Environment and regulation

Entry into force and application dates of the Canadian Arctic and Norwegian Sea emission control areas (MEPC.392(82))

Resolution MEPC.392(82) adds the Canadian Arctic and the Norwegian Sea to the emission control areas of MARPOL Annex VI. Sulphur oxides and particulate matter apply to both seas. Nitrogen oxides Tier III applies by a construction date that differs from sea to sea.

The amendment carries three layers of dates. The day the amendment enters into force, the day the sulphur limit actually applies, and the construction date that separates ships whose engines must meet Tier III. Planning a fuel changeover on the entry-into-force date alone applies the sulphur limit a year early, and misreading the construction date catches ships that are not Tier III ships.

Scope: The requirements in this article reach only ships operating inside the Canadian Arctic emission control area and the Norwegian Sea emission control area. Outside the two seas the general limits of Annex VI continue to apply. This is not a worldwide obligation. It is a regional regime that works only inside the designated areas.

The amendment enters into force on 2026-03-01

3 INVITES the Parties to note that, in accordance with article 16(2)(g)(ii) of MARPOL, the said amendments shall enter into force on 1 March 2026 upon their acceptance in accordance with paragraph 2 above;

The resolution was adopted on 4 October 2024. Paragraph 2 provides that the amendments are deemed accepted on 1 September 2025 unless Parties object. Paragraph 3 fixes the entry into force on 1 March 2026 on the basis of that acceptance.

The entry-into-force date is the day the amended text becomes part of Annex VI. Not every requirement bites on that day. For the sulphur limit, regulation 14.7 gives separate time, as shown below.

The two seas join the lists in regulation 14.3 and regulation 13.6

.6 the Canadian Arctic Emission Control area, which means the area described by the coordinates provided in appendix VII to this Annex; and .7 the Norwegian Sea as defined in regulation 13.9.4 of Annex II of the present Convention.

Regulation 14.3 is the list of emission control areas for sulphur oxides and particulate matter. The amendment adds points .6 and .7 to the end of that list. The Canadian Arctic is bounded by the coordinates in appendix VII, while the Norwegian Sea borrows its definition from another Annex.

The same two seas enter the nitrogen oxides list in regulation 13.6 as points .5 and .6. The two lists point at the same seas, but the conditions of application are set separately by regulation 14 and regulation 13.

Paragraph 1 of appendix VII also changes. Alongside the Baltic Sea and the North Sea, the Norwegian Sea becomes an area defined outside the coordinate list of the appendix. The boundary of the Canadian Arctic is written into paragraph 5 of appendix VII as coordinates in two segments.

The 0.10% sulphur limit bites 12 months after entry into force

4 While a ship is operating within an emission control area, the sulphur content of fuel oil used on board that ship shall not exceed 0.10% m/m.

Regulation 14.4 sets the sulphur limit for fuel oil used inside an emission control area. Once the two seas are on the list in regulation 14.3, that limit reaches them too. For a newly designated area, however, regulation 14.7 gives separate time.

7 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.

During the first 12 months after the designating amendment enters into force, ships operating in that area are outside the paragraph 4 limit and the paragraph 6 changeover procedure and record. The paragraph 5 supplier documentation falls away with them so far as it relates to paragraph 4.

Item	Date	Basis
Designating amendment enters into force	2026-03-01	MEPC.392(82) paragraph 3
0.10% sulphur limit and changeover record apply	after 12 months from entry into force	regulation 14.7

The day 12 months from entry into force is 2027-03-01. From that day, a ship entering either sea has to meet the regulation 14.4 limit and carry the changeover procedure and changeover record of regulation 14.6. This relief exists on the sulphur side only. Regulation 13 has no such provision.

NOx Tier III splits by a construction date that differs from sea to sea

Regulation 13.5.1 prohibits operating an engine inside a Tier III emission control area, with an exception where the emission is within the Tier III limits and the ship was constructed on or after a certain date. Which date depends on the sea. The amendment gives the two seas different dates.

.3 1 March 2026 and is operating in the Norwegian Sea Emission Control Area.

The Norwegian Sea enters regulation 13.5.1.2 as point .3. A ship constructed on or after 1 March 2026 and operating in the Norwegian Sea is caught by Tier III.

.1 that ship is constructed on or after 1 January 2025 and is operating in the Canadian Arctic Emission Control Area.

The Canadian Arctic enters regulation 13.5.1.3 as point .1. The reference date is 1 January 2025. That is earlier than the entry-into-force date of the amendment. Regulation 13.5.1.3 is the provision that takes the later of the adoption date of the area or a date specified in the designating amendment, so the amendment writes that date in directly.

Sea	Tier III construction date	Provision entered
Norwegian Sea	2026-03-01	regulation 13.5.1.2
Canadian Arctic	2025-01-01	regulation 13.5.1.3

Because the two dates differ, one ship can be a Tier III ship in only one of the two seas. Take a ship constructed in June 2025. In the Canadian Arctic it is caught, in the Norwegian Sea it is not.

The Norwegian Sea construction date is defined through three separate dates

For the Norwegian Sea Emission Control Area, “ship constructed on or after 1 March 2026” means a ship: .1 for which the building contract is placed on or after 1 March 2026; or .2 in the absence of a building contract, the keel of which is laid or which is at a similar stage of construction on or after 1 September 2026; or .3 the delivery of which is on or after 1 March 2030.

On the Norwegian Sea side the word constructed is unpacked into three branches. A ship qualifies if the building contract is placed on or after 1 March 2026, or, where there is no contract, the keel is laid on or after 1 September 2026, or the delivery is on or after 1 March 2030. The three are joined by or, so meeting any one of them is enough.

The delivery condition matters. Even where both the contract and the keel laying fall before the reference dates, a delivery that slips to 1 March 2030 or later makes the ship a Tier III ship. A ship with a long building period cannot be judged from the contract date alone.

The date of build box in the IAPP supplement becomes three lines

1.3 Date of build 1.3.1 Date of building contract (dd/mm/yyyy) 1.3.2 Date on which keel was laid or ship was at a similar stage of construction (dd/mm/yyyy) 1.3.3 Date of delivery (dd/mm/yyyy)

The amendment replaces the 1.3 date of build box in the supplement to the International Air Pollution Prevention Certificate with three lines. Contract date, keel laying date and delivery date. The order is the same as the three branches of the Norwegian Sea definition above.

Once all three dates are written in the supplement, a port State can settle Tier III status from that box alone. On the ship’s side, check before the renewal survey that the three dates match the building contract and the class records.

Worth confirming

The passages above come from the body and annex of resolution MEPC.392(82), and regulation 14.4 and regulation 14.7 come from the consolidated Annex VI adopted by resolution MEPC.328(76). This article covers the text of the two resolutions only.

The boundary coordinates of the Canadian Arctic are written into paragraph 5 of appendix VII as 179 points and are not reproduced here. The definition of the Norwegian Sea borrows a provision from another Annex, so that provision has to be checked separately. Certification and testing of Tier III engines is settled by the NOx Technical Code and is not covered here. Whether a Party adds requirements for the two seas in its own law has to be checked in the law of that country.

You can consult the cited source documents

These links lead to the official publishers of the documents discussed here. Match the edition and provisions cited in the article, and check subsequent amendments and flag-state implementation before applying them.

Bellbook takes fuel changeover records in attached to the date and position of the voyage

The time the changeover finished and the position before the new boundary are gone unless written that day. Bellbook takes the voyage log and the Noon report in with the date and position, and totals fuel consumption voyage by voyage.

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