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.
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
- Plan the changeover with sufficient lead time before the ECA boundary, allowing for the fuel's residence time in the lines and systems.
- Record in the engine log: date, time, position, fuel quantity in each tank at the start and end of the changeover.
- Verify the changeover is completed before entering the ECA (not at the point of entry itself).
- On exiting the ECA, similarly record the changeover back to standard-sulphur fuel.
- 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
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
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