Category: Exhaust Gas Cleaning / Emissions Compliance
If your vessel uses an open-loop scrubber, your compliance window is getting shorter. Several European countries have already banned scrubber discharge in their waters, and a wider regional ban is coming. Here is what you need to know and when you need to act.
What has already happened
As of 1 July 2025, Finland, Sweden, and Denmark all banned open-loop scrubber discharge in their coastal and territorial waters. This covers Baltic Sea routes — meaning vessels trading to Hamburg, Rostock, Lübeck, or Kiel are already affected.
What is coming next
In June 2025, the OSPAR Commission — the body covering the North-East Atlantic, including the North Sea — agreed a staged ban across all 15 member countries. Germany is included.
| Deadline | What changes |
|---|---|
| 1 July 2027 | Open-loop discharge banned in all OSPAR internal waters and ports, including German North Sea ports |
| 1 January 2029 | Closed-loop systems also under review — a strengthening decision expected in 2027 |
What are your options
- Switch to low-sulphur fuel (VLSFO/MGO) when in restricted zones — simplest fix, no hardware changes needed
- Upgrade to a hybrid system (switchable between open and closed loop) — requires re-approval, but buys time
- Upgrade to full closed-loop / zero-discharge — the safest long-term investment, compliant well beyond 2027
- Do nothing — non-compliant from July 2027, risking port detentions
One thing many operators miss
Any modification to your existing scrubber system — even switching it to a different operating mode — counts as a system alteration under IMO rules. This triggers a full re-approval process under the current scrubber guideline (MEPC.340(77)). For EU-flagged vessels, MED certification must also be updated.
That process takes 6 to 12 months minimum. If you are planning an upgrade, the time to start is now, not six months before the deadline.
Bottom line
Vessels trading Baltic and North Sea routes should already be operating in closed-loop or fuel-switching mode in restricted zones. For the wider North Sea ban in 2027, the planning conversation needs to happen at the next drydock — or before it.
