New North-East Atlantic ECA: SOx, PM and NOx (MEPC 84)
A new emission control area is never news to read the day before entering it: from 1 September 2027 the North-East Atlantic is an ECA for sulphur, particulate matter and nitrogen oxides — the EEZs and territorial seas of Greenland, Iceland, the Faroes, Ireland and of the mainland parts only of the United Kingdom, France, Spain and Portugal — but the SOx and PM limits apply only 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.
As with every ECA, the dates are staged and must not be confused. The amendments enter into force on 1 September 2027; the 0.10% m/m sulphur limit and the associated particulate matter requirements apply from 1 September 2028, twelve months after entry into force; the NOx Tier III requirements follow the usual three-date principle (building contract placed on or after 1 January 2027, or, in the absence of a contract, keel laying / delivery on the corresponding dates), so they concern new ships, not the existing fleet. For ships regularly transiting the area, this means revising fuel changeover planning and the availability of ECA-compliant fuel well in advance, exactly as already happens for existing ECAs, but with a new geographic area to integrate into passage planning and bunkering management.
Where it starts and where it ends
This is the question the page had never answered, and without an answer the rest is of little use. Appendix VII of Annex VI, at paragraph 6, defines the area thus: “The North-East Atlantic Emission Control Area encompasses the exclusive economic zones and territorial seas, extending up to 200 nautical miles from the baselines of Greenland, Iceland, the Faroes, Ireland, the mainland's of the United Kingdom, France, Spain and Portugal. This designation excludes the seas bounded by the North Sea area, as defined in regulation 1.14.6 of Annex V of the present Convention.”
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.
The full perimeter is described by 175 coordinates in the WGS 1984 datum, joined by geodetic lines and presented in clockwise order. The proposal the area comes from estimated its extent at roughly 5.05 million km²: that would make it the world's largest ECA, though “the largest” is press language and not a regulatory qualification.
The verbatim above and the coordinates on this page are read on the adopted text of Res. MEPC.407(84). With them falls the inconsistency this page used to flag: IMO Circular Letter No.5085 gave the starting point as 86°19'.18 N, 60°10'.17 W in paragraph 7 and as 86°19'.30 N, 60°10'.28 W in the table; the adopted text carries 86°19'.18 N, 60°10'.17 W in both places. The inconsistency belonged to the circular, not to the resolution.
The twelve months are not a concession: they are Regulation 14.7
The gap between entry into force and the fuel obligation is not something negotiated for this ECA. It is a general provision of Annex VI, applying to every new area: “During the first 12 months immediately following entry into force of an amendment designating a specific emission control area under paragraph 3 of this regulation, ships operating in that emission control area are exempt from the requirements in paragraphs 4 and 6 of this regulation and from the requirements of paragraph 5 of this regulation insofar as they relate to paragraph 4 of this regulation”. That is why 1 September 2027 becomes 1 September 2028: not through a negotiation, but by arithmetic.
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.
Then there is the shipyard case, which lives elsewhere: Regulations 13.5.4 and 13.5.5, introduced by Res. MEPC.286(71). It is not a general exemption for anyone in transit: it covers building and sea trials, conversion, repair or maintenance activities that “take place in a shipyard or other repair facility located in a NOx Tier III emission control area”, and it is temporary and conditional. The conditions are two, and both must be met: the engine meets the Tier II limits, and the ship “sails directly to or from the shipyard or other repair facility, does not load or unload cargo during the duration of the exemption, and follows any additional specific routing requirements indicated by the port State”. Loading or unloading cargo during the transit forfeits the exemption.
None of these provisions touches sulphur. Regulation 14 knows no exemptions by ship category: the 0.10% m/m limit in an ECA applies to all. The only ways out are equivalent means approved under Regulation 4 (scrubbers, alternative fuels) and the general exceptions of Regulation 3 — emissions necessary for securing the safety of a ship or saving life at sea, and emissions resulting from damage to a ship or its equipment, provided all reasonable precautions were taken and there was no intent to cause damage nor recklessness.
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
MARPOL Annex VI, amendments adopted by res. MEPC.407(84) on 1 May 2026 (MEPC 84): designation of the North-East Atlantic as an Emission Control Area for SOx, PM and NOx, through the new regulation 14.3.8 and appendix VII of Annex VI. Entry into force 1 September 2027; SOx (0.10% m/m) and PM limits applicable from 1 September 2028, twelve months after entry into force; NOx Tier III from entry into force, not from 2028, for ships caught by the three-date principle: building contract placed on or after 1 January 2027; in the absence of a contract, keel laid (or similar stage of construction) on or after 1 July 2027; delivery on or after 1 January 2031 — not “alternative criteria, any one of them is enough”. The wording of Regulation 13 subordinates the second criterion to the absence of the first: the keel counts “in the absence of a building contract”, not as a free alternative. For a ship with a building contract the keel date is irrelevant; for a ship without one it is the only date that counts. Delivery is a criterion in its own right, catching ships contracted or laid down earlier but delivered much later. The SOx/NOx staging also applies to the Canadian Arctic and Norwegian Sea ECA covered in the adjacent page, which nevertheless has a different NOx regime: a single criterion, keel from 1 January 2025 for the Canadian Arctic, and the three dates of sub-paragraph 13.5.1.2.3 for the Norwegian Sea. That page is the adjacent topic.
