India

India’s ports and waters are outside of IMO MARPOL Annex VI Emission Control Areas. Under Annex VI regulation 14 the maximum fuel sulphur limit of 0.50% applies from 1 January 2020. Regulation 4 also applies and approved EGCS can be used as an alternative means of compliance.

Engineering Circular No. 02 of 2019 issued by the Directorate General of Shipping 28 August 2019 states in paragraph 5(e):
“Wash water resulting from exhaust gas cleaning systems shall not be led into the sea, including enclosed ports, harbour and estuaries, unless the wash-water meets the criteria set out MEPC 259(68) and applicable local regulatory requirements of the coastal state.”

DGS circulars relevant to MARPOL can be found at https://www.dgshipping.gov.in/Content/DGSCirculars.aspx?branchid=20

03 October 2020

Adani Ports and Special Economic Zone Limited (APSEZ) issued  Circular number: APSEZL/Marine/16/2020, titled Trade Notice 16 Guidelines on Compliance with MARPOL Annex VI, which can be found under Mundra Port downloads at https://www.adaniports.com/Downloads.

The circular confirms that all ships calling Adani Group ports & terminals are advised to strictly comply with DGS Circular 02/2019. In addition with regards use of EGCS as an alternative method of compliance:

  • …vessels fitted with hybrid type of scrubbers should switch over to closed loop mode of operations before entering port limit.
  • Ships fitted with closed loop can continue using the system and ensure that it is in good working order throughout stay of vessel in port.
  • Ships will not be permitted to use the open loop system at Adani ports. Ships having open loop type scrubber should change over to compliant fuel before entering the port.
  • If there is any failure of any of the permitted systems the guidelines and reporting as per the circular needs to be strictly followed.
  • Ships calling Adani ports would be required to submit certification for compliance with the above.
  • Ships may be subject to Port state control inspection for validation of necessary compliance.
  • Above will come in to force w.e.f 1st November 2020.

APSEZ currently operates the following 10 domestic ports & terminals in the six maritime states of Gujarat, Goa, Kerala, Andhra Pradesh, Tamil Nadu and Odisha:

  • Mundra Port, Gujarat
  • Tuna Terminal, Gujarat
  • Dahej Port, Gujarat
  • Hazira Port, Gujarat
  • Mormugao, Goa
  • Vizhinjam Port, Kerala
  • Kattupalli Port, Tamil Nadu
  • Ennore Terminal, Tamil Nadu
  • Vizag Terminal, Andhra Pradesh
  • Dhamra Port, Odisha

* It was reported 05 October 20 that APSEZ had completed the acquisition of Krisnapatnam (click to read).

09 October 20 Gulf Agency Company reported that the Port would be subject to the additional guidelines (click to read). Gulf Agency Company subsequently reported 11 November 20 that Krishnapatnam Port Company has issued a Trade Circular revoking the earlier circular dated 6 October banning the use of open loop scrubber systems. (click to read)

Port locations are shown in this graphic from the APSEZ corporate brochure: