Clyde & Co Legal Update: A Practical Overview of the IMO 2020 Sulphur Cap – Part 2

Emissions, Environment, Legal, Pollution — By on November 14, 2018 at 4:52 PM

A Practical Overview of the IMO 2020 Sulphur Cap

Part 2: Challenges Facing Compliance and Challenges to Enforcement

With Regulation 14.1.3 of Annex VI of the MARPOL Convention (“Regulation 14.1.3”) coming into effect in January 2020, there are still numerous challenges surrounding compliance and enforcement, which have cast uncertainty over the effect that the Regulation will have on the international maritime industry, and on individual shipping companies.

This three-part series aims to draw owners’ and charterers’ attentions to the practical issues that they should be aware of, ahead of the implementation of Regulation 14.1.3, and to highlight the various measures that they should now be considering.

In Part 2 we provide 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.

Sulphur Cap Series:

Part 1: Scope of the Regulation and the Risks of Non-Compliance

In Part 1 we explored the scope of Regulation 14.1.3 and provided an analysis of the contractual, penal and coverage risks to which owners and charterers may become exposed.


Beth Bradley

Legal Director

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Benjamin Bryant


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Ioanna Tsekoura


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