In our September ’18 Newsletter about the Sulphur Directive and sanctioning proceedings in Spain, we informed, as per our experience in previous cases, that the penalties for the non-compliance of the limits ranged between Eur. 5,000 and 10,000. Legally, fines could yield to a maximum of Eur. 180,000.

We know that the Spanish General Directorate of Merchant Marine is setting each specific fine based on the following facts:

– The percentage of Sulphur detected over the maximum.
– The period of time that the off-spec fuel was used in Spanish waters.

It seems the intention is also to standardize fines with the rest of EU countries. Our assumption is that this adjustment would mean an actual increase in the amount of the sanction.

Shall keep you duly abreast in this regard and we will be ready to assist in case needed.