Bunkering marine fuel in ports in the Netherlands

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The Human Environment and Transport Inspectorate (ILT) monitors compliance with these rules in the Netherlands and ensures that fuel delivery corresponds with the bunker delivery note, based on Article 3.3 of the Besluit brandstoffen luchtverontreiniging (fuels air pollution decree, in Dutch).

Fuel delivery agreement

The fuel delivery agreement must clearly specify the quantity and quality of the fuel to be supplied. Preferably, it should also include conditions for returning the fuel if the recipient does not accept the delivery.

Requirements for marine fuel

Fuel used by a seagoing vessel for propulsion must comply with the International Convention for the Prevention of Pollution from Ships (MARPOL). The minimum requirements are:

• The regulations of MARPOL Annex VI, Regulation 14 concerning the maximum sulphur content. These requirements vary depending on the navigation area.
• Suitability for the engine and environment in accordance with MARPOL Annex VI, Regulation 18.3 and further arrangements in line with ISO 8217 (1996, 2005, 2012, 2017, 2024).

Fuel sampling during bunkering

A representative sample of the fuel must be taken at the hose connection point on board the receiving vessel during bunkering. This primary sample must be large enough to fill sample containers for all parties involved.

Representatives of both the vessel and the supplier must be present during sampling, as well as a surveyor if one has been appointed by any party.

The sampling and sealing of the sample containers are only valid if all parties give their agreement. The ILT recommends providing space for counterseals on the bunker delivery note.

For fuel sampling during bunkering, the ILT considers International Maritime Organization (IMO) guideline MSC-MEPC.2/Circ.18 binding and authoritative. This guideline replaces the earlier MEPC.182(59).

The vessel must retain the samples on board for at least 12 months after delivery, and longer if the fuel remains on board. The requirements for sample retention are set out in MARPOL Annex VI, Regulation 18.11.

Bunker delivery note (BDN)

During bunkering in a port in the Netherlands, the fuel supplier must draw up a Bunker Delivery Note (BDN). In accordance with MARPOL Annex VI, the BDN must include at least:

• Name and IMO number of the vessel.
• Date of fuel delivery.
• Location (port).
• Name, address and telephone number of the fuel supplier.
• Product name, preferably in accordance with ISO 8217 or ISO 8219-1. The product name determines whether the fuel quality complies with MARPOL Annex VI, Regulation 18.3, as assessed by the ILT.
• Quantity in metric tonnes.
• Density at 15°C (kg/m³).
• Sulphur content in the fuel (percentage by mass, to 2 decimal places).
• Further analytical data from the samples.
• Seal numbers of the required fuel samples.
• A signed declaration confirming that the fuel complies with MARPOL Annex VI, Regulation 14 and Regulation 18.3.

The port authority may impose additional requirements on the BDN, for example in the bunkering permit. The ILT recommends following ISO 13739.

The vessel must retain the BDN on board for at least 36 months after delivery.

Complaints in case of deviations or irregularities

If the fuel supplied in a port in the Netherlands fails to meet the requirements, if the delivery differs from the BDN or if sampling was not carried out correctly, the ship master must report this immediately upon discovery using a Letter of Protest. The ship master must send the Letter of Protest to the supplier, the ship’s flag state and the port state. In the Netherlands, the port state is the ILT. The ship master must send the Letter of Protest as an attachment to the ILT by emailing brandstoffen-luchtkwaliteit@ilent.nl. The vessel must retain a copy of the Letter of Protest together with the BDN on board for at least 36 months.

The flag state informs the IMO. The ILT may take enforcement action against the supplier.