Mediterranean SECA: the 0.10% Sulphur ECA Since May 2025

The Mediterranean Sea Emission Control Area under MARPOL Annex VI: MEPC.361(79), the 0.10% sulphur limit since 1 May 2025, its boundaries and compliance routes.

The Mediterranean Sea Emission Control Area is the sulphur oxides and particulate matter emission control area that MARPOL Annex VI regulation 14.3.5 creates over the whole Mediterranean basin, where fuel oil used on board has been limited to 0.10% m/m sulphur since 1 May 2025. IMO Resolution MEPC.361(79), adopted on 16 December 2022, inserted it; the amendment entered into force on 1 May 2024, and regulation 14.7 deferred the fuel requirement by twelve months. It is the fifth sulphur emission control area , the first created after the global 0.50% limit took effect in 2020, and it covers sulphur and particulates only, not nitrogen oxides.

The area runs from a line across the western entrance of the Strait of Gibraltar to a line across the Dardanelles and to the northern entrance of the Suez Canal. Inside those lines every ship flying the flag of a Party to MARPOL Annex VI , of any size, burns 0.10% fuel or uses an approved equivalent.

What the Mediterranean ECA requires

A ship operating inside the Mediterranean ECA must use fuel oil with a sulphur content not exceeding 0.10% m/m, under regulation 14.4 . The limit applies to fuel used in main engines, auxiliary engines and boilers alike. It has no size threshold and no keel-laying date, which separates it from the NOx regime under regulation 13.

Outside the ECA the global limit of regulation 14.1 applies: 0.50% m/m for fuel used or carried for use, with the carriage ban added by MEPC.305(73) from 1 March 2020. A ship can therefore carry very low sulphur fuel oil through the Mediterranean as long as it does not burn it there. The operational question is when to change over, which regulation 14.6 governs.

Compliance routes

Three routes meet the requirement. The ship can burn a distillate such as marine gas oil or a 0.10% blend often sold as ultra-low sulphur fuel oil . It can burn a fuel that carries almost no sulphur, such as LNG or methanol . Or it can keep burning higher-sulphur fuel through an exhaust gas cleaning system that the flag Administration has approved as an equivalent under regulation 4.

The equivalence test is an emission ratio. MEPC.340(77), the 2021 Guidelines for Exhaust Gas Cleaning Systems, sets 4.3 SO2 (ppm) to CO2 (% v/v) as equivalent to 0.10% sulphur fuel, against 21.7 for the 0.50% limit. Table 1 of the guidelines limits that ratio to petroleum-derived distillate or residual fuel.

Which ships and which fuels the limit binds

Regulation 14.4 binds ships of Parties to Annex VI while they operate in the area, with no exception for size, ship type or age. A small coaster, a ferry and a cruise ship face the same 0.10% limit on every passage inside the area. The only route around the fuel limit is an equivalent approved by the flag Administration under regulation 4.

An LNG-fuelled ship meets the limit on gas, which carries almost no sulphur; any liquid fuel it burns inside the area is held to 0.10% like any other. A ship running its auxiliary engines on 0.10% fuel and its main engine through a scrubber complies, provided the scrubber’s approval covers the main engine and its ratio holds at 4.3.

Directive (EU) 2016/802 adds one further cap in EU waters: Article 5 sets a 3.50% sulphur ceiling, with an exception for ships using an emission abatement method in closed mode. The global 0.50% limit already binds at sea, so the practical interest of Article 5 lies in that closed-mode exception.

Application dates

Four dates attach to the Mediterranean ECA, and each answers a different question.

StepDateSource
Adopted by MEPC 7916 December 2022MEPC.361(79)
Deemed accepted1 November 2023MEPC.361(79) operative paragraph 2, MARPOL Article 16(2)(f)(iii)
Entered into force1 May 2024MEPC.361(79) operative paragraph 3, MARPOL Article 16(2)(g)(ii)
0.10% limit applies1 May 2025Regulation 14.7, MEPC.361(79) operative paragraph 4

The gap between entry into force and application comes from regulation 14.7, not from a choice made for the Mediterranean. Regulation 14.7 exempts ships in a newly designated ECA from regulations 14.4 and 14.6 for twelve months after the designation enters into force. Operative paragraph 4 of MEPC.361(79) applies that exemption “until 1 May 2025”. The tacit acceptance procedure of MARPOL Article 16 explains the earlier steps: amendments adopted by the committee are deemed accepted unless one third of Parties, or Parties with 50% of world gross tonnage, object.

Boundaries of the Mediterranean ECA

The boundary text sits in new paragraph 4 of Appendix VII to MARPOL Annex VI, which MEPC.361(79) inserted. Appendix VII describes the area as “all waters bounded by the coasts of Europe, Africa and Asia” and fixes three limiting lines. The whole basin is inside, high seas included; the area is not confined to territorial seas or exclusive economic zones.

