New North-East Atlantic ECA: SOx, PM and NOx (MEPC 84)

North-East Atlantic ECA: boundaries and ship/engine criteria; applicable Tier III from 1 September 2027, SOx/PM from 1 September 2028.

Operational Explanation

MEPC 84 (27 April - 1 May 2026) adopted amendments to MARPOL Annex VI designating the North-East Atlantic as a new Emission Control Area (ECA) for sulphur oxides (SOx), particulate matter (PM) and nitrogen oxides (NOx), joining the ECAs already in place.

The Regulation 14 areas today number seven, and will become eight: Baltic, North Sea, North America, United States Caribbean Sea, Mediterranean, Canadian Arctic and Norwegian Sea — the last two designated by Res. MEPC.392(82) and in force since 1 March 2026, with the fuel limits from 1 March 2027. And the Mediterranean is not “for SOx”: like every Regulation 14 area it is an ECA for sulphur and for particulate matter. What the Mediterranean is not, and what the North-East Atlantic will be, is a NOx Tier III emission control area under Regulation 13.

For the North-East Atlantic: designation and applicable Tier III requirements from 1 September 2027; SOx/PM, with sulphur not exceeding 0.10% m/m or an approved equivalent, from 1 September 2028. The construction definition covers: a contract from 1 January 2027; or, only without a contract, keel laying/equivalent stage from 1 July 2027; or delivery from 1 January 2031, irrespective of whether a contract exists.

Also check regulation 13.2: original engines, identical replacements, non-identical replacements, additional engines and other major conversions follow different branches. An earlier ship construction date does not automatically exempt a replacement or additional engine. Check power, use, EIAPP, Technical File, applicable Tier and any regulation 13.5.2 exclusion with the Administration or its authorized recognized organization.

Where it starts and where it ends

Appendix VII, paragraph 6, of MEPC.407(84) covers the EEZs and territorial seas of Greenland, Iceland, the Faroes, Ireland and the mainland parts of the United Kingdom, France, Spain and Portugal. It excludes the North Sea already defined in Annex VI; this is not a definition of all North Atlantic waters.

Two things in that sentence deserve close reading. The first is the word mainland: that is where the exclusions live. The Azores, Madeira and the Canaries stay out — but they are not named in the text of Appendix VII. Anyone searching MARPOL for “Azores” will not find it: the exclusion works because only the mainland parts of Portugal and Spain are taken. The second is the explicit exclusion of the North Sea: the new area does not absorb it, it sits beside it, and that avoids two regimes overlapping.

The junctions with the neighbouring areas are defined by coordinates. To the north-east the boundary follows the north-western outer limits of the North Sea from 62°00'.00 N, 01°22'.25 E, excluding the area south of latitude 62°00'.00 N and east of longitude 04°00'.00 W. Running south, it follows the south-western outer limits of the North Sea “excluding the English Channel and its approaches eastward of longitude 05°00'.00 W and northward of latitude 48°30'.00 N”, down to the southernmost coordinate of that stretch, 48°30'.00 N, 05°00'.00 W. From there the area runs south to the intersection of the line joining Cape Trafalgar (36°11'.00 N, 06°02'.00 W) and Cape Spartel (35°48'.00 N, 05°55'.00 W) — the western boundary of the Mediterranean — with the eastern outer limit of Spain's mainland exclusive economic zone, at 35°57'.59 N, 05°58'.27 W.

From which a practical consequence worth stating: Morocco is not included. Cape Spartel appears as a geographic point for drawing a line, not as a jurisdiction brought inside. A route leaving Gibraltar along the African shore does not automatically enter the new ECA.

Appendix VII, paragraphs 6–7, contains 157 numbered points in WGS 1984 and links to Canadian Arctic segments referenced in the sequences 174–51 and 50–23. It is not a stand-alone 175-point polygon to be closed automatically. Use official charts and updates for passage planning, including the referenced segments.

Boundary source: MEPC.407(84), appendix VII, paragraphs 6–7. The adopted text takes precedence over coordinates in earlier proposals.