To be read alongside: Appendix VII, paragraphs 6 and 7, for the perimeter and the 175 coordinates in the WGS 1984 datum; Regulation 14.7, which is the reason for the twelve months' suspension of the sulphur limit; Regulation 14.6, for the written changeover procedure and the records; Regulation 13.5.2 for the three exclusions from Tier III and Regulations 13.5.4 and 13.5.5 for the temporary shipyard exemption; Regulation 4 for equivalent means and Regulation 3 for the general exceptions.
Scope of Application
Every ship navigating, or planning to navigate, within the EEZs and territorial seas of Greenland, Iceland, the Faroes, Ireland and of the mainland parts of the United Kingdom, France, Spain and Portugal, excluding the North Sea area and the waters of the Azores, Madeira and the Canaries. The area exists from 1 September 2027; the fuel obligation (0.10% m/m sulphur or an approved equivalent under Regulation 4) applies from 1 September 2028, by operation of Regulation 14.7; the NOx Tier III obligation, by contrast, applies from entry into force, and only to ships meeting the three-date criteria.
Procedure / How to Complete It
- Update charts and passage-planning systems with the boundaries of the new ECA: the eastern limit runs along the outer limits of the North Sea (62°00'.00 N / 04°00'.00 W to the north, 48°30'.00 N / 05°00'.00 W at the Channel) and the southern limit meets the Cape Trafalgar – Cape Spartel line at 35°57'.59 N, 05°58'.27 W.
- Check that the track does not assume the waters of the Azores, Madeira or the Canaries are included, nor Moroccan waters south of Gibraltar: they are outside the area.
- Revise the written fuel changeover procedure that Regulation 14.6 requires, and the records it calls for: the volume of low-sulphur fuel oil in each tank, and the date, time and position of the ship when the changeover is completed before entry and commenced after exit.
- SOx and PM: verify the availability of fuel oil meeting the 0.10% m/m limit at the usual bunkering ports along routes crossing the area, or the cover of an equivalent arrangement approved under Regulation 4.
- NOx Tier III: verify applicability by construction date and area, and that the EIAPP certificate, the NOx Technical File and the engine's approved operational mode are consistent with it. There is no such thing as “NOx-compliant fuel”: Tier III concerns the engine and its configuration, not what is bunkered.
- Update onboard procedures and crew training on the new area, including it in the voyage-planning checklist.
- Verify that NOx abatement systems (if fitted) are approved and operable in the mode set out in the NOx Technical File. Tier III limits are not “specific” to this area: what is specific is the geographical scope and the applicability dates.
- If the ship is bound for a shipyard inside the area, check that the conditions of Regulations 13.5.4 and 13.5.5 are met: a Tier II compliant engine, a direct passage, and no commercial loading or unloading during the transit.
Practical Example
Example. A ship bound from Lisbon to Rotterdam after 1 September 2028 has no transition left to make: the mainland Portuguese, Spanish and French EEZs all sit inside the new ECA, which borders the North Sea directly. The same ship, today, exits and re-enters. A ship calling at Funchal is a different case: the waters of Madeira are outside the area, and the legs to and from the archipelago remain subject to the global 0.50% m/m limit. Different again is a ship bound for a Galician yard for conversion work: if the engine is Tier II, if she sails directly and if she moves no cargo, Regulations 13.5.4 and 13.5.5 exempt her from Tier III for the duration of the operation — but not from the sulphur limit, which from 2028 applies to her like anyone else.
What Typically Goes Wrong
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Updating passage planning and charts postponed until close to the entry-into-force date (1 September 2027) | Risk of navigating in the new ECA without properly planned changeover procedures | Update passage planning, charts and procedures well ahead of the entry-into-force date |
| Availability of compliant fuel not verified at the usual bunkering ports along the new area | Difficulty sourcing compliant fuel after entry into force | Verify the availability of compliant fuel from usual suppliers along the affected routes well in advance |
| Waters of the Azores, Madeira or the Canaries treated as inside the new ECA because Portugal and Spain are listed | Low-sulphur fuel burned needlessly on Atlantic routes to the archipelagos | Read the word “mainland” in paragraph 6 of Appendix VII: only the mainland parts of Portugal and Spain are taken |
| Regulation 13 exemptions (recreational, reduced power, shipyard) understood as exemptions from the sulphur limit as well | Non-compliant fuel used in an ECA by a ship that believes itself exempt | Remember that those provisions exclude from NOx Tier III alone: on sulphur only Regulation 4 (equivalent means) and Regulation 3 (general exceptions) remain |
| Shipyard exemption relied on while the ship loads or unloads cargo along the way | Exemption forfeited: Regulation 13.5.4 conditions it on a direct passage and on no commercial operations | Plan the voyage to and from the yard without intermediate commercial calls, and observe any routing requirements set by the port State |
What the PSCO Checks
Operational Tips
- Do not wait until 2027 to update passage planning and bunkering contracts: compliant fuel availability needs checking well in advance.
- Integrate the new ECA into the voyage-planning checklist alongside existing areas, not as a separate exception to remember.
- The word that decides the perimeter is mainland: the Atlantic archipelagos of Portugal and Spain stay outside, even though both States are listed.
- If you operate NOx abatement systems, check their compatibility with the new area's specific requirements before entry into force.
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.
- Charts and passage-planning systems updated with the new ECA's boundaries, Atlantic archipelagos excluded
- Written changeover procedure and Regulation 14.6 records prepared for the new area
- Fuel changeover planning revised for entry/exit from the area
- Availability of compliant fuel verified at usual bunkering ports
- Crew trained and voyage checklist updated with the new area
- NOx abatement systems (if fitted) verified for compatibility with the area's requirements
FAQ
Related Topics
Last substantive revision of this page: 28 August 2026 · page fingerprint bb8572bce530