LimitDefinition in Appendix VII paragraph 4Coordinates
WestWestern entrance to the Straits of Gibraltar, a line joining Cape Trafalgar, Spain and Cape Spartel, Morocco36°11’N, 6°02’W to 35°48’N, 5°55’W
North-eastStrait of Canakkale, a line joining Mehmetcik Burnu and Kumkale Burnu40°03’N, 26°11’E to 40°01’N, 26°12’E
South-eastNorthern entrance to the Suez Canal, excluding a polygon around Port SaidP1 31°29’N 32°16’E; P2 31°29’N 32°28.48’E; P3 31°14’N 32°32.62’E; P4 31°14’N 32°16’E

The Strait of Gibraltar

The western line crosses the Atlantic mouth of the Strait of Gibraltar , not its Mediterranean end. The whole strait is therefore inside the ECA, and so are Gibraltar, Algeciras, Ceuta and Tanger Med, the bunkering and transhipment ports on either side of it. A ship calling at any of them is inside the ECA from the moment it crosses the Trafalgar to Spartel line.

That placement matters for bunker planning. A westbound ship leaving Algeciras on 0.10% fuel reaches the ECA boundary within hours, so its changeover to 0.50% fuel starts after it clears the line off Cape Trafalgar and Cape Spartel, not at the port.

The Dardanelles, Marmara and the Black Sea

The north-eastern line crosses the Aegean mouth of the Dardanelles. The Dardanelles transit, the Sea of Marmara, the Bosphorus and the Black Sea all lie outside the ECA, and the Turkish Straits are not part of it. A ship bound for a Black Sea port can change back to 0.50% fuel once it has passed the Mehmetcik Burnu to Kumkale Burnu line.

The Black Sea carries its own regional instrument, the Bucharest Convention , but no emission control area.

Port Said and the Suez Canal

The south-eastern limit is the northern entrance to the Suez Canal , and the text excludes a four-point polygon of about 15 minutes of latitude by 16 minutes of longitude over Port Said and its approaches. The canal is outside the ECA, and so is a ship waiting inside that polygon. A northbound ship enters the ECA when it leaves the excluded polygon, which is where the changeover to 0.10% fuel must be complete.

Changeover, logbook and planning

Regulation 14.6 governs the changeover for any ship that uses separate fuels to comply. The ship carries a written procedure showing how the changeover is to be done, with enough time for the fuel oil service system to be fully flushed of fuel above 0.10% before it enters the ECA. The record shows the volume of low-sulphur fuel in each tank, and the date, time and position of the ship when changeover is completed before entry or started after exit.

That record goes in the logbook or electronic record book prescribed by the flag Administration. It is not an Oil Record Book entry, which belongs to MARPOL Annex I. The operational practice of flushing, temperature control and compatibility testing is covered in fuel switching operations .

The main planning variables are the ship’s flushing time and the distance to the nearest boundary line. A ship trading between the Suez approaches and Gibraltar spends the whole passage inside the ECA; one trading between the Aegean and the Black Sea crosses the Canakkale line once each way.

Grades and fuel quality

A 0.10% distillate and a residual 0.50% blend differ in viscosity and stability. Mixing them in the service system during changeover is where incompatibility shows, which is why the procedure specifies temperatures and rates. ISO 8217:2024 sets the specifications for both, and the practical checks are in bunker quality and ISO 8217 .

Cylinder lubrication follows the fuel. A two-stroke engine switching to 0.10% fuel for a long ECA passage needs a lower base number oil, which is covered in cylinder oil base number and fuel sulphur .

Passage planning through the boundary lines

Where a ship crosses an ECA boundary decides where its changeover must be finished, and the three lines produce different patterns for the main Mediterranean routes.

RouteBoundary crossingsWhere changeover to 0.10% must be complete
Suez northbound to Gibraltar westboundEnters leaving the Port Said polygon, leaves at the Trafalgar to Spartel lineBefore leaving the Port Said polygon
Atlantic eastbound to a Black Sea portEnters at the Trafalgar to Spartel line, leaves at the Canakkale lineBefore crossing the Trafalgar to Spartel line
Black Sea to Suez southboundEnters at the Canakkale line, leaves entering the Port Said polygonBefore crossing the Canakkale line
Intra-Mediterranean ferry or feederNone; the whole trade is insidePermanently on 0.10% fuel or an approved equivalent

Table constructed by Shipping-Wiki.com from the Appendix VII paragraph 4 boundary definitions, 25 September 2026.

The changeover itself takes time the ship has to plan. As a hypothetical example, a ship whose fuel oil service system holds 30 tonnes between the settling tank and the engine, and whose engine burns 1.5 tonnes an hour, needs at least 20 hours of running on the new fuel just to pass one system volume through, and longer in practice, because mixing in the service and settling tanks slows the fall in sulphur content: with full mixing, one system volume still leaves the fuel at about 0.25% sulphur. The 20 hours is therefore a lower bound. The ship’s own changeover procedure, based on its tank arrangement and sampling, sets the start point, and the completion position is recorded under regulation 14.6.

