Persistent Increase in Open Loop EGCS Bans Worldwide

Ports and jurisdictions around the world are increasingly banning open-loop EGCS (Exhaust Gas Cleaning Systems) from being used to comply with International Maritime Organization (IMO) restrictions on the maximum allowable sulfur content in marine fuels.  As of June 2020, open-loop EGCS or scrubbers are banned in parts or all of China, Singapore, the European Union, the Suez and Panama Canals, and the United States. Several ports in Korea, and many ports in the United Kingdom also ban open-loop scrubbers.

According to MARPOL Annex VI as of 1 January 2020, vessels must use fuels with a sulfur content of 0.5% or less or use an alternate means of compliance. Vessels are able to comply by using an EGCS. The controversy surrounding scrubbers relates to the washwater byproduct of open-loop systems.

Understanding Scrubbers

Open-loop EGCS take in seawater, spray it into the exhaust, and discharge this “washwater” overboard.  Closed-loop EGCS on the other hand, use alkaline-dosed freshwater onboard to spray the exhaust, then then filter the water to be recirculated.  Only a small amount of water is discharged, but the particles filtered out need to be scraped or pumped out and disposed of on land.  Open-loop scrubbers do not require large holding tanks or heavy equipment, making them less expensive to install and operate, and thus account for about 80% of scrubbers installed on ships.  A third option, hybrid scrubbers, allows vessels to alternate between closed and open-looped operations depending on local guidance.

Marine fuel is a significant expense for deep sea vessels, and in many cases low-sulfur fuels are not cost-effective for fleet operations. EGCS represent a way for vessel owners and operators to be compliant with the regulations, while also controlling costs. Unfortunately, there is much controversy surrounding how polluting the washwater from open-loop scrubbers might be. There are some parameters this washwater must meet, such as PAH and turbidity limits, but there are other aspects of washwater that are not yet regulated.

Confusion Reigns

Bans on open-looped scrubbers seem to be quietly communicated by local authorities, making it difficult for vessels to know in advance whether an open-loop system is permissible.  In the United Kingdom for example, ports have banned open-loop scrubbers individually, so while no national ban exists, vessels are unable to use them at many ports in the United Kingdom.  Other jurisdictions have not issued formal written guidance banning the use of open-loop scrubbers, despite verbally indicating to Captains and operators that such scrubbers are not permitted.  Verbal or email notice can serve as enough regulatory guidance to allow for port authorities to write up a deficiency, costing the vessel time and money.

Cutting through the Confusion

Staying up to date on scrubber regulations can be a challenge, but it doesn’t have to be. Ocean Guardian, a digital environmental compliance tool, includes the latest official EGCS regulations and guidance from around the world.  Regulations are verified and vetted by a third-party maritime law firm before being deployed to clients and updates are rolled out instantly to connected tools worldwide. Ocean Guardian also allows flexibility for operators to include verbal or emailed instructions from specific port authorities and jurisdictions in the company policies section, when formal written guidance is not available.  For a demo on Ocean Guardian, please contact





10-14-2020 at 7:58