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As of January 1, 2020, the upper limit of sulfur emissions outside emission control areas decreased from 3.5% to 0.5%. This paper aims to present some of the challenges associated with the implementation of the sulfur cap and investigates its possible side effects as regard the drive of the International Maritime Organization (IMO) to reduce carbon dioxide (CO₂) emissions. Even though it would appear that the two issues (desulfurization and decarbonization) are unrelated, it turns out that there are important cross-linkages between them, which have not been examined, at least by the regulators.

A literature review and a qualitative risk assessment of possible CO₂ contributors are presented first. A cost-benefit analysis is then conducted on a specific case study, so as to assess the financial, as well as the environmental impact of two main compliance choices, in terms of CO₂ and sulfur oxide.

From a financial perspective, the choice of a scrubber ranks better comparing to a marine gas oil (MGO) choice because of the price difference between MGO and heavy fuel oil. However, and under different price scenarios, the scrubber choice remains sustainable only for big vessels. It is noticed that small containerships cannot outweigh the capital cost of a scrubber investment and are more sensitive in different fuel price scenarios. From an environmental perspective, scrubber ranks better than MGO in the assessment of overall emissions.

Fuel price data in this paper was based on 2019 data. As this paper was being written, the COVID-19 pandemic created a significant upheaval in global trade flows, cargo demand and fuel prices. This made any attempt to perform even a rudimentary ex-post evaluation of the 2020 sulfur cap virtually impossible. Due to limited data, such an evaluation would be extremely difficult even under normal circumstances. This paper nevertheless made a brief analysis to investigate possible COVID-19 impacts.

The main implication is that the global sulfur cap will increase CO₂ emissions. In that sense, this should be factored in the IMO greenhouse gas discussion.

According to the knowledge of the authors, no analysis examining the impact of the 2020 sulfur cap on CO₂ emissions has yet been conducted in the scientific literature.

The International Maritime Organization has decided that as of 1.1.2020, SOx content in a ship’s emissions should be no more than 0.5 per cent. The purpose of this paper is to address the various challenges expected to arise from the enforcement of the global cap sulfur regulation.

The authors outline various enforcement options and present a model that calculates the profits from noncompliance in the high seas, so as to help determine the level of fines that could be imposed in case of violation.

The main finding is that a harmonized system of fines, which are more than potential savings from cheating, would be a strong deterrent for compliance.

To the authors’ knowledge, no paper in the maritime literature on sulfur regulations has focused on enforcement as of yet.