Bunkering follows from the same geometry. A ship bunkering at Gibraltar, Algeciras, Ceuta or Tanger Med is already inside the ECA, so fuel for the ECA passage and fuel for the onward Atlantic passage are both loaded inside it. A tanker leaving the Black Sea can bunker 0.50% fuel at a Black Sea port but has to hold enough 0.10% fuel for the whole Mediterranean transit from the Canakkale line to its exit.

Scrubbers in the Mediterranean ECA

An approved exhaust gas cleaning system lets a ship keep burning high sulphur fuel oil inside the ECA, provided its emission ratio stays at or below 4.3. The Administration approves the system under regulation 4. For systems on ships keel-laid, or systems delivered, on or after 1 June 2022, Administrations are invited to base that approval on MEPC.340(77); earlier installations were approved under the 2015 guidelines, MEPC.259(68).

Which guidelines apply

MEPC.340(77) was adopted on 26 November 2021 and superseded the 2015 EGCS Guidelines, MEPC.259(68). It applies to systems on ships whose keel was laid on or after 1 June 2022, and to systems contractually delivered, or where there is no contract date actually delivered, on or after that date. Paragraph 1.4 calls the guidelines recommendatory but invites Administrations to base regulation 4 approvals on them. Paragraph 2.1.2 offers two schemes: Scheme A, unit certification with parameter monitoring, and Scheme B, continuous emission monitoring.

When the system fails

A failure inside the ECA has a one-hour window. MEPC.1/Circ.883, issued on 21 May 2019, says at paragraph 6 that a malfunction which cannot be rectified is an accidental breakdown, and that “the ship should then change over to compliant fuel oil if the EGCS cannot be put back into a compliant condition within one hour”. A ship without enough compliant fuel on board communicates a proposed course of action to its Administration and the relevant authorities. The circular sets no longer running period on a failed system. Paragraph 12 adds that a malfunction lasting more than one hour, or repeated malfunctions, is reported to the flag and port State.

The practical consequence is that a scrubber ship trading in the Mediterranean still carries some 0.10% fuel, sized to reach a port or leave the ECA after a failure.

A ship using an exhaust gas cleaning system keeps the records its approval requires, and an inspector entering the ECA compares the logged emission ratio with the 4.3 limit; the record-keeping side is covered in the EGCS record book .

Washwater: national and port restrictions

The ECA does not regulate washwater. Restrictions on open-loop discharge in the Mediterranean are national or port measures, collected in open-loop scrubber discharge restrictions and the scrubber discharge water criteria . Two of them:

  • France. Since 1 January 2022 France has prohibited the use of open-loop scrubbers in the 3-nautical-mile coastal band, for French and foreign ships, by ministerial order under division 213, article 213-6.04, according to the Mediterranean interregional sea directorate (DIRM Mediterranee).
  • Balearic Islands. The Balearic Islands Port Authority ordinance on port water quality, published by resolution of 17 February 2025 (BOE-A-2025-5158), prohibits the use of open-loop systems in the port waters it administers.

A ship with an open-loop system therefore switches to closed-loop mode or to compliant fuel before entering those zones, even though the ECA itself would accept the open-loop system as an equivalent.

When compliant fuel is not available

Regulation 18.2 is the relief mechanism, and it is narrow. A ship that cannot buy 0.10% fuel despite its best efforts presents evidence of those efforts, and regulation 18.2.4 requires it to notify its Administration and the competent authority of the port of destination. The notification is normally a fuel oil non-availability report in the format of appendix 1 to MEPC.320(74), covered in FONAR and BDN documentation .

A FONAR is not an exemption. MEPC.320(74) says so, and the appendix to MEPC.321(74) states that “the cost of compliant fuel is not considered to be a valid basis for claiming non-availability”. Regulation 18.2.2 also says a ship should not be required to deviate from its intended voyage or delay it unduly to find compliant fuel. In the EU, Article 6(8) of Directive (EU) 2016/802 mirrors the regulation 18.2 procedure.

Every delivery carries a bunker delivery note , kept on board for three years under regulation 18.6. The MARPOL delivered sample is retained until the fuel is substantially consumed and for not less than 12 months under regulation 18.8.1. The fuller rules are in MARPOL Annex VI regulation 18 .

Enforcement and sampling

Port State control is the enforcement tool, applied by each Mediterranean port State under its regional memorandum of understanding; EU Mediterranean ports inspect under the Paris MoU . A port State control officer checks the changeover record, bunker delivery notes, the FONAR where there is one, and scrubber records, and can take fuel samples.

Sample results are judged against a test margin. Appendix VI of MARPOL Annex VI, as replaced by MEPC.324(75) and in force from 1 April 2022, gives a test margin value W of 0.11% m/m for in-use and onboard samples tested against the 0.10% limit. The test method is ISO 8754:2003. The procedure is set out in MARPOL Annex VI Appendix VI .

The MARPOL delivered sample drawn at the bunker manifold follows MSC-MEPC.2/Circ.18 of 11 July 2024, which revoked MEPC.182(59): a sample of not less than 600 ml, with the container filled to 90% plus or minus 5%. Article 13(2) of Directive (EU) 2016/802 still refers to MEPC.182(59), so EU sampling practice cites a revoked text.

