MARPOL Annex VI and NOx Technical Code 2008, with Guidelines for Implementation

MARPOL Convention: Amendments to Annex VI — 24 October 2025

Alain Auclair
2 min read
Use of multiple operational profiles for a marine diesel engine, including clarification of engine test cycles and clarification of entries in data reports required under Regulations 27 and 28; designation of the North-East Atlantic as a new Emission Control Area; accessibility to the IMO Ship Fuel Oil Consumption Database (IMO DCS); and the review clause for the short-term GHG reduction measure. Summary: Outlines measures to refine marine engine compliance and emissions control: enabling multiple operational profiles, clarifying engine test cycles and data reporting under Regulations 27 and 28, designating the North-East Atlantic as a new Emission Control Area, improving access to the IMO fuel oil consumption database, and incorporating a review clause for short-term GHG reduction requirements.

General context

The International Maritime Organization (IMO) is strengthening its strategy to reduce greenhouse gas (GHG) emissions from shipping. In this context, it is proposing amendments to MARPOL Annex VI on the prevention of air pollution from ships. These proposals, presented in Circular Letter No. 5085 of 24 October 2025, aim to introduce new environmental requirements, notably regarding emissions and ships’ carbon performance.

Main proposed changes

1.      Creation of a new ECA (North-East Atlantic): Proposal to establish an Emission Control Area (ECA) covering the EEZs and territorial waters of Greenland, Iceland, the Faroe Islands, Ireland, the United Kingdom, France, Spain, and Portugal;

2.      Application of the NOx Tier III standard: Requirement for new ships operating in this ECA to comply with the Tier III nitrogen oxides standard;

3.      Stricter limits for sulphur (SOx) and particulate matter (PM): Implementation or tightening of sulphur content and particulate matter caps for ships sailing in the new ECA;

4.      Strengthening carbon performance (CII) requirements and data transparency: Extension of obligations related to the Carbon Intensity Indicator (CII) and the IMO DCS fuel oil consumption data collection system; and

5.      Implementation timeline: Adoption is planned in 2026 with entry into force in 2027, in accordance with the Convention’s procedures.

Key takeaways

  • Canada actively supports these amendments.

  • Canadian ships, or those operating in the North Atlantic ECA, will have to comply with the new NOx, SOx, and carbon performance obligations.

  • Technical, regulatory, and documentary preparation is required immediately.

Strategic recommendations

- Adapt propulsion and emission control systems.
- Plan for compliant fuel supply.
- Ensure documentary and operational compliance.
- Maintain active monitoring of MEPC and IMO developments and Transport Canada requirements

Conclusion

These amendments mark a regulatory turning point for the decarbonization of shipping. Canadian stakeholders must act without delay to ensure compliance with the future North Atlantic ECA. See the circular letter

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