A number of ports and regions have already stated that they will not allow the discharge of washwater from scrubbers.
Based on the previous list, North updated the positions taken by ports that have or will prohibit the use of scrubbers, or have placed conditions on their use.
In fact, the countries that have been added to the list are the following:
The prohibition is currently suspended. Regulation No. 15/2020 of the Environment Protection Bureau, which came into force on 10 August 2020 , prohibited the discharge of washwater from the exhaust gas cleaning systems (EGCS) of national or foreign-flagged vessels into Argentinean jurisdictional, sea or river waters.
On 24 September 2020, Prefectura Naval Argentina issued Resolution DISFC-2020-22-APN-DPAM#PNA that suspended the enforcement of the above Resolution 15/2020. This resolution took effect from 3 October 2020.
IT&L Legal Consultants warn that this suspension is provisional, and the restrictions have not been permanently overturned.
Prior to 23 July 2020, advice received from local correspondents was “ based on existing provisions in national legislation, especially Law 9.966/00, the discharge of effluents generated by Scrubbers or Exhaust Gas Cleaning Systems (EGCS) is not allowed and the vessel, when in Brazilian waters, must operate with fuel within specifications (sulphur content up to 0.5% m/m)”.
However, correspondents Brazmar advised on 23 July 2020 that the Directorate of Ports and Coasts (DPC) / Navy have changed their previous guidance on the topic, and that the discharge of wash water from open loop and/or hybrid Exhaust Gas Cleaning Systems (EGCS) is allowed within Brazilian Jurisdictional Waters until the competent environmental authority has the opportunity to better assess the scenario.
This is under the assumption that the subject EGCS is approved by Class, has a plan for compliance of SOx emissions and is approved as per requirements of resolution MEPC.259 (68) of IMO.
Brazil- Vale ports and terminals
Vale instruct arriving vessels that the discharge of EGCS washwater is not allowed while operating in its Brazilian ports and terminals.
Vale recommends that vessels should be changed over to compliant fuel before entering contiguous zone or coastal waters (24 nautical miles from coastline).
India- Adani Ports
Adani Ports and Special Economic Zone Ltd has issued a circular advising that the discharge of washwater from open-loop scrubbers is prohibited.
Open-loop scrubber discharge is not permitted in Oman territorial waters.