The EU overlay in Mediterranean waters

EU law applied the 0.10% limit in EU Mediterranean waters on the same date as MARPOL, without any amending act. Directive (EU) 2016/802, covered in the EU sulphur directive article, defines SOx emission control areas at Article 2(h) as “sea areas defined as such by the International Maritime Organisation (IMO) under Annex VI to MARPOL”. Article 6(2) applies 0.10% in Member State territorial seas, exclusive economic zones and pollution control zones within those areas. Article 6(3) sets the date for a new ECA at “12 months after the date of entry into force of the designation”, which for the Mediterranean is 1 May 2025.

Three further provisions of the Directive bear on Mediterranean traffic:

  1. At berth. Article 7 applies 0.10% to ships at berth in every EU port, inside or outside an ECA. The exceptions are ships due at berth for less than two hours according to published timetables, and ships that switch off all engines and use shore-side electricity. The cold ironing and shore power guide covers the second route.
  2. Enforcement. Article 6(4) requires Member States bordering SOx ECAs to check compliance by ships of all flags in their ports.
  3. Abatement. Article 8 allows emission abatement methods in EU ports, territorial seas, exclusive economic zones and pollution control zones where they continuously achieve reductions at least equivalent to the fuel limit.

The at-berth rule predates the ECA and kept a 0.10% requirement in EU Mediterranean ports throughout the years when only the 0.50% global limit applied at sea.

EU ETS and FuelEU on Mediterranean voyages

Sulphur compliance does not settle the EU carbon regimes, which apply on their own tests. Under Article 3ga of Directive 2003/87/EC, as amended by Directive (EU) 2023/959, the EU ETS covers 100% of emissions on voyages between two EU or EEA ports and at berth, and 50% on voyages into or out of the EEA, for ships of 5,000 GT and above. The surrender share was 40% of verified emissions for 2024, 70% for 2025 and 100% from 2026, with methane and nitrous oxide covered from 2026. The phase-in and scope article gives the detail.

A worked example shows the effect on a Mediterranean ferry crossing between an EU and a non-EU port. The inputs are hypothetical except the emission factor and the EU rules. Assume a ship of more than 5,000 GT burns 100 tonnes of marine gas oil on the crossing in 2025.

$$\text{CO}_2 = 100 \times 3.206 = 320.6\ \text{t}$$$$\text{allowances} = 320.6 \times 0.5 \times 0.7 = 112.2$$

The 0.5 is the extra-EEA scope and the 0.7 the 2025 phase-in. At the 2024 average auction clearing price of EUR 64.74 reported in the Commission’s Carbon Market Report COM(2025) 735, those allowances would cost about EUR 7,264. The same voyage from 2026 carries the full 50% share, 160.3 allowances for CO2, with methane and nitrous oxide added from that year.

FuelEU Maritime measures greenhouse gas intensity, and 0.10% marine gas oil does not pass it on its own. Fossil marine gas oil has a default well-to-wake intensity of about 90.77 gCO2e/MJ against a 2025 limit of 89.34 gCO2e/MJ under Article 4(2) of Regulation (EU) 2023/1805. The FuelEU scope follows the same 100% and 50% split for ships above 5,000 GT, and the penalty is EUR 2,400 per tonne of VLSFO-equivalent energy of deficit, set out in FuelEU penalties, pooling and multipliers .

Not a NOx ECA, and the Mediterranean NOx work

The Mediterranean ECA covers sulphur oxides and particulate matter only. MEPC.361(79) inserts regulation 14.3.5 and nothing into regulation 13, so the Tier III limits of regulation 13 do not apply in the Mediterranean. Those limits (3.4 g/kWh below 130 rpm, 9 x n^-0.2 between 130 and 2,000 rpm, and 2.0 g/kWh at 2,000 rpm and above) apply only in NOx emission control areas, compared in NOx Tier I, II and III .

A Mediterranean NOx ECA is at the study stage, and nothing has been proposed. A regional expert meeting in Malta on 18 and 19 November 2025 reviewed a feasibility study prepared through REMPEC and recommended that the earliest entry into force of a possible Mediterranean NOx ECA “should not be earlier than 2032”. Its conclusions go to the seventeenth meeting of the REMPEC Focal Points, tentatively in 2027. No proposal has been put to the Marine Environment Protection Committee.

For ship design this means a newbuilding for Mediterranean trade needs no selective catalytic reduction or exhaust gas recirculation to meet an ECA NOx limit there. An owner planning for trading after 2032 has no adopted text to design against.

How the ECA was adopted

The Mediterranean ECA came through the Barcelona Convention system before it reached IMO. The Barcelona Convention , adopted on 16 February 1976 and amended in 1995 as the Convention for the Protection of the Marine Environment and the Coastal Region of the Mediterranean, has 22 Contracting Parties: 21 coastal States and the European Union. It is part of the UNEP Regional Seas Programme , with its secretariat in Athens.

