Sulphur Cap Series: Part 2 - Challenges Facing Compliance and
Challenges to Enforcement
Part 1 explored the scope of Regulation 14.1.3 of Annex VI of
the MARPOL Convention ("Regulation 14.1.3") and provided
an analysis of the contractual, penal and coverage risks to which
owners and charterers may become exposed, if they do not take steps
to comply with the Regulation by 1 January 2020.
Part 2 provides a summary of compliance challenges facing owners
and charterers, in addition to an analysis of the challenges that
the IMO faces in enforcing Regulation 14.1.3.
1. Challenges facing compliance
a) Cost implications
The first challenge facing shipping companies is the estimated
cost of compliance. The retrofitting of scrubbers or alternative
fuel engines on vessels is likely to involve initial investments in
excess of US$1 million. These options are explored in Part 3 of the
series.
