Brazil

Brasil Directorate of Ports and Coasts (DPC) Circular No 7/2019, 22 November 2019, confirms that all ships in Brazilian territorial waters and national ports must comply with the MARPOL Annex VI requirement to use fuel with a sulphur content no greater than 0.50% from 1 January 20 (paragraphs 3.1 and 3.2). EGCS are allowed as an alternative method of compliance (see paragraphs 3.3 and 3.4), provided the equipment is approved, has documentation and is operated as per MEPC.259(68) Guidelines for Exhaust Gas Cleaning Systems. (Click here to view circular)

DPC circulars can be viewed at https://www.marinha.mil.br/dpc/circular

It should be noted that there have been reports by P&I club corresponents in Brazil (e.g. https://proinde.com.br/news/brazilian-maritime-authority-changes-position-on-open-loop-scrubbers/) that discharges from open loop EGCS were or were to be prohibited in Brazilian waters, however it appears that the advice of regulators has been changing and there is no formal notice to this effect, so Circular No.7/2019 still applies.

A number of sources also cite a statement by Vale S.A. dated 20 December 19 recommending that to comply with Brazilian environmental law ships only use Low Sulphur Fuel Oil within 24 nautical miles of the Brazilian Coast. Also that EGCS wash water should not be discharged overboard within Brazilian waters or while inside the Vale S.A. ports and terminals of (i) Ponta da Madeira, (ii) Tubarão & Praia Mole Complex and (iii) Ilha Guaiba. Owners/Masters may be asked to provide written confirmation of compliance while inside Vale’s ports and terminals. Non-compliance could result in berthing being rejected and owners being responsible for associated costs.

Vale port regulations can be found at https://www.vale.com/logistics (click on the port name). It should be noted that the above Vale statement regarding no EGCS discharges appears not to be in any of the regulation documents.