The steps, in order:

  1. December 2019. COP 21 in Naples adopted Decision IG.24/8, a roadmap towards a proposal for the possible designation of the Mediterranean as an ECA.
  2. December 2021. COP 22 in Antalya adopted Decision IG.25/14, agreeing to submit the proposal to IMO.
  3. 4 February 2022. IMO document MEPC 78/11, “Proposal to Designate the Mediterranean Sea, as a whole, as an Emission Control Area for Sulphur Oxides”, was submitted. It proposed an effective date of 1 January 2025.
  4. June 2022. MEPC 78 agreed to designate the Mediterranean and approved draft amendments to Annex VI with a view to adoption at MEPC 79.
  5. 16 December 2022. MEPC 79 adopted MEPC.361(79), with application from 1 May 2025 rather than the proposed 1 January 2025.

Who submitted it

MEPC 78/11 was submitted by 40 States and the European Commission, in three groups. Fifteen Mediterranean coastal States that were then Parties to Annex VI proposed the designation: Albania, Croatia, Cyprus, France, Greece, Italy, Malta, Monaco, Montenegro, Morocco, Slovenia, Spain, the Syrian Arab Republic, Tunisia and Turkey. Six Mediterranean States that had not yet ratified Annex VI associated themselves: Algeria, Bosnia and Herzegovina, Egypt, Israel, Lebanon and Libya. The 19 non-riparian EU Member States associated themselves too.

The document recorded that, as of 23 November 2021, the six non-Parties were in the process of ratifying Annex VI. Operative paragraph 5 of MEPC.361(79) invites Mediterranean coastal States to ratify and implement Annex VI “as soon as possible, if they have not yet done so, at least by the date of entry into force”. Annex VI binds ships of its Parties, so a coastal State’s ratification decides whether its own flag is bound in the ECA.

The case the proponents made

MEPC 78/11 based its case on modelled fuel use and health effects. Its 2016 baseline was 19.16 million tonnes of fuel used in the Mediterranean Sea area by 33,163 unique vessels, of which 78.8% was heavy fuel oil, 17.2% marine diesel oil, 2.8% marine gas oil and 1.3% LNG. It estimated more than 1,000 avoided premature deaths and more than 2,000 avoided cases of childhood asthma a year for model year 2020, and a 95% net reduction in SOx and 62% in PM2.5 compared with the global Annex VI limits alone.

On cost, the proposal put the total at about USD 1.7 billion in 2020. It costed two alternative compliance routes: fuel switching at USD 1.761 billion a year and the scrubber route at USD 1.157 billion a year, both in 2016 dollars. The cost per tonne of pollutant avoided was USD 13,400 for SOx and USD 155,000 for PM.

What the proposal said about fuel prices

MEPC 78/11 examined the price ratio between marine gas oil and low sulphur fuel oil over November 2019 to October 2020. It found a ratio between 1.05 and 1.51, with a median of 1.29, and a spread that had stabilised at around USD 95 per tonne in the Europe, Middle East and Africa region from June 2020. They describe the market of 2019 and 2020, and a current spread has to be taken from the market on the day.

The proposal also recorded that 507 million people live in areas where air pollution exceeds national standards or World Health Organization levels, the population basis for its health estimates.

The cost of compliance for an operator

For a ship burning separate fuels, the ECA cost is the price spread between 0.10% fuel and the fuel it would otherwise burn, multiplied by the tonnes consumed inside the ECA. The proposal’s own spread gives a way to size it. The figures below are hypothetical except that spread, which is a 2020 market figure and not a current price.

Assume a ship burns 100 tonnes of fuel inside the ECA on a passage and pays the MEPC 78/11 spread of USD 95 per tonne for 0.10% fuel over the 0.50% alternative. The fuel cost of the ECA for that passage is 100 x 95 = USD 9,500. A liner operator passes that kind of cost to shippers through the bunker adjustment factor or a separate low sulphur surcharge .

A scrubber ship avoids the spread on the tonnes it burns through the scrubber and pays for the system instead, which is the trade-off the proposal’s two cost routes reflect. A ship burning LNG or methanol pays neither spread, but its fuel cost and its EU carbon position are set by the gas or methanol market and by the ETS and FuelEU rules above. The IMO 2020 sulphur cap article covers the global price history.

The Mediterranean among the other ECAs

The Mediterranean was the fifth SOx ECA and the first added after the global 0.50% limit took effect. Four existing areas have applied the 0.10% limit since 1 January 2015: the Baltic Sea , the North Sea , the North American ECA and the US Caribbean ECA . Two more followed through MEPC.392(82), adopted on 4 October 2024 and in force on 1 March 2026: the Canadian Arctic and the Norwegian Sea , where 0.10% applies from 1 March 2027.

A North-East Atlantic ECA was adopted by MEPC.407(84) on 1 May 2026. It enters into force on 1 September 2027 with its 0.10% limit from 1 September 2028, and is adopted but not in force. The Mediterranean is the only one of the eight SOx areas that is not also a NOx Tier III area: the other seven are listed in regulation 13.6, the North-East Atlantic among them once in force.

