VIEWPOINT: Sweden's Scrubber Ban in Danger of Becoming an Own Goal

Scrubber system. File Image. Image Credit: Ship & Bunker

The Swedish government's decision in July to announce the prohibition of discharges from open-loop exhaust gas cleaning systems (EGCS, or "scrubbers") within Swedish territorial waters from July 1, 2025 - with all operations of closed loop scrubbers also prohibited from January 1, 2029 - sets a concerning precedent.

The evidence supporting the ban appears to be light and lacking the support of a risk assessment; a process that the IMO recommends before any EGCS restrictions are implemented.

At the Clean Shipping Alliance (CSA) we, like many others, have seen reports from Swedish sources over the years questioning the potential impact of EGCS discharges, but we've not yet seen any evidence of actual environmental harm.  However, the several studies we have provided data for – whether water quality, accumulation in ports, or impact on marine life -- have repeatedly shown little/no risk. Our only conclusion is that Sweden's decision must be based on other assumptions. 

Denmark soon followed Sweden with a similar decision and timetable for enacting a ban in their waters as well – also apparently without a risk assessment. This was particularly disappointing, considering that some of the most credible studies showing little or no environmental risk from scrubbers have come from Danish sources, including from the government itself.  

As an alternative means of compliance in accordance with regulation 4 of MARPOL Annex VI, the use of scrubbers – which had been in use both on land and for other purposes within the marine industry for decades – was supported by all IMO Member States as well as the European Union. Indeed, it remains included in the EU Sulphur Directive as an alternative means of reducing sulphur emissions, which it does remarkably well, along with reducing harmful particulate matter and visible smoke.

Today, the approximately 4,000 ships globally that are fitted with EGCS/scrubbers, about 8% of the global trading fleet, are providing a practical, transitional bridge to alternative fuel solutions which are not yet ready. Importantly, EGCS are increasingly recognized as having a potentially critical role in meeting shipping's decarbonisation goals, as exhaust cleaning is an essential process step in a marine carbon capture and storage system (CCS). At least one CSA member is already actively developing and operationally testing these systems with existing scrubbers -- innovative problem solving for the marine industry.

Restrictions of EGCS use also have the potential to be an 'own goal' in ports air emissions quality, as EGCS-equipped ships typically reduce nitrogen oxides (NOx), and have less sulphur, less PAH's, less ultra-fine particulates, and less CO2 on well-to-wake basis, than ships using only ECA-compliant marine gasoil (MGO). Our experience shows an increase in fuel consumption of 1.0 - 1.5 percent for scrubber use, which is minimal compared to the significant energy penalties in the MGO refining process.

In a World where scalable alternative low carbon fuels could be decades away, the restriction of a transition technology like EGCS, which provides improved air emission quality and has the technical potential to help shipping decarbonise, seems very short-sighted.  And when such restrictive actions are taken unilaterally, without strong evidence, uncertainty is created for the global shipping sector, adding potential risk to other investment decisions such as alternative fuels and decarbonisation technologies.

Our message to other countries (and ports) that also may have considered this backward step of restricting the use of EGCS: do your own risk assessment in your own waters, per IMO guidance. The science is available and competent, objective parties can help you arrive at an informed decision – as some other major port States already have.