Applicability: all vessels imported into China after 1 September 2018 intended for Chinese domestic trades
1.Chinese domestic trade requirement summary
On 3 July 2018, the Chinese Ministry of Transport published new national regulations for controlling emissions of nitrogen oxides (NOx) within China.
These new national regulations will require domestic vessels operating Chinese domestic trades to comply with the IMO Tier-II NOx emission limits, irrespective of the age of the vessel. Chinese domestic trades include both coastal and inland waters.
As such, all vessels imported into China after 1 September 2018 intended for Chinese domestic trades will be required to comply with the IMO Tier-II NOx emission limits.
Chinese coastal domestic trade is considered to be within:
- The Chinese national 12 nm zone; and
- Hainan Island waters.
Chinese inland waterways are considered to be:
- All navigable waters of the Yangtze River; and
- All other inland navigable waterways of major cities.
2.NOx compliance
NOx Tier-II limits took effect for engines installed on vessels constructed on or after 1 January 2011. However, it is possible that the emissions from many engines installed before that and certified as NOX Tier-I compliant may actually satisfy the emission limits for NOx Tier-II, although the engine is not certified as NOx Tier-II compliant.
Consequently, it has been identified that owners of vessels affected by the new regulations will generally be faced with one or more of three possible scenarios:
- Diesel engines on board the vessel are already compliant with the NOx Tier-II emission limits and have the appropriate NOx Tier-II documentation. In such circumstances, no action is required.
- Diesel engines on board the vessel are compliant with the NOx Tier-I emission limits and have the appropriate NOx Tier-I documentation. However, the measured NOx emissions shown in the NOx Tier-I documentation also satisfy the NOx Tier-II requirements. In such circumstances, it is expected that only the engine certification will require updating – see Section 3 below.
- Diesel engines on board the vessel are compliant with the NOx Tier-I emission limits and have the appropriate NOx Tier-I documentation. The measured emissions shown in the NOx Tier-I documentation exceed the NOx Tier-II requirements. In such circumstances, it is expected that engine conversion and re-testing will generally be required – see Section 4 below.
The appropriate documentation is:
- MARPOL Annex VI (International) Air Pollution Prevention Certificate plus Supplement Certificate (IAPP Certificate)
- Engine (International) Air Pollution Prevention (EIAPP/EAPP) Certificates plus Supplements
- Engine NOx Technical Files
The engine’s Tier can be determined from the NOx emission values stated in the NOx Technical File. The NOx Technical File can contain two values: the parent engine NOx emission reference condition value, and the parent engine NOx emission value at the worst case tolerance condition. The highest value determines the engine’s Tier.
3.Diesel engines certified as Tier-I compliant but where emissions satisfy the Tier-II requirements
It should be noted that a Statement is not considered acceptable by the Chinese MSA. To achieve compliance, it is necessary to reissue the certification and documentation.
The following actions are recommended:
a) Shipowner
i) The shipowner should request the engine manufacturer to amend their ‘Member Engine’ NOx Technical File from NOx Tier-I to NOx Tier-II.
b) Engine Manufacturer
i) On receipt of a request from the shipowner, the engine manufacturer should amend the ‘Parent Engine’ NOx Technical File and then submit it for approval via their Lloyd’s Register (LR) Client-Facing Office, and, once completed;
ii) Amend and apply for ‘Member Engine’ NOx Technical File approval.
c) LR Client-Facing Office
i) The LR Client-Facing Office will communicate and provide all the necessary documentation from the owner and engine manufacturer to the LR Technical Support Office.
d) LR Technical Support Office
i) On receipt of a request from the engine manufacturer, LR will examine and approve the submitted ‘Parent Engine’ and ‘Member Engine’ NOx Technical Files, and then;
ii) Issue the ‘Member Engine’ Tier-II EIAPP Certificate.
e) Shipowner
i) The amended ‘Member Engine’ NOx Technical File and EIAPP Certificate should be placed on board;
ii) Once on board, LR should be invited to verify the ‘Member Engine’ documentation and to reissue the IAPP Certificate and Record.
4.Diesel engines certified as Tier-I compliant but where emissions do not satisfy the Tier-II requirements
The following actions are recommended:
If the engine on board does not comply with the Tier-II emission boundaries then the shipowner should seek the engine manufacturer’s clarification/confirmation as to whether it is feasible to upgrade or adjust to a Tier-II compliant engine.
5. If the engine manufacturer does not exist
The following actions are recommended:
The shipowner should approach LR for further information and consideration by contacting marpol@lr.org.