AreaInstrument0.10% applies fromNOx ECA
Baltic SeaRegulation 14.3.11 January 2015Yes
North SeaRegulation 14.3.21 January 2015Yes
North AmericanRegulation 14.3.31 January 2015Yes
US CaribbeanRegulation 14.3.41 January 2015Yes
MediterraneanMEPC.361(79), regulation 14.3.51 May 2025No
Canadian Arctic, Norwegian SeaMEPC.392(82)1 March 2027Yes
North-East AtlanticMEPC.407(84), not in force1 September 2028Yes, adopted, not in force

Table constructed by Shipping-Wiki.com from the MARPOL Annex VI regulation 14 register and the resolutions named, 25 September 2026.

Other MARPOL designations in the Mediterranean

The Mediterranean carries several other MARPOL designations with their own rules. It is a special area under Annex I for oil, designated in the 1973 Convention, and under Annex V for garbage, with special-area requirements in effect from 1 May 2009 under MEPC.172(57). It is not a sewage special area: under Annex IV the Baltic Sea is the only one, according to MEPC.1/Circ.778/Rev.5 of 9 May 2025.

The North-Western Mediterranean Sea PSSA , designated by MEPC.380(80) on 7 July 2023 for waters off France, Italy, Monaco and Spain, is a particularly sensitive sea area , a separate designation from the ECA; the Strait of Bonifacio article covers the other PSSA in those waters. A PSSA sets no fuel limit, and the Atlantic Western European Waters PSSA lies wholly outside the Mediterranean.

Common misreadings of the Mediterranean ECA

The statements below are wrong, and each has a textual answer.

  • “The ECA entered into force on 1 May 2025.” The amendment entered into force on 1 May 2024. The 0.10% limit applied from 1 May 2025 because regulation 14.7 exempts ships for twelve months after a new ECA enters into force.
  • “The Sea of Marmara is included.” The north-eastern line crosses the Dardanelles at its Aegean mouth. Marmara, the Bosphorus and the Black Sea are outside.
  • “Only territorial seas are covered.” Appendix VII covers all waters bounded by the three continents within the three lines, high seas included.
  • “Fuel bunkered before May 2025 could be used up afterwards.” MEPC.361(79) contains no such provision. The regulation 14.7 exemption ended on 1 May 2025.
  • “Open-loop scrubbers are banned in the ECA.” The ECA accepts an approved scrubber as an equivalent. Bans on open-loop discharge are national or port measures, such as the French 3-mile band.
  • “A scrubber failure allows four hours on high sulphur fuel.” MEPC.1/Circ.883 paragraph 6 gives one hour before the ship should change over to compliant fuel.
  • “Tier III NOx applies in the Mediterranean.” The designation is SOx and particulate matter only; no Mediterranean NOx ECA has been proposed to IMO.
  • “A FONAR exempts the ship.” Regulation 18.2 lets a ship present evidence of its efforts. MEPC.320(74) states that a FONAR is not an exemption, and price is not a valid ground.

Limitations

This article states the Mediterranean ECA as MARPOL Annex VI and the named EU instruments stood on 25 September 2026. The boundary description is taken from Appendix VII paragraph 4 as inserted by MEPC.361(79); positions of individual ports relative to the lines are derived from those coordinates and should be checked against an official chart for any operational decision near a boundary.

National and port rules on open-loop scrubbers change without IMO involvement. Only the French and Balearic measures are described, because they are the ones confirmed in primary sources; other Mediterranean States and ports may impose restrictions not listed here. The current Annex VI party status of Mediterranean States that were non-Parties in November 2021 should be checked in the IMO status of treaties before relying on it.

The cost and carbon worked examples use hypothetical fuel quantities. The USD 95 per tonne spread is a 2020 figure from the proposal and does not describe current prices, and the EUR 64.74 allowance price is the 2024 auction average. The Mediterranean NOx work is at study stage and any date after 2032 is a recommendation of a regional meeting, not an adopted requirement.

Frequently Asked Questions (FAQs)

