Operational Guide · Registers & Logbooks

# Change Over Fuel (Fuel Oil Changeover ECA)

The fuel changeover procedure at the entry/exit of Emission Control Areas: timings and records that inspectors always check.

MARPOL Annex VI sulphur cap ECA changeover

## Operational Explanation

On entering an Emission Control Area (ECA) the ship must switch from fuel compliant with the global limit (0.50% sulphur m/m) to fuel with a sulphur content not exceeding 0.10% m/m (or use an equivalent abatement system, e.g. an approved scrubber).

May 2025 update: under Resolution MEPC.361(79) the entire Mediterranean Sea became a SECA (Sulphur Emission Control Area): from 1 May 2025 the changeover to 0.10% S fuel (or use of an equivalent scrubber) is mandatory for anyone transiting the Mediterranean too, not only in the historical ECAs.

2026 update: two new ECAs entered into force (Canadian Arctic and the Norwegian Sea, Resolution MEPC.392(82), from 1 March 2026), adding to North America, the US Caribbean, the Baltic, the North Sea and the Mediterranean. For the full regulatory picture, see the MARPOL Annex VI topic.

## Regulatory Reference

MARPOL Annex VI, Regulation 14 (sulphur limits) and Regulation 4 (equivalent methods, e.g. scrubbers). Global sulphur cap 0.50% m/m since 2020; ECA limit 0.10% m/m.

## Scope of Application

All ships transiting to/from an ECA, except those fitted with an approved equivalent abatement system (scrubber) or running on compliant alternative fuels (LNG, methanol).

## Procedure / How to Complete It

1. Plan the changeover with sufficient lead time before the ECA boundary, allowing for the fuel's residence time in the lines and systems.
2. Record in the engine log: date, time, position, fuel quantity in each tank at the start and end of the changeover.
3. Verify the changeover is completed before entering the ECA (not at the point of entry itself).
4. On exiting the ECA, similarly record the changeover back to standard-sulphur fuel.
5. For ships fitted with a scrubber, verify and record the system's correct operation as an alternative to changeover.

## Practical Example

Example entry: "Changeover started 03.08.2026 at 04:00, position 50°45'N 001°30'W, completed at 06:30, 46 miles from the North Sea ECA boundary. 0.10% S fuel confirmed by bunker analysis certificate."

## Real Cases

Several Annex VI deficiencies arise from a changeover completed too late relative to the ECA boundary, due to underestimating the fuel's residence time in the lines — a planning error more than an intentional one.

## Common Mistakes Mistake Library

Mistake | Consequence | How to avoid it
--- | --- | ---
Changeover started too late | Ship inside the ECA still running non-compliant fuel | Calculate line residence time and bring the operation forward
Incomplete record (position/quantity missing) | Annex VI PSC deficiency | Use a standard changeover form with all required fields
Bunker Delivery Note inconsistent with the fuel declared compliant | Dispute over fuel quality | Always keep the Bunker Delivery Note and the MARPOL sample
Procedures not updated after the Mediterranean SECA (1 May 2025) | Use of non-compliant fuel in an area now regulated | Update onboard procedures and bunker planning to include the Mediterranean among the SECAs
Using the FONAR as a permanent authorisation | The FONAR documents diligence but does not authorise continuing use of non-compliant fuel | Treat the FONAR as a documented, exceptional measure, not a recurring solution

## PSC Observations

Annex VI inspectors check the changeover log, the Bunker Delivery Note and, where fitted, the operation of the scrubber as an equivalent method; the MARPOL fuel sample must be available on board for at least 12-18 months per Flag guidance.

## Operational Tips

- Always calculate the fuel's residence time in the lines before planning the changeover.
- Use a dedicated form (not just the generic engine log) to track the operation.
- Keep track of the calendar of new ECAs (Mediterranean from 2025; Canadian Arctic and Norwegian Sea from 2026).
- If compliant fuel is not available in port, prepare a documented FONAR (Fuel Oil Non-Availability Report) to submit to the Administrations concerned.

## Checklist

- Changeover planned with adequate lead time
- Complete record (date, time, position, quantity)
- Bunker Delivery Note and fuel sample retained
- Scrubber, if fitted, verified and recorded as an alternative

## FAQ

What is the sulphur limit outside ECAs?
0.50% m/m, in force globally since 1 January 2020.
Which ECAs are active in 2026?
North America, the US Caribbean, the Baltic, the North Sea, the Mediterranean (from 1 May 2025), plus the new Canadian Arctic and Norwegian Sea ECAs, in force from 1 March 2026.
Since when has the Mediterranean SECA been mandatory?
Since 1 May 2025 (Resolution MEPC.361(79)): maximum sulphur content 0.10% m/m, unless an equivalent scrubber (EGCS) is used.
What is a FONAR and when is it used?
The Fuel Oil Non-Availability Report is the report a ship submits when compliant fuel is not available in port; it documents the operator's diligence but does not automatically authorise the use of non-compliant fuel.
🎬 Additional photos, videos and interactive diagrams for this topic will be available in a future version of the platform.

## Related Topics

MARPOL Annex VI (full reference)Oil Record Book Regulatory Updates (IT)

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