Enforcement, compliance and monitoring of the IMO 2020 Sulphur limit fall under Regulations to Annex VI of the International Convention for the Prevention of Pollution from Ships (MARPOL). It states that nations that have ratified MARPOL and acceded to Annex VI are obliged to give effect to and enforce the provisions of the regulation. 

Port states must therefore enforce the provisions of MARPOL by monitoring vessels within their territorial waters and reporting non-compliance to the relevant flag state. This reporting ensures that adequate amounts of compliant low-sulphur fuel are available within their jurisdiction and provides shore-based facilities for the receipt and removal of scrubber waste. 

Against this background, the Sierra Leone Ports Authority, in consultation with the Ministry of Transport and Aviation, consented to implement this important international member state mandate in July 2021.

It is also important to note that Sierra Leone is 18 months behind the global mandate to implement the IMO 2020 statutory instrument. In view of the above, the Sierra Leone Ports Authority will serve as the consulting government agency to implement IMO 2020. Furthermore, the Port Authority will undertake a joint implementation of the regulation, together with a competent institution for efficiency and standardisation.

The Port of Freetown in Sierra Leone will extend a grace period spanning from 15 July 2021 to 31 August 2021 for vessels that are non-compliant. Penalties will not be instituted against defaulting or non-compliant vessels on or before 31 August 2021. However, a non-compliance report together with a warning letter will be issued to non-compliant vessels for corrective action to be taken prior their next call at the port and within this grace period as stipulated above.

The Port Authority will take appropriate measures to ensure compliance by initial inspections based on documents and other methods, including remote sensing and portable devices. If there are clear grounds to conduct a more detailed inspection, sample analyses and other detailed inspections may be undertaken. The samples to be analysed may be the representative samples provided with the Bunker Delivery Note.

From 1 September 2021, ship owners and operators risk penalties of up to USD15,000 should they continue to carry fuel with a sulphur content exceeding 0.5 percent. The IMO 2020 service charge will be implemented even for ships with an exhaust gas cleaning system (scrubber) installed. It is also important to note that tariffs and fines are subject to periodic reviews based on prevailing circumstances.

The IMO Implementation tariff is as follows:

Total Bunker on board (MT)	Tonnage Cost per Metric Tonne (MT) in USD
001 – 300	15
301 – 500	14
501 – 750	13
751 – 1000	12
1001 – above	11

For further information, please refer to the official letter from the Sierra Leone Ports Authority attached below.

Ships or members experiencing problems related to enforcement of MARPOL Annex V or unavailability of compliant fuel are encouraged to inform BIMCO via email hsse@bimco.org with “IMO 2020” in the subject field.

As reported on BIMCO