What is the Mediterranean Sea Emission Control Area?
It is the fifth emission control area for sulphur oxides and particulate matter under MARPOL Annex VI, listed as regulation 14.3.5 by Resolution MEPC.361(79). Inside it, fuel oil used on board may not exceed 0.10% m/m sulphur under regulation 14.4, unless the ship uses an approved equivalent such as an exhaust gas cleaning system.
When did the 0.10% limit start to apply in the Mediterranean?
On 1 May 2025. MEPC.361(79) was adopted on 16 December 2022, deemed accepted on 1 November 2023 and entered into force on 1 May 2024. Regulation 14.7 then exempted ships from the ECA fuel and changeover requirements for twelve months, so the limit bit on 1 May 2025.
Is the Sea of Marmara inside the Mediterranean ECA?
No. The north-eastern boundary is a line across the Strait of Canakkale, the Dardanelles, from Mehmetcik Burnu to Kumkale Burnu. The Dardanelles transit, the Sea of Marmara, the Bosphorus and the Black Sea are all outside the ECA.
Is Gibraltar inside the Mediterranean ECA?
Yes. The western boundary joins Cape Trafalgar (36°11’N, 6°02’W) and Cape Spartel (35°48’N, 5°55’W), the western entrance to the Strait. Everything east of that line, including Gibraltar, Algeciras, Ceuta and Tanger Med, lies inside the ECA.
Where does the Mediterranean ECA end at Suez?
At the northern entrance to the Suez Canal, with a polygon excluded around Port Said, bounded by 31°29’N and 31°14’N and by 32°16’E and 32°32.62’E. The canal and the excluded polygon are outside the ECA.
Does the Mediterranean ECA cover the high seas in the middle of the basin?
Yes. Appendix VII paragraph 4 of MARPOL Annex VI describes the area as all waters bounded by the coasts of Europe, Africa and Asia within the three boundary lines. It is not limited to territorial seas or exclusive economic zones.
Is the Mediterranean ECA also a NOx emission control area?
No. MEPC.361(79) designates the area for sulphur oxides and particulate matter only. The Tier III NOx limits of regulation 13.5 do not apply in the Mediterranean.
When will a Mediterranean NOx ECA apply?
No proposal has been submitted to IMO. A regional expert meeting in Malta on 18 and 19 November 2025 recommended that any Mediterranean NOx ECA should not enter into force earlier than 2032, and sent its conclusions to the REMPEC Focal Points meeting planned for 2027.
Was there a grace period for non-compliant fuel bought before 1 May 2025?
No. The only relief was the regulation 14.7 exemption, which MEPC.361(79) operative paragraph 4 applied until 1 May 2025. The resolution contains no provision for consuming earlier non-compliant stock after that date.
Can a ship carry 0.50% VLSFO while in the Mediterranean ECA?
Yes, provided it does not burn it there. Regulation 14.1 limits fuel carried for use to 0.50% sulphur for ships without an approved equivalent; regulation 14.4 governs the fuel used inside the ECA.
What must a ship record when changing over fuel for the Mediterranean ECA?
Regulation 14.6 requires a written changeover procedure, and a record of the volume of low-sulphur fuel in each tank with the date, time and position when changeover is completed before entry or started after exit. The record goes in the logbook or electronic record book prescribed by the flag Administration.
Can a scrubber be used instead of 0.10% fuel in the Mediterranean?
Yes, as an equivalent approved by the flag Administration under regulation 4. MEPC.340(77), which applies to systems on ships keel-laid or systems delivered from 1 June 2022, treats an emission ratio of 4.3 SO2 (ppm) to CO2 (% v/v) as equivalent to 0.10% sulphur fuel, for petroleum-derived fuels.
Does the Mediterranean ECA ban open-loop scrubbers?
No. MEPC.361(79) says nothing about washwater. Restrictions come from coastal and port States: France has banned open-loop discharge within its 3-nautical-mile coastal band since 1 January 2022, and the Balearic Islands Port Authority prohibits open-loop use in its port waters under an ordinance published as BOE-A-2025-5158.
What should a ship do if its scrubber fails inside the ECA?
Under MEPC.1/Circ.883 paragraph 6, if the system cannot be put back into a compliant condition within one hour, the ship should change over to compliant fuel oil. If it has no compliant fuel, it communicates a proposed course of action to its Administration and the relevant authorities.
What if 0.10% fuel is not available at the last port before the ECA?
Regulation 18.2 lets the ship present evidence of its efforts to buy compliant fuel. It must notify its Administration and the competent authority of the port of destination, normally by a fuel oil non-availability report in the MEPC.320(74) format. The report is not an exemption, and the price of compliant fuel is not a valid ground.
How long must bunker delivery notes and samples be kept?
The bunker delivery note is kept on board for three years after delivery (regulation 18.6). The MARPOL delivered sample is retained until the fuel is substantially consumed and in any case for not less than 12 months (regulation 18.8.1).
What sulphur result on an in-use sample counts as a breach of the 0.10% limit?
Appendix VI of MARPOL Annex VI, as replaced by MEPC.324(75), gives a test margin W of 0.11% m/m for in-use and onboard samples against the 0.10% limit. A result above that is a breach; the MARPOL delivered sample is judged against the limit itself.
Does the EU apply the 0.10% limit in its Mediterranean waters?
Yes, from 1 May 2025. Directive (EU) 2016/802 defines SOx emission control areas by reference to IMO designations (Article 2(h)) and applies 0.10% in a new ECA 12 months after the designation enters into force (Article 6(3)). No amending act was needed.
Does the EU at-berth 0.10% rule still matter in the Mediterranean?
Yes. Article 7 of Directive (EU) 2016/802 applies 0.10% to ships at berth in every EU port, inside or outside an ECA, except where published timetables show less than two hours at berth or the ship switches off all engines and uses shore-side electricity.
Who proposed the Mediterranean ECA?
IMO document MEPC 78/11 of 4 February 2022 was submitted by 40 States and the European Commission. Fifteen Mediterranean coastal States that were Parties to Annex VI proposed it, six Mediterranean States not then Parties associated themselves, and 19 other EU Member States associated themselves.
What did the Barcelona Convention Parties decide?
The Contracting Parties adopted a roadmap towards a Mediterranean ECA in Decision IG.24/8 at COP 21 in Naples in December 2019, and agreed to submit the designation proposal in Decision IG.25/14 at COP 22 in Antalya in December 2021.
Did MEPC 78 adopt the Mediterranean ECA?
No. MEPC 78 in June 2022 agreed to designate the Mediterranean and approved draft amendments to MARPOL Annex VI. MEPC 79 adopted them as MEPC.361(79) on 16 December 2022.
What did the proponents estimate compliance would cost?
MEPC 78/11 estimated costs of about USD 1.7 billion in 2020, with fuel switching adding USD 1.761 billion a year and the scrubber route USD 1.157 billion a year (2016 dollars), for a 95% net reduction in SOx and 62% in PM2.5.
What health benefits did the proposal claim?
More than 1,000 avoided premature deaths and more than 2,000 avoided cases of childhood asthma a year, for model year 2020, according to MEPC 78/11.
How much fuel do ships burn in the Mediterranean?
The proposal’s 2016 baseline was 19.16 million tonnes of fuel used by 33,163 unique vessels in the Mediterranean Sea area, 78.8% of it heavy fuel oil. That is modelled consumption in the area, not bunker sales at Mediterranean ports.
Is the Mediterranean a special area under other MARPOL annexes?
Yes, under Annex I for oil and Annex V for garbage, where special-area requirements took effect on 1 May 2009 (MEPC.172(57)). It is not a sewage special area under Annex IV, where the Baltic Sea is the only one.
Is the North-Western Mediterranean PSSA part of the ECA?
No. The North-Western Mediterranean Sea PSSA, designated by MEPC.380(80) on 7 July 2023 for France, Italy, Monaco and Spain, is a separate designation and sets no fuel limit.
Are the Atlantic approaches to the Strait of Gibraltar in the ECA?
No. The ECA stops at the line from Cape Trafalgar to Cape Spartel. A separate North-East Atlantic ECA was adopted by MEPC.407(84) on 1 May 2026; it enters into force on 1 September 2027 with its 0.10% limit from 1 September 2028, and is adopted but not yet in force.
Does 0.10% marine gas oil satisfy FuelEU Maritime?
No. Sulphur and greenhouse gas intensity are separate tests. Fossil marine gas oil has a default well-to-wake intensity of about 90.77 gCO2e/MJ, above the 2025 FuelEU limit of 89.34 gCO2e/MJ under Article 4(2) of Regulation (EU) 2023/1805.
How is a Genoa to Tunis voyage treated under the EU ETS?
As a voyage between an EU port and a non-EU port, 50% of its emissions are in scope under Article 3ga of Directive 2003/87/EC, for ships of 5,000 GT and above. The shipping company surrendered allowances for 70% of that share for 2025, and surrenders for 100% from 2026.
Do the scrubber guidelines apply to every ship?
MEPC.340(77) applies to exhaust gas cleaning systems on ships whose keel was laid, or whose system was delivered, on or after 1 June 2022. Paragraph 1.4 calls the guidelines recommendatory and invites Administrations to base their regulation 4 approvals on them. Earlier systems were approved under the 2015 guidelines, MEPC.259(68).

