Transport Canada launched an online consultation about vessels using scrubber systems in Canadian waters from November 19, 2024 until January 19, 2025.
This report summarizes what we heard from stakeholders, including:
- the marine industry and associations
- non-governmental organizations
- Indigenous Peoples
- members of the general public
On this page
Background
On January 1, 2020, the International Maritime Organization (IMO) implemented a cap on the sulphur content in marine fuel used for international shipping. The cap reduced the sulphur content allowed in a ship’s fuel from 3.5% to 0.5%. The goal was to improve air quality, preserve the environment, and protect human health.
Canada and the United States have stricter limits on the allowable sulphur content in marine fuels based on the North American Emissions Control Area (ECA), which was created in 2015. The new Canadian Arctic ECA limits the sulphur content of fuels used to 0.1% by 2027.
Under the International Convention on the Prevention of Pollution from Ships (MARPOL) and Canada’s Vessel Pollution and Dangerous Chemical Regulations, vessels can meet the restrictions on the sulphur in fuels and resulting emissions by either:
- using low-sulphur fuel (less than 0.5% sulphur); or
- using pollution-reducing technology such as a scrubber
Scrubbers are recognized by the IMO as an acceptable means to follow both domestic and international regulations regarding the sulphur limits.
A scrubber (or exhaust gas cleaning system) reduces the levels of certain chemicals or pollutants (like sulphur oxides and nitrous oxides) in marine engine exhaust.
Scrubbers are either open-loop, closed-loop or hybrid systems.
- Open-loop scrubbers continually wash exhaust gases with fresh, naturally alkaline seawater; the washwater is filtered and treated then discharged back into the sea.
- Closed-loop scrubbers recirculate treated washwater; Most of the waste is stored onboard the vessel, filtered and treated and disposed of at certified waste management sites on shore. They discharge a smaller amount of “bleed-off” water back into the sea but the pollutants can occur in higher concentrations.
- Hybrid systems can switch between open-loop and closed-loop.
There has been growing concern recently about the potential longer-term environmental impacts of discharge from scrubbers on marine species and ecosystems. We launched an online consultation to gather feedback from Canadians on the issue. The consultation was open for 60 days from November 19, 2024 to January 19, 2025.
Consultation Approach
The consultation was meant to gain perspective on the use and potential effects of scrubbers in Canadian waters. The consultation was published on our Let’s Talk Transportation webpage. We also asked over 2,000 possible respondents from Indigenous Peoples, industry stakeholders, community associations, professional associations, research organizations, and other levels of government to participate. This included emailing the consultation link to members on the Canadian Marine Advisory Council's distribution list, sending invitations to Indigenous Peoples through the bi-monthly National Bulletin to Indigenous Communities and Organizations, and promotion on social media.
We asked the following discussion questions:
- Do you think Transport Canada should implement restrictions on scrubber system discharge from vessels in Canadian waters? Why or why not?
- What factors should be considered when exploring a timeline for the introduction of potential restrictions on scrubber discharge from vessels and why?
- Is there anything else that Transport Canada should consider about vessels using scrubber systems, including when exploring potential restrictions?
We also invited stakeholders and partners to respond to these questions by email throughout the consultation period.
Who we heard from
During the consultation period, we received 930 responses across the 3 questions from 629 unique respondents through the Let’s Talk webpage or by email. Individual respondents to the survey remained anonymous, but they identified as belonging to one of the following groups:
- the general public
- environmental non-governmental organizations
- the marine industry
- Indigenous Peoples
How we heard
376 comments were submitted by email and 253 came through the Let’s Talk webpage. Many respondents did not directly address the discussion questions listed above. Because of this, we are not presenting the feedback in that format.
It is important to note that 323 of the 376 emails we received were identical. This suggests they were part of a form letter campaign. However, each of these form responses was submitted by a separate person and we acknowledged them as a unique view.
By the numbers
| Total Comments | 930 |
|---|---|
| Total respondents | 629 |
| Preformatted comments | 323 |
| Other comments | 607 |
| Let's Talk respondents | 253 |
| Email respondents | 376 |
What we heard
We received a large number of responses of different lengths and complexities. We grouped these ideas under themes to analyze them more clearly. Some responses overlapped across multiple themes, showing how interconnected these issues are. The themes are:
- Environmental impacts
- Scientific research
- International considerations
- Economic considerations
- Communication and consultation
Environmental impacts
An overwhelming majority of respondents (98%) supported some kind of restriction on using scrubbers or scrubber discharge in Canadian waters. Respondents were concerned with water pollution from scrubbers. Many comments said that using scrubbers to reduce or eliminate sulphur oxides and other pollutants simply moves them from the air to the water. Others shared concerns that using scrubbers with heavy fuel oil emits more particulate matter, black carbon, and carbon dioxide into the atmosphere compared to using lower-sulphur fuels.
Some feedback that supported restricting scrubber systems or scrubber discharge in Canadian waters pointed to Canada’s public domestic and international commitments. Respondents noted that the negative effects on marine life from scrubber discharge undermine Canada’s commitments to protect 30% of its marine spaces by 2030 (as part of Canada’s 2030 Emission Reduction Plan) and its investments in protecting marine areas.
A recurring theme was urgency in protecting the marine environment. Many respondents emphasized the need for immediate restrictions on scrubbers and scrubber discharges. Some suggested that Transport Canada should use available tools to address the issue, such as Interim Orders. They have also been used to limit speeds and establish areas where ships cannot go to reduce risks like noise and ship strikes in critical marine mammal habitats.
