Applicability: shipowners, ship operators and ship managers.
The IMO has adopted amendments to MARPOL Annex VI concerning the requirements for using low-flashpoint fuels or gas fuels. This follows the 81st session of the Marine Environment Protection Committee, which adopted these amendments by Resolution MEPC.385(81). The amendments enter into force on 1 August 2025.
In-use fuel oil sampling points
Further to Class News 02/2022, IMO Resolution MEPC.385(81) includes a minor amendment to exclude ships which use high-flashpoint gas fuels (e.g. ammonia) from the requirement to fit or designate in-use fuel oil sampling points. The amendments also include a small change to the format of the Supplement to the IAPP certificate, which will be rolled out when the ship’s certificate is next reissued after the amendments enter into force.
Fuel Oil Quality
As the sampling point is part of the verification mechanism controlling sulphur content of fuel oils, additional requirements are being introduced for low-flashpoint fuels and gas fuels. Ships subject to the survey and certification requirements of MARPOL Annex VI (ships of 400gt and above, and fixed and floating drilling rig and other platforms), which are receiving and using on board low-flashpoint fuels or gas fuels, will be required to have a Bunker Delivery Note (BDN) issued by the fuel supplier, including the following:
- Name and IMO Number of ship receiving fuel;
- Port where fuel is received;
- Date of delivery of fuel;
- Name, address, and telephone number of fuel supplier;
- Product name(s);
- Quantity of fuel in metric tons;
- Density determined by a method appropriate for the fuel, including the temperature;
- Declaration signed by the supplier that the fuel meets the fuel quality requirements of MARPOL Annex VI Regulation 18; and
- The sulphur content of the fuel specifically for use on board as tested by an appropriate method, or a statement that when tested by an appropriate method the sulphur content is less than 0.001% m/m.
Recommended next steps
Officers onboard ships receiving low-flashpoint fuels and gas fuels should be aware of the need to receive a BDN, including the required information and declaration. Suppliers of such fuels should be equally aware of the need to supply such a BDN.
For further information
For further information or advice, please get in touch with statutorysupport@lr.org.