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Marine Fuels Sulphur Legislation: European legislation has recently been adopted regarding the sulphur content of marine

fuels. Shell Marine Products thought it would be helpful to its customers to summarise critical dates arising from EU Directive 2005/33/EC and related MARPOL Annex VI requirements. Key Dates: See attached map regarding the location and extent of the Sulphur Emission Control Areas (SECAs). 1. Baltic Sea SECA, maximum sulphur content for marine fuels 1.5% by mass: 19th May 2006: 11th August 2006: Baltic SECA 1.5% limit comes into effect in line with MARPOL Annex VI Baltic SECA 1.5% limit comes into effect in line with EU Directive 2005/33/EC Article 4a

From 19th May 2006 therefore the 1.5% sulphur limit will be enforced for vessels of all flags by port state control of those countries which are signatory to MARPOL Annex VI. Vessels flagged in MARPOL Annex VI signatory countries will be required to comply regardless of port of call within the SECA. From 11th August 2006 enforcement will extend to all EU state ports, and will apply to vessels of all flags. 2. North Sea SECA, maximum sulphur content for marine fuels 1.5% by mass: 11th August 2007: November 2007: North Sea 1.5% limit comes into effect in line with EU Directive 2005/33/EC Article 4a North Sea 1.5% limit comes into effect in line with MARPOL Annex VI (date not yet finalised)

From 11th August 2007 the 1.5% sulphur limit will be enforced for vessels of all flags by port state control of all EU state ports. In this case MARPOL legislation lags slightly behind the implementation of the EU legislation. 3. Passenger ships operating on regular services to or from any EU Community port, maximum sulphur content for marine fuels 1.5% by mass: 11th August 2006: Passenger ship limit comes into effect in line with EU Directive 2005/33/EC Article 4a

The legislation defines passenger ships as vessels carrying more than 12 passengers (not crew or those employed on the business of the ship), and defines regular services as a series of passenger ship crossings operated so as to serve traffic between the same two or more ports, or a series of voyages from and to the same port without intermediate calls, either

according to a published timetable, or with crossings so regular or frequent that they constitute a recognisable schedule

Note: Customers should take independent legal advice regarding the legislation, and neither Shell Marine Products Limited nor any company of the Shell Group shall have any liability for any loss, damage, cost or expense to any person, whether shipowner, charterer or otherwise, which may occur in connection with or arising out of this interpretation or guidance. 1/3

4. Inland waterway vessels and ships at berth in Community ports, maximum sulphur content for marine fuels of 0.1% by mass 1st January 2010: The 0.1% limit comes into effect in line with EU Directive 2005/33/EC Article 4b, subject to certain exclusions

In addition to the above, Article 4c of Directive 2005/33/EC deals with trials and use of new emission abatement technologies. This article states that Articles 4a and 4b are not mandatory provided either ships undergo approved abatement trials or if ships are using approved abatement technology, provided that, in each case, certain conditions are fulfilled. Future Developments: The EU commission continues to review further potential legislation regarding the control of sulphur emissions within European waters. Shell Marine Products, through its participation in SEAaT and other industry bodies continues to maintain a proactive participation in discussions on further proposed developments, and will naturally share these developments with our customers as they become clear. Customer Commitment Shell Marine Products realises that the new IMO and EU legislation presents a significant challenge to the shipping industry, and it is committed to helping our customers develop and operationalise strategies to meet their new obligations. Specifically, Shell Marine Products offers its customers: A global policy of adherence to the MARPOL Annex VI requirements for Bunker Suppliers Many years of experience as the largest supplier of quality Low Sulphur Fuel Oil within the future SECA regions. Shell Low Sulphur bunkers are typically produced from native low sulphur crudes processed in our regional refineries. As with all Shell Marine Products fuels, quality is tightly controlled through our well-established Fuel Oil Quality Assurance System. Shell Marine Products offers customers a cylinder oil, Shell Alexia LS, specifically designed to perform under the testing conditions present when operating with Low Sulphur fuels in low speed engines. Even when a change in lubricant grade is not required, Shell Marine Products lubrication and condition monitoring services will compliment its range of high quality lubricants to assist customers in developing optimal lubrication strategies. As a founding member and sponsor of SEAaT (Shipping Emissions Abatement and Trading, an industry body set up to raise awareness and acceptance of solutions for emissions reductions that are sustainable, cost effective and achievable) Shell Marine Products can assist customers in understanding new legislative and technical developments in the fast changing world of environmental legislation.

Note: Customers should take independent legal advice regarding the legislation, and neither Shell Marine Products Companies nor any company of the Shell Group shall have any liability for any loss, damage, cost or expense to any person, whether shipowner, charterer or otherwise, which may occur in connection with or arising out of this interpretation or guidance.
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SECA Map This map shows the boundaries of Baltic Sea SECA 1 and North Sea SECA 2, together with Shells refineries and LSFO supply points in Northern Europe.

Shell Marine Products October 11th 2005 shell.com/marine

Notes: 1 Customers should take independent legal advice regarding the legislation, and neither Shell Marine Products Companies nor any company of the Shell Group shall have any liability for any loss, damage, cost or expense to any person, whether shipowner, charterer or otherwise, which may occur in connection with or arising out of this interpretation or guidance. 2 Reference to Shell Marine Products refers to companies registered under the marine business which are registered in the UK, Scandinavia and the U.S, Shell Marine Products Limited, Shell Marine Products A.S. and Shell Marine Products (US) Company respectively. 3/3