Many respondents believe that immediate national restrictions on scrubbers would greatly benefit Canada’s coastal waters and should be implemented as soon as reasonably possible. They suggest that we should focus first on ecologically, environmentally, and culturally significant areas or those experiencing the greatest harm. For example, respondents mentioned Canada’s network of marine protected areas could benefit from restrictions on scrubber use, particularly within the habitat of the Southern Resident Killer Whale in the Salish Sea. These areas are designated for the long-term conservation of nature, its ecosystem services, and cultural values.
Several respondents who self-identified as Indigenous emphasized the need for restrictions in culturally significant and sensitive areas. They were strongly opposed to the continued discharge of scrubber washwater. They highlighted concerns about its negative effects on water quality, marine life, and the health of fish and other marine species that Indigenous Peoples rely on for food and economic activities.
Some respondents suggested a phased approach that targets open-loop scrubbers first be adopted if a complete ban on scrubbers is unrealistic. These restrictions are already in place at several Canadian ports, which ban washwater discharge at berth or anchor. They noted that this approach could specifically target ships using open-loop scrubbers because their discharge is much more polluting than discharge from ships using closed-loop scrubbers.
Scientific evidence
One of the most common discussion points was the need for scientific evidence for the potential impacts of scrubber washwater discharge on the marine environment. Respondents were split on this topic. Some cited studies showed harm to the marine environment, while others pointed to studies that do not show harm at typical discharge concentrations and volumes. Respondents on both sides called for peer-reviewed, science-based research to clearly determine and demonstrate discharge level, composition and potential impacts. This will make sure future decisions are informed by sound scientific evidence.
This work includes risk and impact assessments in Canadian waters, as outlined in the IMO’s 2022 guidelines (MEPC.1/Circ.899). The IMO guidelines encourage member states to do thorough, transparent risk assessments before imposing any scrubber restrictions. This includes detailed sampling and analysis of washwater from multiple vessels and comparing the makeup of discharge (like PAHs, heavy metals and pH) against recognized water quality criteria.
Several respondents recommended making time for comprehensive risk assessments and evaluating results. This would include publishing and providing the results to stakeholders, including the marine industry, so they can modify their ship operations to meet any new restrictions before they enter into force.
Several respondents defended scrubbers. They noted that scrubbers are explicitly allowed under MARPOL Annex VI, Regulation 14 and are an IMO-approved technology that follows the regulations. They argued that a blanket ban on all types of scrubbers would unfairly penalize those who have invested in these systems based on IMO guidance.
Canadian vessel operators have made significant financial investments in scrubber technology to meet regulatory standards, acting in good faith under the current framework. These respondents suggested that prior investments deserve protection by including grandfather provisions or more time to comply for systems already in place. They also emphasized that the IMO’s work must be fully developed before Canada considers changes to its scrubber regulations.
International considerations
Some feedback wanted Canada to align its scrubber policies with the United States. There is no nationwide ban in the United States, but there are some regional or state-level restrictions, including in California, Washington, and Alaska. They see this approach as more balanced and less disruptive, targeting areas where the issue is most prevalent.
Respondents emphasized that the IMO’s discussions about scrubbers must address Canada's unique needs, such as the shared waters of the Great Lakes, distinct water conditions, and the need for regulations that work with the United States. Several respondents said that any regulatory or policy changes should make sure that both Canadian and United States vessels are treated fairly.
In addition, respondents also suggested that Canada should consider practices from other places that have bans on using scrubbers or requirements for vessels to use cleaner fuels. This would allow vessels to switch fuels without needing engine modifications before entering these areas. Respondents pointed to countries like Denmark, Sweden, and Finland who have announced prohibitions on discharges in their territorial waters. Denmark specifically banned open-loop scrubber discharges as of July 1, 2025, followed by bans on closed-loop discharges in 2029. Respondents also noted that 5 Canadian ports currently have restrictions:
- Vancouver
- Montreal
- Prince Rupert
- Sept-Îles
- Saint John
Economic considerations and alternatives
Many respondents noted that ships with scrubbers can seamlessly switch to cleaner distillate fuel. This is a common practice for vessels transiting in and out of ECAs and does not require retrofits. They argued that this means there is no practical or technical reason to delay restrictions on installing scrubbers and no need for a phased-out timeline for banning scrubbers or discharging scrubber washwater.
However, several respondents opposed an immediate blanket ban on scrubbers without consulting affected parties. They argued that it could disrupt marine trade, impose excessive costs on ship operators, disadvantage Canadian vessel owners and undermine global efforts to reduce overall emissions, including greenhouse gases. They highlighted that although shipowners can switch to low-sulphur fuel, a scrubber ban would force them to use more expensive low-sulphur fuels for extended periods. This could cause significant economic impacts and issues with limited supply.
Respondents noted that scrubbers are a significant long-term investment and could be an option when low-sulphur fuel isn’t available. They also mentioned that vessel crews would need to manage temperature differences, compatibility issues, and potential operational risks for engines. A few respondents suggested publishing an implementation schedule for any future prohibitions as early as possible instead. This would allow time for economic adjustments to be made in the least disruptive way possible to the marine and shipping industries.
Communication and consultation
Finally, many respondents had a strong desire to be included in future consultations on this matter. They emphasized that any amendments to regulations should involve increased engagement and communication with industry and other stakeholders. This will make sure changes are collaborative and informed.
Next steps
Feedback from this consultation period is valuable information for guiding the future of scrubber use in Canadian waters. This information provides us with a deeper understanding of Canadians' views on the use of scrubber systems in Canada.
Further consultation with industry, Indigenous Peoples, and interested parties has begun and will continue into 2026.
We thank everyone who participated in Let's Talk Transportation: Vessels using scrubber systems in Canadian waters for sharing their time, knowledge, and expertise.