Fact Sheet on NZ issues relating to
•IMO Nitrogen Oxide (NOx) Tier III
•MARPOL Annex VI and Sulphur Oxide (SOx)
The purpose of this factsheet is to assist anyone interested in this issue but not familiar with the operation of SOLAS
IMO NOx Tier III
• IMO Tier III requirements apply to new vessels and engines built since 1 January 2016. Technically, the trigger
is keel-laying after 1 January 2016 and an engine output of greater than 130kW. Earlier vessels are generally subject to
Tier II requirements.
• The difference between the Tier II and Tier III is a reduction in the production of NOx by approximately 76%.
• It is expected that any vessels being constructed today will meet Tier III requirements because this is needed
for international voyages and impacts on resale value.
• As measured by the volume of cargo carried, 88 out of 172 IMO member states have signed up to MARPOL Annex VI,
representing 96% of World tonnage.
o Lots of individual countries have not signed but they do not have significant cargo volumes.
o Most of the SOLAS vessels on the NZ-international circuit are flagged to countries that have signed MARPOL Annex
o MoT has commenced engagement with the sector and will commence cost-benefit analysis on the implications of
acceding to Annex VI. If the engagement and analysis supports the case for accession, a formal National Interest
Analysis will be carried out, informed by public consultation, with recommendations to Cabinet.
• Annex VI seeks to control SOx emissions through limitations on the sulphur content of marine fuels.
• The sulphur content limits set by the annex are
o January 2012 3.5% by mass
o January 2020 0.5% by mass
• Within the Annex, certain areas of the globe have been designated Sulphur Emission Control Areas (SECA’s). Since
1 January 2015 the sulphur limit for fuel oil used by ships in these areas has been limited to 0.10% by mass.
• Note that there are health issues in respect of SOx but MARPOL does not specifically address particulate
• Australia has signed the Annex. It already imports most of its fuel and is expected to import 0.5% fuel when the
lower requirements come in.
The refinery and availability of low sulphur fuels
• SOLAS vessels in NZ are generally using no greater than 3.5% fuel, either because of the Annex or as a
commercial decision. The fuel produced by the NZ refinery is approximately 1.9 – 2.8% (depending on viscosity/grade) and
any vessel bunkering in NZ will be using this.
• Note that fishing vessels and recreational vessels use automotive gas oil (known as AGO i.e., fuel available at
gas stations that goes in trucks and cars) so they are not part of this discussion.).
• The refinery does not blend marine diesel oil (MDO). MDO is a blend of AGO mixed with light fuel oil to create a
fuel that does not require heating but is cheaper than AGO.
• Retooling the Marsden Point refinery to produce low sulphur fuel
• The cost of retooling Marsden Point to convert all high-sulphur residues to MARPOL-compliant product will be
high and prohibitively expensive.
• The refinery is currently exploring if it is possible to produce smaller volumes of 0.5% sulphur fuel, and what
may be required to achieve this. This has not yet been fully scoped nor costed.
• Whether Marsden Point eventually produces low SOx fuel will be a commercial decision for the refinery.
• Currently, high sulphur by-products from refining have commercial value to Marsden Point. Once the 0.5 % sulphur
requirement comes into force, this situation may change, affecting the refinery’s business model in this regard. In the
event that there is a major shift to low SOx fuels, there is an open question as to how the high sulphur residues will
be disposed of or used.
Fuel usage in practice
• Ministry of Transport officials believe that IMO sulphur fuel requirements will not affect domestic shipping
until such time as New Zealand accedes to Annex VI, should Government make such a decision. Federation members do not
agree. If the rest of the world moves to implement Annex VI, then the fuel companies, as global players, will respond
and supply fuels accordingly. NZ is a very small fish at the end of the supply chain, we will be affected by Annex VI,
irrespective of NZ government decisions.
• Regardless of what NZ does, SOLAS vessels going internationally will need to comply with the requirements of the
state they are visiting. Port State Control has the power to enforce this under ‘no more favourable treatment’
provisions. Coastal ships going to Sydney or Singapore, typically for survey or repair can be affected by this.
• Federation members are already making decisions in response to MAROL Annex VI. Factors to be considered include
assumed availability of fuels, supply infrastructure, costs and the operating requirements (such as heating and
filtration) of particular engines. In some cases, decisions have already been made to operate using diesel.
• There has been some discussion in the media about vessels using a variety of fuels.
• Because vessels have multiple tanks, the opportunity for fuel switching exists.
• It is very unlikely that ships of Ratifying States will carry higher sulphur fuels for use in the waters of
non-party States or in international waters. This is because IMO sulphur limits apply to fuels used in territorial
waters of Annex VI Contracting States and ships of Ratifying States on the High Seas.
The future and the policy picture
• The maritime sector experience is that every time NZ deviates from accepted international regulation, it makes
it harder for vessel operators to comply, not easier. If there is one set of rules for trading coastal, and then another
set when the same vessels go outside of New Zealand’s EEZ, there can be additional costs and confusion
• Even if NZ does not sign up to Annex VI, all international ships calling here will still need to comply with the
requirements, and all New Zealand based ships (coastal vessels) travelling internationally, will still need to comply.
As such, the vast majority of fuel supplied to ships in NZ, will need to be compliant with the 0.5% sulphur cap. Only a
small portion of fuel would be exempt from this limit.
• As Annex VI stands, there are two routes to compliance.
o Vessel operators can continue to use high sulphur fuels (above the 0.5% cap), but need to have fitted an
exhaust gas treatment system (also known as “scrubbers”). This is generally considered to be uneconomic for the current
New Zealand coastal fleet. Retro-fitting scrubbers on existing vessels poses significant practical problems, for example
because of their size and the complexity of incorporating them into the engine system. Scrubbers have not been widely
implemented on international trading ships.Or,
o Vessels operators can use fuels with less than 0.5% sulphur content. At this time, the only fuel available in NZ
that meets this specification is diesel. In NZ, there is only one grade of diesel supplied by the refinery for all users
– marine and road going. This is relatively expensive amounting to approximately up to 50% higher cost. The actual cost increase to each user varies and is confidential.
• None of the fuel companies have yet stated what fuels they propose to supply post 1 Jan 2020. We believe that
most of them will be waiting to see if IMO adhere to this date or defer implementation to 2025. However, it seems
unlikely that they would simultaneously supply both high and low sulphur grades of fuel in the NZ market.
• Any low sulphur fuel is almost certain to be imported from Singapore as costs to modify Marsden Point to produce
this are likely to be prohibitive. However, Refining NZ is still evaluating whether the supply of some 0.5% bunker fuel
• Ships, and the fuel infrastructure that supplies them, are long term assets. Both ship owners and fuel companies
need certainty of policy to ensure that good investment choices are made.
Terms explained: Marine Diesel Oil (MDO) & Intermediate Fuel Oil (IFO)