The short answer
What you need to know
Marine fuel compliance depends on where and when a ship operates, as well as the fuel and compliance system it uses. A product name alone does not establish whether a fuel is suitable for the voyage.
- The global fuel sulphur limit is 0.50% m/m outside designated emission control areas; the ECA limit is 0.10% m/m.
- The Mediterranean requirement has applied since 1 May 2025. Canadian Arctic and Norwegian Sea sulphur requirements apply from 1 March 2027.
- Match the route, technical requirements and delivery documentation before comparing prices.
What do the sulphur limits mean?
MARPOL Annex VI sets the international framework. The global 0.50% sulphur limit took effect on 1 January 2020. The notation m/m means a percentage by mass. Approved equivalent arrangements, such as exhaust gas cleaning systems, may allow use of higher-sulphur fuel; local restrictions on discharge can still matter.
Do not treat “marine gas oil” or “low sulphur fuel” as a complete purchase specification. Ask for the contractual sulphur maximum, the applicable fuel grade and the vessel’s technical acceptance criteria. A useful comparison starts with fuels that the operator can actually receive and use.
Separate designation from compliance dates
The Mediterranean Sea became subject to the 0.10% sulphur requirement on 1 May 2025. A voyage into the region needs to account for this even if the fuel was purchased elsewhere.
The Canadian Arctic and Norwegian Sea ECAs entered into force on 1 March 2026, with the sulphur requirement applying from 1 March 2027. These are different milestones. The date in a designation announcement is not necessarily the date on which a new fuel limit starts.
| Area / rule | Sulphur requirement applies |
|---|---|
| Global cap outside ECAs | 1 January 2020 |
| Mediterranean Sea ECA | 1 May 2025 |
| Canadian Arctic and Norwegian Sea ECAs | 1 March 2027 |
Sources: IMO: Mediterranean Sea sulphur emission control area · IMO: New emission control areas in the Canadian Arctic and Norwegian Sea · IMO: IMO 2020 sulphur limit: questions and answers
Check what accompanies the delivery
Under Regulation 18, fuel deliveries to ships required to carry an International Air Pollution Prevention certificate are documented through a bunker delivery note, subject to the regulation’s provisions and exceptions. The note is retained for at least three years. The representative sample remains under the ship’s control until the fuel is substantially consumed, and for at least 12 months.
Check that the order, delivery note, sampling record and laboratory result all identify the same delivery. A test result is only useful if it can be linked to the fuel received. Agree how to report any differences before bunkering begins.
Plan the voyage before buying the fuel
Start with the planned voyage and delivery date. Ask the vessel operator to confirm the relevant area boundaries, fuel changeover plans and equipment limits. Include these requirements in the enquiry so they can be addressed before delivery.
A lower product price may come with extra costs for separating fuels, testing or handling. When comparing offers, list the specification, delivery dates, documentation and responsibilities. This helps with purchasing but does not replace the vessel’s compliance procedures.
Fuel unavailability reporting is not a general exemption from the sulphur rules. Treat availability concerns as something to resolve with the operator and authorities through the appropriate process, not as a contractual shortcut.
Sources: IMO: IMO 2020 sulphur limit: questions and answers · IMO: Fuel oil quality — Regulation 18
Put it into practice
Your buyer checklist
Use these questions when speaking with your supplier and technical advisers.
- Identify the delivery port, voyage areas and relevant sailing dates.
- Have the operator confirm the required grade, sulphur maximum and equipment compatibility.
- Agree quantity, delivery method, sampling arrangements and documentary requirements.
- Check delivery and sample identifiers against the order.
- Confirm any local port or discharge restrictions with the operator.
Sources & scope
International MARPOL sulphur guidance, with selected regional dates checked on the date below. This is not a complete list of ECAs, a boundary chart, a vessel compliance plan or a statement of local port law. Consult the IMO instruments and the relevant flag, coastal and port authorities for the voyage.
Source check: . Written with AI assistance using the sources below. This guide has not had an independent technical or legal review. The buyer checklist contains practical suggestions, not additional regulatory requirements.
