Bunkering marine fuel oil in ports in the Netherlands

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Responsibilities during bunkering

The ship’s engineer, ship master and shipowner or charterer must see to it that the supplier and bunker operator follow the legally outlined bunkering and sampling procedure.

The Human Environment and Transport Inspectorate (ILT) monitors compliance with these rules in the Netherlands and ensures that fuel oil supply corresponds with the bunker delivery note (BDN), based on Article 3.3 of the Besluit brandstoffen luchtverontreiniging (Fuels Air Pollution Decree, in Dutch).

Fuel oil delivery agreement

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

Requirements for marine fuel oil

Fuel oil 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).

Safety Data Sheet (SDS)

Before bunkering, the supplier’s representative provides the person responsible on the seagoing vessel with a veiligheidsinformatieblad, VIB (Safety Data Sheet, SDS) for each type of fuel oil in the delivery. This enables the responsible person to assess the safety risks and establish the necessary procedures.

Bunkering and sampling procedure

Representatives of both the receiving 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 sign to confirm their agreement. Only the chief engineer or the ship master are entitled to sign the samples and the BDN on behalf of the receiving vessel.

BDN and sub-sample retention

The vessel must keep on board:

• The BDN for at least 36 months after supply.
• The sub-sample or sub-samples designated to it for at least 12 months after supply, or longer if the fuel oil remains on board. The requirements for keeping samples are set out in MARPOL VI/18.8.1.
• The SDS for as long as the fuel oil remains on board.

Letter of Protest in case of deviations or irregularities

If the fuel oil 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 (LoP) as described in Procedures for Port State Control 2021, Guidelines under MARPOL VI/2.15.

The ship master must send the LoP to the supplier’s representative, who must countersign to confirm receipt. The ship master must send copies of the countersigned LoP to:

• The ship’s flag state administration.
• The ILT as the port state authority, as an attachment by emailing brandstoffen-luchtkwaliteit@ilent.nl.
• The port authority overseeing bunkering.

The vessel must keep a copy of the LoP 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.