by Ariane Morrissey
Member states of the International Maritime Organization (IMO) are set to discuss a proposal, put forward by a group of European countries, that would open the door for restrictions on discharges from exhaust gas cleaning systems (EGCS), also known as scrubbers, in Particularly Sensitive Sea Areas (PSSAs).
The proposal, which was submitted ahead of a meeting of the IMO’s Sub-Committee on Pollution Prevention and Response (PPR 13) next week (9-13 February), would amend MARPOL Annex VI to allow countries that are Parties to a designated PSSA to prohibit EGCS discharges in that area.
PSSAs are designated by IMO as areas needing special protection because of their significance for ecological, socio-economic or scientific reasons, and their vulnerability to international shipping activities. They include the Great Barrier Reef, the Galapagos Archipelago and the Canary Islands, for example.
Ih their submission, the EU countries note divergent views on the extent of the environmental impact of EGCS discharge water on the marine environment, partly due to different research methods being used’ However, they argue that there is ample scientific and technical material indicating a negative impact on the marine environment linked to the discharge water from EGCS’, which ‘supports the need for further action to address these discharges, in particular in enclosed sea areas, shallow waters, archipelagos and other vulnerable area’.
Some countries behind the proposal, including Denmark, Finland and Sweden, have already introduced such bans in their territorial waters, which entered into force in 2025.
The submission was welcomed by environmental NGOs, including Friends of the Earth International, WWF, Pacific Environment and the Clean Shipping Coalition.
‘We argue, based on the science that has already been published, that it’s clear there’s a problem, and what we’re effectively doingis taking an air pollution problem, and in trying to address it, we’re turning it into an ocean pollution problem. We can’t do that’, said Sian Prior, Shipping Director at Seas At Risk, and Lead Advisor for Clean Arctic Alliance.
‘Ideally, we don’t want any discharge from scrubbers into the ocean’, she told ship.energy in an interview. It’s not acceptable. But as a first step, to introduce a ban in some of the most sensitive areas would be appropriate’.
Divisions on science and law
Opponents of Europe’s proposal have questioned the legality of using the PSSA framework to restrict EGCS discharges, but also whether the scientific evidence is robust enough to justify a ban.
The International Chamber of Shipping (ICS), BIMCO and the Cruise Lines International Association (CLIA) have submitted a paper to PPR 13 arguing that the proposed regulatory change is inconsistent with the legal framework for the establishment of PSSAs. Potential legal and procedural issues were also raised by Liberia and the World Shipping Council in separate submissions.
The International Bunker Industry Association (IBIA) published a paper highlighting the lack of evidence of harm to the marine environment to justify a global ban, and warning that such a move could discourage shipowners and technology providers from investing in technology that may subsequently be banned.
Michael Kaczmarek, Chairman of the Clean Shipping Alliance, which represents companies from the commercial shipping and cruise industries that have invested in EGCS, described the European proposal as an attempt to bypass IMO processes: He argues that member states should instead address the issue through the IMO’s guidelines for assessing EGCS.
‘We don’t have a problem with regulation, we have a problem with regulation that is not supported by science, or not supported by good science’, he told ship.energy. ‘Most of these countries aren’t doing their homework, and quoting work that’s been done by somebody else’, he added.
‘Do your homework. We’re talking about your local waters, so you should be doing your own testing in your own waters using the universally accepted IMO standards and processes’.
Kaczmarek pointed to a study led by CLIA, based on EGCS discharge water samples from 80 cruise ships since 2017, which reports “incremental concentrations attributable to EGCS operations; within the limits specified by IMO guidelines.
‘There’s still more research to be done, but we’ve done a lot in the last years’, he said. There’s been a number of risk assessments that have been done according to the IMO process, and the ones that have been done using the IMO approved standards have come out showing little or no risk to the marine environment’.
That view is contested by Liudmila Osipova, a scientific consultant with a PhD in quantitative ecology who was formerly a Senior Researcher at the International Council on Clean Transportation (ICCT), andis a co-author of a study on EGCS that was funded by Canada and submitted to PPR.
‘There are a lot of scientific institutions that looked into this, including very respected universities, and they published independent peer-reviewed research in highly-ranked journals showing a lot of concerning results about scrubbers’ discharge impact’, she pointed out in an interview. There is no doubt that there is enough scientific evidence to say that there is a strong concern’.
Osipova emphasised that scrubber discharge waters are acidic and contain heavy metals as well as polycyclic aromatic hydrocarbons (PAHs), the combination of which can impact marine ecosystems.
‘Its clear that there is an effect’, she argued. ‘I think the industry is trying to say it’s not strong enough to be a concern. But what some member states, scientists and non-profit coalitions are trying to say is that we dor’t want to wait until there is a cumulative effect, because it’s happening again and again, in the same spots, for years’.
A Task Team of GESAMP, a group of independent scientific experts that advises the UN, was re-established in October 2025 to assess the available evidence on the environmental impact of EGCS effluents, and propose a standard methodology for the calculation of emission factors. It is expected to continue its work during the first three quarters of this year.
Polar fuels on the agenda
The PPR 13 meetingis also set to discuss a proposal, submitted by Denmark, France, Germany and the Solomon Islands, to introduce a new fuel standard to limit black carbon emissions in the Arctic.
The proposal would amend MARPOL Annex VI to incorporate new requirements for the fuel used by ships when operating ‘within wider Arctic Waters’. The thresholds would effectively ban residual fuels or blends and require that ships use distillate fuels or other fuels with comparably low black carbon emissions.
A key debate will be to determine the geographic scope to which this fuel standard would apply. The submission on the table suggests that the requirement applies to all ships operating above a latitude of 6OºN, which is wider than the area defined by the Polar Code.
‘I am really hopeful at the moment’, Sian Prior commented. ‘From what I’ve been hearing, I think there’s a recognition, after about 15 years now of this item being on the agenda, that we need to get into this discussion of a regulation. There’s probably a bit of nervousness around what the geographic scope will be, but I think there is increasing consensus behind the need for a measure.
‘As far as the Arctic, which is warming up to four times the global average, is concerned, there is no time to lose’, she argued.
The proposal on polar fuels is opposed by Russia, which argues that more data is required on actual black carbon emissions in the Arctic before the discussion can progress.
The PPR Sub-Commiittee doesn’t have the power to approve or adopt measures, but it can make recommendations to the Marine Environment Protection Committee (MEPC), which has decision-making power.
Photo: Shutterstock
Originally published at: https://ship.energy/policy/imo-ppr-13-egcs-scrubbers-pssa-proposal-polar-fuels-black-carbon-arctic/