The twelve months are not a concession: they are Regulation 14.7

Regulation 14.7 suspends the requirements of paragraphs 14.4 and 14.6, and those in 14.5 relating to 14.4, for the first twelve months after designation. It does not suspend regulation 13 on NOx. Thus the SOx/PM requirements start in 2028, while applicable Tier III requirements start in 2027.

And it also explains why NOx Tier III applies immediately, from entry into force. Regulation 14.7 suspends paragraphs 4, 6 and — insofar as they relate to paragraph 4 — paragraph 5 as well: the sulphur limit, the changeover procedure and the records attached to it. All three are paragraphs of Regulation 14. Regulation 13 is not among the suspended paragraphs, and that is why NOx Tier III is untouched.

The exemptions: all from NOx Tier III, none from sulphur

Regulation 13.5.2 excludes three categories from Tier III alone: recreational craft of less than 24 metres in length specifically designed and used solely for recreation; ships with a combined nameplate propulsion power of less than 750 kW that demonstrate to the Administration that they cannot comply because of design or construction limitations — being under the threshold is not by itself enough; and recreational craft constructed before 1 January 2021, of less than 500 gross tonnage and 24 metres in length or over.

The temporary shipyard exemption in regulations 13.5.4–13.5.5 requires Tier II compliance, direct routing, no loading/unloading throughout the entire exemption and compliance with port State routing requirements. Its duration is limited: for a new ship, delivery including trials until direct ECA exit or, for dual-fuel, the nearest suitable gas bunkering facility in the area; for conversion/maintenance/repair of a ship with a Tier II engine, direct entry to the yard until direct exit following release and trials; for dual-fuel ships required to be gas-free for safety, entry or degassing within the ECA until direct exit or the nearest suitable gas bunkering facility. This is not a blanket exemption for the whole stay or from sulphur requirements.

Reference: MEPC.328(76), regulations 13.5.4–13.5.5.

The NOx exclusions described above do not waive sulphur requirements. Within Annex VI’s scope, verify fuel compliant with regulation 14 or an equivalent method approved under regulation 4. Regulation 3 exceptions and exemptions remain subject to their own conditions: they include safety, life-saving, damage and specific research trials authorized by the Administration under 3.2. They are not automatic ship-category exemptions.

Presenting these four cases as exemptions from the new ECA, without saying what they exempt from, would let a 20-metre pleasure craft believe it may burn high-sulphur fuel. It may not: all four concern NOx Tier III alone.

Regulatory Reference

Adopted text checked: MEPC.407(84), ClassNK T1378 attachment 1. On 15 September 2026 the direct IMO PDF still contains an awaiting-certification notice. This reproduction allows verification of dates, construction criteria and boundaries without bringing entry into force forward.

Scope of Application

Every ship operating within the official boundary must assess SOx/PM separately from NOx. Also check regulation 13.2: original engines, identical replacements, non-identical replacements, additional engines and other major conversions follow different branches. An earlier ship construction date does not automatically exempt a replacement or additional engine. Check power, use, EIAPP, Technical File, applicable Tier and any regulation 13.5.2 exclusion with the Administration or its authorized recognized organization.

Procedure / How to Complete It

1. Identify the ECA and entry/exit points on the actual route using updated official charts.
2. For the North-East Atlantic: designation and applicable Tier III requirements from 1 September 2027; SOx/PM, with sulphur not exceeding 0.10% m/m or an approved equivalent, from 1 September 2028. The construction definition covers: a contract from 1 January 2027; or, only without a contract, keel laying/equivalent stage from 1 July 2027; or delivery from 1 January 2031, irrespective of whether a contract exists.
3. Also check regulation 13.2: original engines, identical replacements, non-identical replacements, additional engines and other major conversions follow different branches. An earlier ship construction date does not automatically exempt a replacement or additional engine. Check power, use, EIAPP, Technical File, applicable Tier and any regulation 13.5.2 exclusion with the Administration or its authorized recognized organization.
4. Confirm compliant fuel availability or an approved, operational equivalent method. Check other applicable restrictions separately.
5. Where regulation 13.5.3 applies, record engine Tier and on/off status on entry into and exit from the NOx ECA and status changes within it, with date, time and position. Regulation 14.6 instead concerns ships using separate fuels: a written procedure, changeover completed before entry and started after exit, with low-sulphur fuel volumes in each tank, date, time and position. No changeover is required when continuing to use fuel that already complies.
6. The temporary shipyard exemption in regulations 13.5.4–13.5.5 requires Tier II compliance, direct routing, no loading/unloading throughout the entire exemption and compliance with port State routing requirements. Its duration is limited: for a new ship, delivery including trials until direct ECA exit or, for dual-fuel, the nearest suitable gas bunkering facility in the area; for conversion/maintenance/repair of a ship with a Tier II engine, direct entry to the yard until direct exit following release and trials; for dual-fuel ships required to be gas-free for safety, entry or degassing within the ECA until direct exit or the nearest suitable gas bunkering facility. This is not a blanket exemption for the whole stay or from sulphur requirements.

