use an EGCS in Australian waters to comply with the sulphur limit that is:

Learn more about requirements for using an EGCS.

What to do when a ship cannot get compliant fuel 

If a ship is not able to get compliant fuel oil, it must send a fuel oil non-availability report (FONAR) to: 

  • its flag administration
  • the Competent Authority at the ship’s next port of destination. 

The ship must send this report as soon as it is aware that it will not be able to get compliant fuel.

Use AMSA form 1857 to make a FONAR report when the next port of destination is an Australian port.

Ships must keep a copy of the FONAR on board for at least 36 months.

Exceptions to the 2020 sulphur limit

MARPOL permits a ship to exceed the sulphur limit when acting to secure the safety of the ship or to save a life at sea.

Where a ship with an EGCS gets damaged and releases emissions that exceed the sulphur limit, the ship must take all reasonable steps to reduce emissions. This may include carrying out repair works or switching to compliant fuel.

Ship Implementation Plan (SIP)

While not mandatory, we recommend ships have an SIP to show how they will comply with the sulphur limit. The IMO provides guidance on the development of a SIP (MEPC.1/Circ.878).

Background

Why was the sulphur content of marine fuel reduced?

Burning fuel containing sulphur releases sulphur oxides (SOx) into the air. In high concentrations, SOx contributes to poor health. It can result in serious illnesses such as lung cancer and respiratory issues. High levels of SOx can also lead to acid rain and cause acidification of soil and freshwater. 

In October 2016, the International Maritime Organization (IMO) agreed that from 1 January 2020 all ships and vessels must use fuel containing no more than 0.50 per cent m/m sulphur.

To support this, the IMO agreed that from 1 March 2020 all ships and vessels cannot carry fuel containing more than 0.50 per cent m/m sulphur.

Relevant regulations

Our approach to the sulphur limit and carriage ban is in line with Australia’s existing Port State control (PSC) regime. It also takes into account the 2019 Guidelines for port State control under MARPOL Annex VI, Chapter 3 (resolution MEPC.321(74)).

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Last updated: 1 August 2025

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