Sources

  1. IMO Resolution MEPC.361(79): Mediterranean Sea Emission Control Area for Sulphur Oxides and Particulate Matter, 16 December 2022
  2. IMO Resolution MEPC.340(77): 2021 Guidelines for Exhaust Gas Cleaning Systems
  3. IMO MEPC.1/Circ.883: guidance on EGCS monitoring failure and recommended actions, 21 May 2019
  4. IMO Resolution MEPC.320(74): 2019 Guidelines for consistent implementation of the 0.50% sulphur limit
  5. Directive (EU) 2016/802 relating to a reduction in the sulphur content of certain liquid fuels
  6. IMO: Marine Environment Protection Committee, 78th session, meeting summary
  7. IMO: Mediterranean Sea becomes an Emission Control Area, 1 May 2025
  8. IMO: Mediterranean States examine a possible NOx Emission Control Area, 28 November 2025
  9. DIRM Mediterranee: control of the ban on open-loop scrubbers in the 3-mile coastal band
  10. BOE-A-2025-5158: Balearic Islands Port Authority ordinance on port water quality, 17 February 2025
  11. Directive (EU) 2023/959 amending Directive 2003/87/EC (EU ETS), Article 3ga
  12. Regulation (EU) 2023/1805 (FuelEU Maritime)
  13. IMO document MEPC 78/11, 4 February 2022: Proposal to designate the Mediterranean Sea, as a whole, as an ECA for sulphur oxides (copy hosted by the Clean Arctic Alliance)
  14. European Commission: Carbon Market Report, COM(2025) 735, 3 December 2025