MARPOL ANNEX IV: Argentine Maritime Authority Prohibits Discharge of Washwater from open loop Scrubbers into National Waters

Marpol Annex VI, first adopted in 1997, requires ships to reduce SOx emissions, either by burning low sulphur fuel or by cleaning the exhaust gas. For that purpose, Exhaust Gas Cleaning Systems (EGCS), also known as “scrubbers”, have been fitted onboard many ships as an acceptable equivalent method for complying with these requirements.

Reality indicates that many ships have —or are intending to have— scrubbers fitted. Therefore, we wrote this brief report on the latest developments on this matter in Argentina.

Even though this country has not ratified Marpol Annex VI so far, and there are no restrictions or regulations in force regarding its implementation, the Argentine Maritime Authority issued the Resolution 15/2020 DISFC-2020-15-APN-DPAM-PNA which prohibits the discharge of washwater from open loop scrubbers into national waters, i.e. inland waters, territorial sea, adjacent area, and the Argentine economic zone.

Said resolution has become enforceable since the August 10th, 2020, when it was published on the Official Gazette (10/08/2020 N° 31188/20 v. 10/08/2020). Accordingly, from that moment onwards, shipowners are obliged to keep such washwater onboard, or otherwise discharge it into reception facilities.

Being this last the case, it is worth mentioning that Argentine ports have no reception facilities available; therefore, if washwater cannot be held onboard, it shall be discharged into barges fitted for that purpose, which would inevitably increase operational costs.

There are still uncertainties about the procedures that will be implemented in order to enforce the abovementioned restrictions, particularly, for those ships in transit through their exclusive economic zones which do not call at Argentine ports.

We are following with interest the progress of this matter and the position which shall be adopted by the Argentine Maritime Administration, so whether you deem it necessary, we would be pleased to regularly update you and/or your Company on the latest developments on this regard.

Our team could also provide advice on operational and compliance aspects concerning ports, waterways, available reception facilities, and other local regulatory framework which may impact on your fleet operations.


We remain at your disposal.