Iceland’s New Scrubber Rule: Welcome, But Doesn’t Address Spill Risks or Black Carbon

Cruise ship, one of the biggest to visit Iceland, leaving Akureyri, on the way out of Eyjafjörður ©Adam Asgeir Oskarsson

Iceland’s New Scrubber Rule: Welcome, But Doesn’t Address Spill Risks or Black Carbon

Photo: Cruise ship, one of the biggest to visit Iceland, leaving Akureyri, on the way out of Eyjafjörður ©Adam Asgeir Oskarsson

Reykjavík, 9 December, 2019:- The Iceland Nature and Conservation Association and the Clean Arctic Alliance today welcomed the new regulation issued by Iceland’s Minister for the Environment and Natural Resources, Guðmundur Ingi Guðbrandsson, to restrict exhaust emissions containing high levels of sulphur from being burned by ships in Iceland’s territorial waters, i.e. 12 nautical miles, but highlight that while Iceland is making a positive step forward in cleaning up shipping emissions, the new rule contains a loophole that allows vessels to continue to burn polluting heavy fuel oil and emit black carbon, provided they use scrubbers to remove sulphur from the exhaust emissions

“Iceland’s new regulation to limit exhaust emissions with high levels of sulphur from shipping in Iceland’s waters is a positive step forward by Environment Minister Guðmundur Ingi Guðbrandsson, but fails to address emissions of black carbon, which accelerates Arctic sea ice melt, and in turn accelerate the effects of human-induced climate change,” said Árni Finnsson, of the Iceland Nature Conservation Association. “The only viable step forward is for Iceland to completely ban the use and carriage of heavy fuel oil from its territorial waters, ahead of an International Maritime Organization ban currently in development to ban its use and carriage in the Arctic”.

Using a scrubber to extract the sulphur from a ship’s exhaust results in the production of scrubber effluent or waste which will need to be disposed of. Most scrubbers are “open loop” which means the waste produced , which can be high in sulphur and also other pollutants such as heavy metals and polyaromatic hydrocarbons, can be dumped straight into the sea. There are also concerns that if a scrubber malfunctions in cold temperatures or due to ice, ships will continue to burn HFO and will emit high levels of Sulphur.

In addition, two other threats will remain. Continuing to use HFO along with a scrubber may reduce black carbon emissions somewhat, but it will not however prevent emissions of black carbon entirely. Black carbon is a climate forcer which when emitted into the atmosphere remains there for days to weeks before being deposited back onto land or water. If it is deposited onto snow and ice in the Arctic, it accelerates sea and ice melt, increasing the area of exposed, dark ocean water which absorbs more heat, and promoting the self-reinforcing cycle of human-induced climate warming.

The other threat is that the amount of HFO carried by ships in the North Atlantic and into the Arctic will not be significantly reduced by Iceland’s new regulation, which means the risk of severe damage to the ocean ecosystem in case of an accidental HFO spill will remain. Cleaning HFO once it enters the marine environment, particularly colder Arctic waters, is virtually impossible.

The Iceland Nature and Conservation Association and the Clean Arctic Alliance urge the Government of Iceland to ban all vessels which burn or carry HFO, from entering Icelandic waters. Banning the use and carriage of HFO and switching to lighter distillate fuels, eliminates the threat from sulphur emissions, reduces black carbon emissions and removes the HFO spill risk entirely. Furthermore, together with the other Nordic nations, Iceland should demonstrate leadership at the forthcoming meeting of the Pollution Prevention and Response sub-committee (17 – 21 February, 2020) of the International Maritime Organization (IMO), the UN agency responsible for regulating international shipping, in seeking a ban on the use and carriage of HFO in Arctic waters, by means of an amendment to MARPOL Annex I.


Árni Finnsson, Iceland Nature and Conservation Association, [email protected], +354 551 2279

Dave Walsh, Communications Advisor, Clean Arctic Alliance [email protected], +34 691 826 764


Regulation banning the use of heavy fuel oil in the territorial sea of Iceland

Government of Iceland: Spurt og svarað um svartolíu og reglugerðarbreytingu sem bannar notkun hennar (Questions and Answers heavy fuel oil and regulatory amendment that prohibits its use)


About Black Carbon

Black carbon (BC), a harmful air pollutant, is the product of incomplete combustion of organic fuels, and contributes from 7-21% of shipping’s climate warming impact. The largest sources of BC are fossil fuel, biomass and biofuel combustion. Ships emit more BC per unit of fuel consumed than other combustion sources due to the quality of the fuel used. BC has human health impacts and is a potent climate forcer. When emitted in the Arctic, black carbon particles fall on snow, on glacier ice and sea ice, reducing their reflectivity (albedo) and increasing the absorption of heat. As multi-season sea ice recedes due to climate change, Arctic waters will open up to increased shipping – which could lead to increased black carbon emissions, fueling an already accelerating feedback loop.

Recognising the threat to the Arctic from black carbon the Arctic Council’s Framework for Action on Enhanced Black Carbon and Methane Emissions Reductions (agreed in Iqaluit in 2015), commits the Arctic countries to demonstrate leadership by reducing Black Carbon (and methane) emissions produced beyond the borders of Arctic States. The Framework for Action includes a commitment to actively work with and within relevant forums and agreements, which includes the IMO’s Marine Environment Protection Committee, to promote actions and decisions that lead to enhanced black carbon and methane emissions reductions.

Heavy fuel oil is a greater source of harmful emissions of air pollutants, such as sulphur oxide, and particulate matter, including black carbon, than alternative fuels such as distillate fuel and liquefied natural gas (LNG). When emitted and deposited on Arctic snow or ice, the climate warming effect of black carbon is up to five times more than when emitted at lower latitudes, such as in the tropics.

Infographic: How Can We Reduce Black Carbon Emissions From International Shipping?

“Residual fuels such as HFO accounted for an estimated 83% of BC from ships, while ships powered with 2-stroke slow speed diesel main engines were responsible for two-thirds of global BC emissions. Further, just six flag states—Panama, China, Liberia, Marshall Islands, Singapore, and Malta—accounted for more than half of BC emissions.”

Report: Black Carbon Emissions and fuel use in global Shipping

Report: The impacts of an Arctic shipping HFO ban on em


About the Clean Arctic Alliance

The following not-for-profit organisations form the Clean Arctic Alliance, which is committed to a ban on HFO as marine fuel in the Arctic:

Alaska Wilderness League, Bellona, Clean Air Task Force, Danish Ecological Council, Ecology and Development Foundation ECODES, Environmental Investigation Agency, European Climate Foundation, Friends of the Earth US, Greenpeace, Iceland Nature Conservation Association, Nature And Biodiversity Conservation Union, Ocean Conservancy, Pacific Environment, Seas At Risk, Surfrider Foundation Europe, Stand.Earth, Transport & Environment and WWF.

More more information visit