Definition of fuel oil and provision of bunker delivery notes for low-flashpoint fuel or gas fuel
IMO resolution MEPC.385(80), effective 1 August 2025, contains a set of amendments to MARPOL Annex VI concerning the definition of “fuel oil” and provision of bunker delivery notes for “low-flashpoint fuel” or “gas fuel”. Members may wish to note the amended definitions and new requirements. The pro-forma BDN for LNG fuel delivered to a ship for use on board that ship as set out in the IGF Code is also provided for reference.
Definitions
“Fuel oil means any fuel delivered to and intended for use on board a ship.ʺ
“Gas fuel means a fuel oil with a vapour pressure exceeding 0.28 MPa absolute at a temperature of 37.8°C.”
Note that resolution MEPC.328(76) amended MARPOL Annex VI sets out that the definition of “low-flashpoint fuel” means gaseous or liquid fuel oil having a flashpoint lower than otherwise permitted under paragraph 2.1.1 of regulation 4 of chapter II-2 of SOLAS 1974 as amended.
Bunker Delivery Notes for low-flashpoint fuel or gas fuel
From 1 August 2025 regulation 18.5.2 of MARPOL Annex VI requires details of low-flashpoint fuel or gas fuel delivered to and used on board a ship to be recorded on a bunker delivery note as follows:
“5.2 For each ship subject to regulations 5 and 6 of this Annex, details of low-flashpoint fuel or gas fuel delivered to and used on board that ship shall be recorded by means of a bunker delivery note that shall include at least the information specified in items 1 to 6 of appendix V to this Annex, the density as determined by a test method appropriate to the fuel type together with the associated temperature and a declaration signed and certified by the fuel oil supplier’s representative that the fuel oil is in conformity with paragraph 3 of this regulation. In addition the sulphur content of a low-flashpoint fuel or a gas fuel delivered to a ship specifically for use on board that ship shall be documented on the bunker delivery note by the supplier in terms of either the actual value as determined by a test method appropriate to the fuel type or, with the agreement of the appropriate authority at the port of supply, a statement that the sulphur content, when tested by such a method, is less than 0.001% m/m.ʺ
Ships delivered gas for use as fuel on board (Non LNG/Gas Carriers)
The IGF Code (resolution MSC.391(95)) reads as follows:
“18.4.1.1 Before any bunkering operation commences, the master of the receiving ship or his representative and the representative of the bunkering source (Persons In Charge, PIC) shall:
.1 agree in writing the transfer procedure, including cooling down and if necessary, gassing up; the maximum transfer rate at all stages and volume to be transferred;
.2 agree in writing action to be taken in an emergency; and
.3 complete and sign the bunker safety check-list.
18.4.1.2 Upon completion of bunkering operations the ship PIC shall receive and sign a Bunker Delivery Note for the fuel delivered, containing at least the information specified in the annex to part C-1, completed and signed by the bunkering source PIC.”
The format of the BDN set out in annex to part C-1 of the IGF Code is attached below.
LNG/Gas Carriers using cargo (boil-off gas) as fuel on board
For LNG/Gas Carriers using cargo (boil-off gas) as fuel, as the gas fuel is not “delivered” to the ship then it could be interpreted that a BDN is not required for the fuel used on board that ship. However, the Administration of the ship should confirm the requirement.
