NOx Tier III rule to be implemented by 2021

The International Maritime Organisation (IMO), at its Marine Environment Protection Committee meeting held from 13-17 May rejected a proposal submitted by Turkey and ICOMIA that sought to mitigate the impact caused by the Tier III regulation.
NOx is a pollutant released by combustion engines. The International Maritime Organisation (IMO) has several NOx emissions regulations. Emission limits are commonly referred to as Tier I, II and III. Tier III refers to the NOx emissions. Vessels above 500gt constructed on or after 1 January 2016 must already comply with the emission limits, and from 2021 vessels below 500gt but above 24 meters will also be covered. The proposal that Turkey and ICOMIA submitted aimed to offer an alternative emission standard for vessels currently covered under a delay provision (above 24m and below 500gt). This delay provision expires in 2021 after which all recreational vessels above 24m, if operating in designated Emission Control Areas, must comply with a 2g/kWh standard. It is understood this standard can only be met by use of exhaust gas aftertreatment systems, currently available designs require a minimum of 30% additional space of the engine installation envelope.
The consequence of this – loss of internal guest cabin space – could render yachts just above the 24m threshold commercially unattractive. ICOMIA considers the >24m – 40m market segment crucial for the marine industry, considering the ability for boaters to progress in boat size and the relevant turnover for builders, equipment and tender/toy manufacturers, and ancillary service providers. This is why ICOMIA has dedicated a significant amount of time to advocating the feasible application of the rule.
In 2013, together with key IMO Member States, the International Council of Marine Industry Associations (ICOMIA) managed to negotiate a delay, moving the application date of the IMO Tier III NOx emission limits from 2016 to 2021. The years since saw a group of key yacht builders and engine manufacturers convened by ICOMIA actively searching for ways to minimise the impact of the rule – the outcome confirming our predictions over the disproportionateness of applying the rule on yachts concerned. Subsequently, ICOMIA commissioned independent research to confirm the industry’s concerns and formulate the case of the large yacht industry which was presented at IMO. This triggered an invitation to submit a proposal for a second amendment of the MARPOL Convention to address the case of yachts above 24m and below 500gt, which were originally covered by the delay provision.
This proposal, co-sponsored by the Turkish IMO Delegation and ICOMIA, was discussed this week by the Marine Environment Protection Committee of IMO. The proposal to delay the application of the rule and relaxing the standards so these can be met without the use of catalysts, would have lessened the negative impact of the implementation of Tier III on the marine industry.
Unfortunately, despite ICOMIA’s significant efforts in producing the proposal and support from eleven delegations, the proposal was rejected, meaning that the regulation will be implemented from 2021 for vessels below 500gt, with significant implications for the superyacht industry. No further opportunities exist to object to the rule, so it is important that all vessels designed to operate globally comply with the requirements from 2021 onwards.
Udo Kleinitz, Secretary General of ICOMIA said:
“ICOMIA fought hard to advocate for the industry. Having been involved with this file for the last 11 years, at this stage it is difficult to capture the impact this decision will have on vessel design, let alone our industry. We are most grateful to those IMO Member States who supported our proposal, and would like to mention in particular Turkey for co-sponsoring this document and the associated lobbying efforts, as well as Malta for their efforts on the European stage. I also would like to thank the yards who supported our advocacy effort, namely Ferretti Group, Overmarine, Monte Carlo Yachts, Princess Yachts, Sanlorenzo Yachts, Sunseeker and Viking Yachts. This proposal deserved to succeed on technical grounds, but unfortunately, we lacked the political support from IMO Member States who decided against continuing a case they accepted 6 years ago.”