IMO issues BDN advice

Malcolm Latarche
Malcolm Latarche
ShipInsight

09 January 2019


Further advice on the various regulatory changes that became effective on 1 January has been given by the IMO.

As reported by ShipInsight in its Regulations Calendar, several new regulations including collection of fuel use and bunker delivery notes became effective at the turn of the year.

The IMO has issued a statement explaining some of the changes. Amendments to the bunker delivery note relating to the supply of marine fuel oil to ships which have fitted alternative mechanisms to address sulphur emission requirements entered into force on 1 January 2019. The amendment enters into force as the shipping industry counts down to 1 January 2020, when the limit for sulphur in fuel oil will be reduced to 0.50% m/m outside emission control areas (ECAs), from 3.5% currently. In ECAS, the limit will remain at 0.10% m/m.

The amendments to Appendix V of MARPOL Annex VI are intended to address situations where the fuel oil supplied does not meet low sulphur requirements, but has been supplied to a ship which is using an alternative compliance method permitted under regulation 4 of MARPOL Annex VI (“Equivalents”) to reduce the sulphur oxide emissions of the ship in order to comply with MARPOL requirements. An equivalent means may be abatement technology such as an exhaust gas cleaning system ("scrubber"), if accepted by the flag State of a ship as an alternative means to meet the sulphur limit requirement.

The bunker delivery note shall include a declaration signed and certified by the fuel oil supplier's representative that the fuel oil supplied is in conformity with regulation 18.3 of MARPOL Annex VI and that the sulphur content of the fuel oil supplied does not exceed:

  • the limit outside ECAS (currently 3.50%, falling to 0.50% from 1 January 2020) under regulation 14.1;
  • the limit in emission control areas (0.10% m/m) under regulation 14.4; or
  • the purchaser's specified limit value, on the basis of the purchaser's notification that the fuel oil is intended to be used:

in combination with an equivalent means of compliance; or is subject to a relevant exemption for a ship to conduct trials for sulphur oxides emission reduction and control technology research.

The 0.10% m/m limit applies in the four established ECAS: the Baltic Sea area; the North Sea area; the North American area (covering designated coastal areas off the United States and Canada); and the United States Caribbean Sea area (around Puerto Rico and the United States Virgin Islands).

In October 2018, IMO’s Marine Environment Protection Committee (MEPC) adopted a further amendment to MARPOL Annex VI, which will prohibit the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship - unless the ship has an equivalent compliance method. This amendment is expected to enter into force on 1 March 2020, and will (among other things) amend the form of the International Air Pollution Prevention Certificate (IAPP Certificate), so that it specifies that, for a ship without an approved equivalent arrangement, the sulphur content of fuel oil carried for use on board the ship shall not exceed 0.50% m/m as documented by bunker delivery note. (See briefing 19/2018).