Practical Example

Example after 1 September 2028: a Lisbon–Funchal ship starts inside the ECA and must comply with 0.10% m/m or an equivalent until crossing the official boundary. Only after exit does the global 0.50% limit resume, subject to local rules; it may still continue on 0.10% fuel. Madeira is excluded, but not the entire route. Lisbon–Rotterdam requires no transition between ECA sulphur limits only if the actual route stays within adjoining areas; assess the NOx calendar separately.

What Typically Goes Wrong

Common Mistakes Mistake Library

• SOx correctly deferred, NOx overlooked: the twelve-month suspension does not cover Tier III.
• Delivery overlooked: the 2031 criterion applies even with an earlier contract.
• Excluded island = excluded voyage: check the initial ECA leg.
• Shipyard exemption overstated: check activity, duration, routing and absence of loading/unloading; sulphur remains separate.

What the PSCO Checks

Operational Tips

• Prepare a ship–engine–area–date matrix, not one fleet-wide deadline.
• Check the actual boundary and compliance-method documentation before the voyage.
• Do not equate the fuel sulphur limit with engine NOx conditions.

Preparation checklist

Educational checklist. This summary supports learning and preparation only. It does not replace the vessel’s approved procedures, manuals, statutory documents, company SMS, or applicable official requirements. Completing it demonstrates neither compliance nor readiness for an inspection: it shows that a list has been read, not that the ship is in order. Always verify the current documents carried on board.

• Identify the ECA and entry/exit points on the actual route using updated official charts.
• For the North-East Atlantic: designation and applicable Tier III requirements from 1 September 2027; SOx/PM, with sulphur not exceeding 0.10% m/m or an approved equivalent, from 1 September 2028. The construction definition covers: a contract from 1 January 2027; or, only without a contract, keel laying/equivalent stage from 1 July 2027; or delivery from 1 January 2031, irrespective of whether a contract exists.
• Also check regulation 13.2: original engines, identical replacements, non-identical replacements, additional engines and other major conversions follow different branches. An earlier ship construction date does not automatically exempt a replacement or additional engine. Check power, use, EIAPP, Technical File, applicable Tier and any regulation 13.5.2 exclusion with the Administration or its authorized recognized organization.
• Confirm compliant fuel availability or an approved, operational equivalent method. Check other applicable restrictions separately.
• Where regulation 13.5.3 applies, record engine Tier and on/off status on entry into and exit from the NOx ECA and status changes within it, with date, time and position. Regulation 14.6 instead concerns ships using separate fuels: a written procedure, changeover completed before entry and started after exit, with low-sulphur fuel volumes in each tank, date, time and position. No changeover is required when continuing to use fuel that already complies.
• The temporary shipyard exemption in regulations 13.5.4–13.5.5 requires Tier II compliance, direct routing, no loading/unloading throughout the entire exemption and compliance with port State routing requirements. Its duration is limited: for a new ship, delivery including trials until direct ECA exit or, for dual-fuel, the nearest suitable gas bunkering facility in the area; for conversion/maintenance/repair of a ship with a Tier II engine, direct entry to the yard until direct exit following release and trials; for dual-fuel ships required to be gas-free for safety, entry or degassing within the ECA until direct exit or the nearest suitable gas bunkering facility. This is not a blanket exemption for the whole stay or from sulphur requirements.

FAQ

Related Topics

Last substantive revision of this page: 15 September 2026 · page fingerprint 38eb32e76826