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Friday, September 21, 2018


The question as to whether the chemical tankers Ship Type III are to be subject to the new accelerated phase-out has been raised once again by several members.

The answer is as follows:

Tankers transporting cargoes listed under the MARPOL Annex II are not subject to the phase-out scheme. They would only be subject if they transported cargoes listed under MARPOL Annex I. These include oil products (CPP and DPP) and crude oils. Be aware that veg oils and animal oils are listed under MARPOL Annex II.

Single hull chemical tankers will cease to have the right to transport oil as of the date given by the Phase-Out Table in paragraph 4 of the revised Regulation 13G.

According to paragraph 5(a) of the revised 13G, if the tanker has a double bottom (quite a few of the Ship Type III chemical carriers have a double bottom), then such a tanker is allowed to trade oil until its 25th anniversary, provided that the ship was in operation by 1 July 2001 (this is to prevent any further newbuildings with double bottom benefiting  from such an exemption).

However, be aware that paragraph 8 of the revised 13G gives the right to Port States to deny access to its berths to ships using the delayed phase-out . It is not clear yet to what extent Port States will use this right, but, at this time, it is worth mentioning as a theoretical negation of the provision of paragraph 5.

If you would like any further information, please e-mail to Dragos Rauta (