Singapore has joined the list of ports that will ban the use of open loop scrubbers in their waters. Exhaust gas cleaning systems (EGCS) – more commonly referred to as scrubbers are an accepted equivalent measure in complying with the IMO 2020 global sulphur cap.

The use of scrubbers has split the shipping industry. With about 15 months to go, the shipping industry is broadly split into two camps, either to burn low-sulphur fuel or install a scrubber system.

But an increasing number of ports around the world are looking at the impact of scrubber use in their waters. With the discharge of wash water into the sea, open-loop scrubbers are seen by  some as simply transferring the sulphur pollution from the air to the sea. Therefore, ports and regions have already stated they will not allow the discharge of wash water from scrubbers.

This table summarises the positions taken by ports that have or will prohibit the use of scrubbers, or have placed conditions on their use.



EGCS discharge allowed?





Belgian federal law: discharge only allowed in coastal and open seawaters when at least 3nm off coast. Discharges must not imperil EU Water Framework Directive objectives.
Flemish regional law: discharge not allowed in ports or inland waters.


Inland Waterways, canals and ports within inland waterways


See: Convention on the Collection, Deposit and Reception of Waste Produced during Navigation on the Rhine and Inland Waterways (CDNI)





See: Port of Dublin’s Notice to Mariners No. 37 of 2018 Prohibition on the Discharge of Exhaust Gas Scrubber Wash Water.



All Ports

Conflicting advice

European Commission Report (2016): allowed – no restrictions, but national authorities take the position open-loop scrubber discharge should be prohibited in territorial waters and ports.

ABS Report (2018): prohibited in port waters.

Correspondents Pandi Balt Ltd 8:2018: advice – wash water discharges currently allowed under regulations, but likely to be prohibited in future.


All Ports

Conflicting advice

European Commission Report (2016): allowed – no restrictions (in accordance with IMO Wash water Guidelines MEPC 184(59)).

ABS Report (2018): prohibited in territorial waters and ports.

Lithuanian authorities are studying whether EGCS wash water discharges have serious impacts on the marine environment or not. When results will be clear, conclusions will be provided.

United States

Californian Ports and Waters


Californian ARB OGV regulations stipulate: only distillate fuels can be used to comply with the 0.1% sulphur limit;  changeover to compliant distillate fuel (MGO or MDO) prior to entering Californian waters.

United States

Connecticut Ports and Waters


Discharge of exhaust gas scrubber wash water into Connecticut waters from any vessel is prohibited.

VGP 2013: 6.5.9 Discharge of exhaust gas scrubber wash water into Connecticut waters from any vessel covered under the VGP or sVGP is prohibited.

This condition is necessary for compliance with CGS section 22a-427, Standards No.1, 2, 9, 12, 14, 15, and 24 of the CT WQS.

United States

Hawaii Ports and Waters

Yes – conditional

Additional requirements under VGP 2013 Section 6.6.

State of Hawaii (Clean Water Branch) issued ‘Blanket Section 401’ Water Quality Criteria (WQC): covers 27 categories of effluent discharge from an applicable vessel (EGCS wash water being one) that have received the best control or treatment into waters of the State of Hawaii incidental to the normal operation of the applicable vessels.

United Arab Emirates

Abu Dhabi Ports

Yes – conditional

Abu Dhabi Ports Company Policy: sludge generated from exhaust gas scrubber wash water discharge must not be discharged into port waters. Exhaust gas scrubber wash water discharge may only be discharged in port waters if free from pollutants. Any exhaust gas scrubber sludge should be discharged from a vessel to an ADPC licensed waste disposal contractor.





Ban on the use of open loop scrubbers expected to take effect on 1/1/2020.


This information is for guidance only. For up to date and definitive information, contact the local authorities or agents. Source: North of England P&I Club

Source: Marine Insurance P&I Club News 05/12/2018