The most revealing part of the scrubber discussion today is what owners and charterers are choosing for newbuild vessels that will not enter service until the end of this decade – fuel flexibility is key.
Greek owners provide some of the clearest examples. As reported by Riviera Maritime Media, Navios Maritime Partners has committed $482 million to four scrubber-fitted VLCC newbuildings for delivery in the second half of 2028. Navios also holds options to acquire another two plus two newbuilding VLCCs.
In a company announcement in July, TOP Ships said it had agreed to acquire three scrubber-fitted, eco-design MR product tanker newbuildings for delivery in 2029. SAFETY4SEA has meanwhile reported that Aegean Shipping Management has committed to two scrubber-fitted VLCCs and two LR2/aframax tankers.
The pattern extends into dry bulk. Splash reported that Seanergy Maritime Holdings’ renewal programme comprised six scrubber-fitted newbuildings in May and has since expanded to include another scrubber-fitted capesize newbuilding for delivery in 2029. Separately, Splash has linked Thenamaris to an order for four scrubber-fitted MR2 product tankers.
Look beyond individual companies and the trend is even clearer. Lloyd’s List analysis of Clarksons Research data at the end of June showed scrubbers fitted or planned on 92% of VLCCs on order, compared with 66% of those already trading. For suezmaxes, the comparison was 66% of the orderbook against 40% of the existing fleet. In dry bulk, 74% of capesize newbuildings were due to carry scrubbers, compared with 57% of vessels on the water. For panamaxes, the figures were 46% and 19% respectively.
These are not merely investments responding to the 2020 sulphur cap, they concern vessels expected to trade through the 2030s and into the foreseeable future.
The value lies in not having to predict 2035
Nobody ordering a ship today can say with confidence which compliant marine fuel will be cheapest or readily available in 2035, what or where alternative fuels will be available at scale, how regional requirements will evolve, or what charterers will be prepared to pay for. Many newbuilds are therefore being provided with basic infrastructure for an alternative future fuel option, e.g. methanol or ammonia, but are also continuing to install EGCS (scrubbers).
An exhaust gas cleaning system is an approved equivalent means of sulphur compliance under MARPOL Annex VI which allows an owner to retain access to different conventional fuel grades, adjusting to both the market and fuel availability. Where local rules require fuel switching or a different operating mode, the vessel can adjust. For ECA transits, both HFO and VLSFO (by far the most widely used marine fuel in the world today) may be used with scrubbers.
The economics will not be identical for every vessel: A VLCC operating predominantly on long-haul trades has a different degree of exposure to local discharge restrictions from an MR making frequent calls in tightly regulated ports. Fuel optionality has significant value because fleets operate under varying commercial, bunker supply and regulatory conditions.
The charter arrangements also matter. In the Navios and TOP Ships cases, charterers have committed to scrubber-fitted vessels years before delivery; clearly these are not speculative technology decisions by owners, there is identifiable commercial demand behind the investments.
Science and process matter because the investment is real
While capital allocation does not by itself ensure environmental compliance, it does reflect the scale of the commercial decisions affected by regulation and therefore the importance of ensuring that the regulatory process is clear, practical, and led by the best scientific evidence.
There is a substantial body of credible research assessing EGCS discharge water and lifecycle impacts. More than 30 studies and assessments collated in the Clean Shipping Alliance’s Recommended EGCS Studies library include work by government agencies, universities and independent research organisations across the United States, Japan, Denmark, South Korea, Australia and Brazil. Across the conditions assessed, this evidence identifies low or negligible environmental risk and finds discharges are within relevant water-quality criteria.
Lifecycle research also challenges the assumption that switching to low-sulphur fuel is automatically the lower-impact option. Studies comparing HFO used with EGCS against VLSFO and MGO have found that, once fuel production, refining, transport and onboard use are considered together, HFO with EGCS can match or outperform low-sulphur alternatives across a range of environmental impact categories, including climate impact (CO2).
This is why having a common standard for evaluating the environmental risk from scrubbers in local waters is so important. The IMO’s MEPC.1/Circ.899 Guidelines provide that framework, setting out a common methodology for risk and impact assessments, including WET testing and other internationally accepted protocols that local authorities can use when considering restrictions on EGCS discharge water.
Regional requirements are nevertheless becoming more fragmented. OSPAR Decision 2025/01 requires OSPAR Contracting Parties to adopt national prohibitions on open-loop EGCS discharge in internal waters and port areas by July 2027, followed by discharge from EGCS closed-loop mode by July 2029, although implementation will be postponed by some nations for up to three years. Another recommendation now encourages the same restriction to be extended to territorial seas, which OSPAR is evaluating now.
The risk evaluation principle is straightforward: assess the receiving environment, identify whether an unacceptable risk exists and match any measure proportionately to that risk. However, currently there is no public evidence that any OSPAR Contracting Parties have conducted the IMO-recommended risk assessments or considered other mitigations prior to agreeing to restrictions in their waters.
Where an area-specific assessment using accepted testing methods, such as ISO, US EPA and OECD protocols, demonstrates an unacceptable environmental risk, proportionate restrictions should follow. Where it does not, any intended restriction on an approved means of MARPOL Annex VI compliance should be reconsidered, until supported by a clear IMO-aligned evidential justification.
In the meantime, while regional regulatory irregularities continue, especially in Europe, owners must continue to make responsible, forward-looking business decisions to ensure fuel flexibility for their newbuilds.
Across several of the largest tanker and dry bulk segments, owners and charterers continue to invest in and contract around scrubber-fitted tonnage expected to trade well into and beyond the 2030s. Those decisions today make it clear that the market continues to value the fuel options and compliance flexibility that EGCS provide.
These capital decisions send a clear message to regulators that as certainty around the future availability of compliant alternative fuels is not yet evident, owners must continue to build flexibility for existing fuels into new vessels.
Source: By Andreas Chrysostomou, Executive Director, Clean Shipping Alliance
