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Marine fuels quality

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Sulphur in ships fuel

IMO MARPOL Annex VI Reg 14

From the first of January 2015 the maximum allowed sulphur content in fuel used on board ships decreases 10 times from 1.0 to 0.10 % within the Emission Control Area (ECA) in the North of Europe.

The use of approved emission abatement systems is allowed. Also other low sulphur fuels like LNG may be used.

The maximum sulphur content of fuel outside the ECA is 3.50% until the first of January 2020. From that date the maximum sulphur content in fuel used outside the ECA is 0.50%.

EU Directive 1999/32/EC as amended concerning sulphur in fuel

From 1 January 2010, the maximum sulphur content in fuel used on board ships berthed in the EU ports is 0.10% according to the EU sulphur directive. The directive is implemented in the Dutch Prevention of Pollution from ships act.

The following provisions are set out in Article 14 of the associated Regulations.

With effect from 1 January 2010, the following vessels do not use marine fuels with a sulphur content exceeding 0,10 % by mass:

  • ships at berth in Community ports, allowing sufficient time for the crew to complete any necessary fuel-changeover operation as soon as possible after arrival at berth and as late as possible before departure.

The foregoing shall not apply to:

  • whenever, according to published timetables, ships are due to be at berth for less than two hours
  • to ships which switch off all engines and use shore side  electricity while at berth in ports.

Bunker Delivery Note

The Bunker Delivery Note (BDN) is the delivery note for the bunkered fuel. This is required to include data on the fuel delivered.
The following data must appear on the Bunker Delivery Note according to MARPOL Annex VI, Appendix V:

  • Name and IMO number of Receiving Ship
  • Delivery date
  • Location/Port
  • Name, address and telephone number of marine fuel oil supplier
  • Product Name
  • Quantity: Metric Tons
  • Density (15°C, kg/m3)
  • Sulphur content (the sulphur percentage on the Bunker Delivery Note must be stated to two decimal places).

A signed declaration from the fuel supplier stating that the fuel delivered is in accordance with Articles 14.114.4 or 18.3 of Annex VI. Compliance with these Articles will entail the following:

  • The sulphur concentration of the fuel does not exceed 3.50%.
  • The sulphur concentration of fuel for use in an Emission Control Area does not exceed 0.10%.
  • No additives are present.
  • The fuel does not contain inorganic acids.
  • The fuel does not contain additives which might affect the safety of the vessel, which are hazardous to the personnel and/or which would contribute to additional air pollution.

List of fuel suppliers

The establishment of a list of suppliers is an obligation flowing from MARPOL Annex 6, Reg 18.9 and Article 4bis, Section 6 of the Sulphur Directive. This stipulates that a list of fuel suppliers must be maintained. This will be drawn up by the Ministry of Infrastructure and Water Management. Laboratories, controllers and hauliers do not appear on this list.

This list is a means of identifying the supplier involved in the event of any observed breaches. It is not intended to identify 'approved suppliers'. To appear on the list, the fuel deliveries involved must be to sea-going vessels exceeding 400 GT according to MARPOL. If the fuel delivered is not in compliance with Regulation 14 or 18 of Annex 6, the captain must report this to the flag state, who will then notify the port state (and preferably the supplier).

Sampling during bunkering

An IMO Directive (Res. MEPC.182(59)) applies to samples taken during bunkering. Other samples are not valid. The fuel supplier will seal the samples in the presence of a representative of the vessel. This will be invalid if broken.
In any dispute about fuel quality, the samples will be of major importance. The procedure set out in Appendix VI in Annex VI will apply to the handling of these samples and any disputes.

Twelve months of samples to be held on board

According to Annex VI, samples must remain on board for at least twelve months. This may cause problems for certain vessels, for example ferries that bunker frequently. In accordance with Annex VI Reg 18.11, these will be dealt with in another way.

Complaints about bunkering in the Netherlands

According to Annex VI Reg. 18, complaints relating to bunkering should go from the flag state to the relevant port state, so that the latter can take action against the supplier who is in breach. The information may be distributed among the IMO members.

Fuel quality

Fuel with an excessive sulphur content may be blended to reduce the sulphur content. These blends can cause problems, for example as a result of instability.

If the fuel is unusable and the vessel needs to dispose of it, it will be deemed to be waste and must be sent to a waste collector in the port.

Enforcement as of 1st of January 2015

From the 1st of January 2015 during inspections of Port State Control, Flag State Control and special Sulphur inspectors, logbooks and other relevant document concerning the fuel bunkered and used and the change over procedures will be checked. In certain cases samples of fuel may be taken. In the EU agreements are made about the number and the selection of ships to be inspected as well as the number of fuel samples to be taken. Inspection guidelines are available for all member states.

In some ports ships exhaust gas monitoring equipment may be used in order to select ships for inspections. At sea planes may be used in order to detect sulphur in the ships exhaust gasses.

The results of the inspections and the results of the monitoring equipment are collected and made available in the EU by the Thetis-S database system for all sulphur inspections.

If during the inspection it is proven that the ship was not in compliance with the sulphur directive the ship may be detained and/or prosecuted. The prosecution is done by the criminal prosecutor but anyway the economic advantages from using high sulphur fuel will be taken into account and the penalty has to be sufficient in order to prevent repetition of this contravention. The maximum penalty in the Netherlands is at this moment €800.000.

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