MARPOL amendments clarify status of “fuel oil”, “gas fuels” and “low-flashpoint fuels”

IMO has approved draft amendments to MARPOL Annex VI to clarify the requirements for different fuel types with regard to sampling and information provided by suppliers.

The key outcome is that it will be made clear that low-flashpoint fuels and those defined as ‘gas fuels’ are not subject to the same requirements for sampling as residual and distillate marine fuel blends.

These changes have been made to reflect the fact that it is unsafe to obtain MARPOL samples – whether it is delivered, in-use or onboard samples – of low-flashpoint fuels (e.g. methanol) and fuels that may be defined as gas, such as ammonia. These fuels are typically very low in sulphur, well below any current MARPOL limits. Hence, MARPOL samples are not really needed, but that is not clear in current regulations.

The amendments that were approved by the 80th session of the Marine Environment Protection Committee (MEPC 80) include an amendment of the definition of fuel oil in Regulation 2 of MARPOL Annex VI to read: “Fuel oil means any fuel delivered to and intended for use on board a ship. ʺ

A new paragraph is added for the definition of gas fuel, aligned with the definition of ‘gas’ in IGF Code. This definition of gas fuel would cover ammonia.

A revision of Paragraph 12 in Regulation 14 makes it clear that the requirements to have sampling points is not required in any oil service system used for a low-flashpoint fuel or a gas.

Furthermore, Regulation 18 is amended to clarify the requirements for what needs to be included in the bunker delivery note when providing gas or low-flashpoint fuels to ships. This includes the density as determined by a test method appropriate to the fuel type together with the associated temperature.

“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,” the draft amendment states.

It is expected that these amendments to MARPOL Annex VI will be adopted at MEPC 81 (April 2024), meaning they could enter into force from September 2025.