Will you need a new engine? New air pollution rules for small commercial vessels and recreational boats

New Zealand has recently adopted Annex VI to the International Maritime Organisation (IMO) International Convention for the Prevention of Pollution from Ships 1973 (MARPOL).  Annex VI is aimed at reducing emissions from ships and includes limits on the use of high sulphur content fuels (to control the emission of harmful sulphur oxides (SOx)) and restrictions on the emission of harmful nitrogen oxides (NOx) by vessels.  The requirements are incorporated in Maritime Rule Part 199.  

In addition to larger ships and those engaged on international voyages, some of the new rules also cover recreational vessels and smaller commercial vessels (under 400GT) undertaking domestic voyages.  

In general terms, the rules apply to vessels with engines powered by liquid or gaseous fuels having an output exceeding 130kw (174.3 hp) which were “installed” on existing vessels after 19 May 2005 (or on or after 1 January 2000 if the vessel voyages outside NZ  jurisdiction), or which have had a major conversion after that date, or are installed on vessels (including existing vessels) that become New Zealand ships on or after 1 January 2023.  The rules apply to both main propulsion engines and auxiliaries.

For voyages within NZ jurisdiction by smaller commercial vessels with engines installed before 1 January 2023 compliance needs to be shown at the vessel’s next intermediate or renewal survey on or after 1 January 2029, and at latest by 2032.  For voyages outside NZ jurisdiction (without calling at overseas ports e.g. deep sea fishing vessels) compliance needs to be shown at the vessel’s next intermediate or renewal survey on or after 1 April 2023.  For vessels with engines installed on or after 1 January 2023 compliance must be shown at the next survey after 1 April 2023.  Recreational vessels must comply by latest 2032.

Petrol, diesel or gaseous fuels, e.g. LPG or CNG will meet the new SOx requirements but if you use a heavier grade fuel, then you will need to check with the supplier.  To comply with NOx requirements engines must operate within specified NOx emission limits and hold the compliance documentation specified in the rules.   If compliance can’t be demonstrated then offending engines will need to be replaced with compliant models.

The new rules don’t apply to vessels operating only on inland waters such as rivers or lakes, to engines of 130kW output or less, engines that don’t run on liquid or gaseous fuels, or to engines which have not been “installed” on a vessel. There is a definition of what “installed” means:  it would include e.g. outboards where fuel is supplied from tanks permanently affixed to a vessel, but not where portable tanks are used. Engines installed prior to 19 May 2005 on existing New Zealand vessels which have not undergone major conversion after that date and where the vessel does not venture outside NZ jurisdiction, are excluded.

If a vessel exceeds 400GT, has incinerators or equipment that uses ozone depleting substances, or voyages outside NZ then additional requirements apply.

For further information contact Karl Stolberger or Barbara Versfelt‍