The new MSA Notice (2018) 555 issued on 29 December 2018 bans discharging washing water from open loop scrubbers in part of China ECAs as of 1 January 2019.
For illustration purposes only the below map identities the prohibited areas which are, at least for now, Inland River ECAs, port areas in Coastal ECAs and the Bohai Sea.
The crucial provision of MSA's Notice is set out in Article 7 which bans the discharge of wash water or wash water residue from open-loop Sulphur Oxide Exhaust Gas Cleaning Systems. A free translation was kindly provided by Hai Tong & Partners, Shanghai:
The discharge and treatment of water pollutants generated by exhaust gas after-treatment device used by a ship shall conform to requirements of relevant regulations. It is prohibited to discharge into Inland River ECAs, waters of ports in Coastal ECAs and Bohai sea waters the washing water generated from open exhaust gas cleaning system. Requirements for prohibiting the discharge into waters within other coastal ECAs the washing water generated from open exhaust gas cleaning system will be promulgated in due time for implementation. It is also prohibited to discharge into water or burn onboard the washing water residuals generated from exhaust gas cleaning system, the ship shall truthfully record the situation regarding the storage and disposal of washing water residuals generated from exhaust gas cleaning system.
In respect of the storage and disposal of the wash water there is an obligation on the Owners to hold all relevant compliance certificates, technical and monitoring manuals and the record book of the exhaust gas cleaning system.
Wash water residues from Exhaust Gas Cleaning Systems should be handled as an operational waste.
For any discharge of the wash water or residues proper documentary trail should be kept for a period of no less than 18 months as good evidence.
Available for further reading (see links):
Huatai's circular dated 15 January 2019 and an English translation of MSA's Notice (2018) 555 is kindly shared by Hai Tong & Partners, Shanghai.