UK's ban on heavy fuel oil (HFO) in Arctic Waters

The UK Maritime and Coastguard Agency published a Maritime Guidance Note (MGN) 704, which outlines recent amendments to Annex I of the International Convention for the Prevention of Pollution from Ships (MARPOL), establishing a phased prohibition on the use and carriage of heavy fuel oil (HFO) in Arctic waters. This measure aims to protect the Arctic’s sensitive marine ecosystem from the risks associated with oil pollution.

The International Maritime Organization (IMO) adopted these amendments under Resolution MEPC.329(76). The changes extend existing prohibitions on the use and carriage of heavy-grade oils in Antarctic waters to include the Arctic region. The new regulation, known as Regulation 43A, focuses on reducing the risk of oil spills and pollution in the Arctic, where environmental conditions make cleanup operations extremely challenging. In the UK, these amendments are incorporated into national law through the Merchant Shipping (Prevention of Oil Pollution) (Amendment) Regulations 2024, which update the 2019 Regulations.

Heavy fuel oil is defined under Regulation 43.1.2 of MARPOL Annex I as any oil (excluding crude oils) with a density greater than 900 kg/m³ at 15°C or a kinematic viscosity exceeding 180 mm²/s at 50°C. This includes heavy-grade oils, tar, bitumen, and their emulsions.

The prohibition on the