The International Maritime Organisation (IMO) considers exhaust gas scrubbers to be an acceptable means of reducing vessels’ sulphur emissions and ensuring compliance with MARPOL Annex VI. A separate guideline, Resolution MEPC.259(68), specifies the requirements for the verification, testing, survey and certification of scrubber systems and sets out the criteria for discharging scrubber wash water into the sea.
However, some coastal states and ports have implemented local regulations with more stringent requirements that restrict or completely prohibit the discharge of wash water from open loop scrubbers or prohibit the use of scrubbers.

Euroshore, as stated in its Position Paper regarding the use of Scrubbers (….insert link with the website) is against the discharge of wash waters from open loop scrubbers, and fully support any initiative from ports authorities or states to ban that practice.

We are currently aware of the following regions/states/ports with local regulations that have an effect on exhaust gas scrubber wash water discharge, although the list should not be considered as complete.



China’s Ministry of Transport (MOT) issued its ‘Notice on regulating the implementation of supervision and management of ship air pollutant emission control areas’ which states that from 1 January 2019 discharge of wash water from scrubbers is prohibited in the county’s inland emission control areas (ECAs), port water areas of coastal domestic ECAs and Bohai Bay waters. A ban in the entire coastal domestic ECA will be announced in due course.


The Maritime and Port Authority of Singapore (MPA) prohibits discharge in Singapore port waters from 1 January 2020. It published useful guidance on IMO 2020 sulphur limits:  ships fitted with open loop scrubbers are advised to ‘carry out the switch to either closed-loop mode or to compliant fuel well in advance of the vessel’s arrival at the port waters’.


In 2018 DG Engineering Circular 05, India seems to indicate that scrubber wash water discharges are allowed, if the criteria set out in MEPC.259(68) are met and provided local regulations are followed. However, it is not clear if local restrictions will be imposed in some areas.

Abu Dhabi, UAE

In 2013, Abu Dhabi authorities issued ‘Vessel discharge and maintenance guidelines for owners, masters and agents’ stating scrubber wash water can be discharged in port waters if free form pollutants whilst scrubber sludge should be discharged from the vessel to an Abu Dhabi Ports Company (ADPC) licensed waste disposal contractor.



The European Commission (EC) 2016 Note on discharge of scrubber wash water, bans the discharge in ports and inland waters. Relevant Belgian legislation is the law on the protection of  surface water against pollution(Flemish Region, Law of 26 March 1971).


Discharge is not allowed in inland waterways and the Rhine (Art. 1 & 3 of the CDNI Convention (Convention on the collection, deposit and reception of waste produced during navigation on the Rhine and inland waterways).


The port rules and conditions of use approved by the Ministry of Transport forbids discharge in. port waters, hereby referring to Reference is made to the above mentioned EC 2016 Note. Authorities are currently studying the impact of scrubber wash water on the marine environment and will provide conclusions upon its completion.


Discharge is not allowed in territorial and port waters, again referring to the above mentioned EC 2016 Note.  Discussions are ongoing within the EC on improving regulations in order to provide more clarity.

Dublin, Ireland

The Irish authorities’ Notice No. 37 of 2018 ‘Prohibition on the discharge of exhaust gas scrubber wash water’ stipulates wash water discharge is prohibited in waters under Dublin port jurisdiction (including waters from the Matt Talbot Memorial Bridge eastwards to a line from the Baily Lighthouse through the North and South Burford buoys and through Sorrento Point).


The Norwegian Maritime Directorate (NMD) bans the use of all types of scrubbers, including closed loop and hybrid systems, and also proposes prohibiting waste incineration on board in the country’s heritage fjords. Implementation is expected to start in the first half of 2019.


Hawaii, USA

Conditional section 401 Water Quality Certification (WQC), as mentioned in section 6.7 of the 2013 Vessel General Permit (VGP), allows for discharge of wash water subject to certain requirements (mentioned in same section) being fulfilled.

Connecticut, USA

In accordance with section 6.5.9[UK1] of the 2013 VGP, discharge of exhaust gas scrubber wash water into Connecticut waters from any vessel covered under the VGP is prohibited. See CGS section 22a-427 and Connecticut Water Quality Standards (CT WQS).

California, USA

The California Air Resources Board for Ocean-Going Vessels (CARB OGV) regulations permit the use of abatement technologies such as scrubbers, hence their use as well as any discharge of wash water is prohibited. However, pursuant to CARB’s Marine Notice 2017-1 discharge is permitted, if the vessel has an experimental or temporary research permit.


Various other coastal states and ports are discussing enforcing similar bans citing the adverse effects of scrubber wash water on the marine environment. It is therefore likely that the above list of states/ports currently regulating/banning open-loop scrubber discharges in their waters will grow over time

In those areas where the discharge of wash water is not permitted, vessel operators have two options to choose from to ensure compliance with sulphur limits:

  • use compliant fuel instead of open-loop scrubbers; or,
  • switch to closed-loop operation mode, necessating to convert currently installed open-loop systems to closed-loop or hybrid systems, if not already done.

Any change-over should be carried out well in advance of the vessel entering the areas with prohibition or restrictions in place. This will help in identifying operational issues, if any, after  change-over and will allow for sufficient time to rectify such before the vessel enters the area.

We advise members and clients to monitor the situation closely and ensure that crews onboard vessels fitted with open-loop scrubbers are made aware of any relevant local discharge requirements in force. As a precautionary measure, we advise owners of vessels with open-loop scrubbers installed to approach local agents for detailed actual requirements on scrubber wash water discharge as part of a vessel’s voyage planning.  


Source: GARD (http://www.gard.no/web/updates/content/26939066/beware-of-local-restrictions-before-discharging-washwater-from-exhaust-gas-scrubbing) -  Marine Insurance P&I Club News,Shipping: Emission Possible 16/01/2019



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 - washwater 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 Washwater 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 washwater into Connecticut waters from any vessel is prohibited.

VGP 2013: 6.5.9 Discharge of exhaust gas scrubber washwater 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 washwater 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 washwater discharge must not be discharged into port waters. Exhaust gas scrubber washwater 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.



Source: North of England P&I Club – 5/12/2018