February 20, 2023 | Circular No. 11495

Dear Member,

Vessels are currently allowed to use scrubbers to meet the 0.1% maximum sulfur requirement in Canadian waters, per Vessel Pollution and Dangerous Chemicals Regulation. However, as reported in CL10968 and CL11391, vessels operating with open loop scrubbers may face challenges doing so, including the following limitations:

  • Per Vessel Pollution and Dangerous Chemicals Regulations in the Canada Shipping Act, 2001, vessels using scrubbers must meet the IMO Guidelines on discharges.
  • Transport Canada has advised that open-loop scrubbers are not to be used in freshwater or brackish water as they are not designed to be effective in these environments.
  • The Government of Canada has proposed limiting or prohibiting scrubber washwater in Marine Protected Areas. As mentioned in CL11494, this would apply to federally established Marine Protected Areas in waters between 0-12 nautical miles from shore.
  • Under the Canada Marine Act, ports have the authority to prohibit scrubber use in waters under their jurisdiction.

Canadian Port Authorities that currently restrict open-loop scrubber use within waters under their jurisdiction include the Port of VancouverPort of Montreal, and Port of Sept Iles. The Port of Prince Rupert has also proposed disallowing open loop scrubbers its harbour. We advise members with vessels that operate using open-loop scrubbers to be aware that additional ports may be implementing similar restrictions.

Please contact the undersigned with comments or questions.



Miako Ushio
Manager, Enviornmental and Regulatory Affairs