❓Received a question:
I haven’t been to the North Sea for a while, what should I do?
⚖️ Regulatory framework
The main document is MARPOL Annex VI.
It expressly allows for equivalent methods of complying with sulfur (SOx) limits, including EGCS/scrubbers.
🌍 North Sea ECA
The North Sea ECA requires a SOx equivalent of 0.10% sulfur.
What this means in practice:
- ✅ HSFO + scrubber = compliant
- ✅ Open-loop scrubber permitted
- ✅ Switching to diesel when entering the ECA is not required
- ❌ No MARPOL violation if:
- scrubber in ECA mode
- parameters within limits
- there are correct log entries
💬 From a MARPOL perspective: Open-loop scrubber is a legal way to comply with ECA requirements
📋What is usually checked
Within the ECA (without ports):
- EGCS functionality
- SOx compliance
- entries:
- entering ECA
- scrubber mode (ECA / 0.10)
🎓 Captain’s conclusion:
🟢ECA ≠ mandatory diesel
🟢If The scrubber is working properly in 0.10 mode—you can safely go to HSFO + open loop.
If we get 150 ❤️, in the second part we’ll look at why everything changes when approaching EU ports and where the “sudden” demands to close the discharge come from.
Author: Captain Artem Panchenko
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