September 12, 2023 | Circular No. 11576

Dear Member,

As noted in previous communications, an IMO prohibition on Heavy Fuel Oil (HFO) use and carriage as a fuel in Arctic waters will come into effect on 1 July, 2024.


Concerns about HFO use in the Arctic fall into two categories:

  1. A spill of HFO would be very difficult to clean up in the Arctic. It would be a long-term task, and the impacts on the environment and Arctic inhabitants could be dramatic.
  2. Burning HFO in the Arctic is a powerful short-term driver of climate change. The soot, or ‘black carbon’ created by burning HFO settles on snow or ice. Because it is dark in color, it absorbs energy from sunlight and speeds up polar ice melt. Climate change is a particular problem in the Arctic, which is seeing temperatures rise twice as fast as the global average.

Use and carriage of HFO has been banned in Antarctic waters since 2011.


It is our understanding that most LSFO & VLSFO currently available fall under the MARPOL definition of HFO (i.e., having a density at 15°C higher than 900 kg/m3 or a kinematic viscosity at 50°C higher than 180 mm2 /s). On a practical level, this means that most LSFO/ VLSFO may be neither used as a fuel, nor carried in fuel tanks, within Arctic waters as of July 2024. Please note that the prohibition does include fuel intended for use outside Arctic waters.

Additional information

Please contact the undersigned for additional information including the MARPOL text and exemptions.


Miako Ushio
Manager, Environmental and Regulatory Affairs