Shipping is now settling in to the post change over period following the new sulphur content limit for vessels entering and operating in designated Emission Control Areas. The Paris MoU has now issued guidelines on compliance and inspection matters. The guidelines The Paris MoU, covering 27 maritime administrations in and around Europe, has issued guidelines on the application of MARPOL Annex VI Regulation 18 in an Emission Control Area (ECA), which are republished next to this advisory. Regulation 18 of Chapter III of Annex VI of MARPOL concerns issues of the (non) availability of MARPOL compliant fuel. The guidance on an inspection by a port state control officer (PSCO) for a vessel within an ECA includes: looking at the bunker delivery note (BDN) checking the MARPOL sample of the fuel verifying that there is a written procedure as well as record of fuel changeover Should a non-compliance be found then a more detailed inspection would follow. Risk management advice Should a vessel not be able to obtain compliant fuel, then it might be able to utilise the provisions of Regulation 18, but the Association would caution that this is not a "get out" provision for compliance. It is likely that in practice PSC will rigorously test any attempted reliance on this provision to ensure that best efforts were in fact made to source compliant fuel. In order to be able to rely on Regulation 18's provision it will be necessary, at a minimum, to: present a record of efforts made to source compliant fuel show evidence of an attempt to buy such fuel demonstrate efforts made to locate alternative sources notify the port state administration in the port of arrival of this situation notify the vessel's flag state of this situation further evidence will be the vessel's voyage plan (and how it corroborates the non-availability of compliant fuel) provide contact details of fuel suppliers approached for compliant fuel plans to obtain compliant fuel at the first port of call in an ECA For a