Bunker delivery note (BDN) amendments enter into force

Jan 11 2019

Amendments to the bunker delivery note (BDN) relating to fuel supply to ships, which have fitted alternative mechanisms to address sulfur emission requirements, entered into force on 1st January, 2019.

The IMO explained that the amendments to Appendix V of MARPOL Annex VI are intended to address situations where the fuel oil supplied does not meet low sulfur requirements, but has been supplied to a ship using an alternative compliance method permitted under regulation 4 of MARPOL Annex VI.

This may be abatement technology, such as an exhaust gas cleaning system (scrubber), if accepted by the ship’s flag state as an alternative means to meet the sulfur limit requirement.

The BDN shall include a declaration signed and certified by the fuel oil supplier's representative that the fuel conforms with regulation 18.3 of MARPOL Annex VI and that the sulfur content of the fuel oil supplied does not exceed:

•  The limit outside ECAS (currently 3.5%, falling to 0.5% from 1st January, 2020) under regulation 14.1.

•  The limit in emission control areas (0.1% m/m) under regulation 14.4. 

•  The purchaser's specified limit value, on the basis of the purchaser's notification that the fuel oil is intended to be used in combination with an equivalent means of compliance, or is subject to a relevant exemption for a ship to conduct trials for SOx emission reduction and control technology research.

In October, 2018, IMO’s MEPC adopted a further amendment to MARPOL Annex VI to prohibit the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship - unless it has an equivalent compliance method.

This amendment is expected to enter into force on 1st March, 2020, and will (among other things) amend the International Air Pollution Prevention Certificate (IAPP Certificate), so that it specifies that, for a ship without an approved equivalent arrangement, the sulfur content of fuel oil carried for use on board the ship shall not exceed 0.5% m/m as documented by the BDN.

Also on 1st January, 2019, amendments to MARPOL Annex VI to designate the North Sea and the Baltic Sea as ECAs for nitrogen oxides (NOx) entered into force.

Both ECAs will take effect on 1st January, 2021, and will result in considerably lower emissions of NOx from international shipping in those sea areas, the IMO said.

In NOx ECAs, ships are subject to ‘Tier III’ controls to limit NOx emissions.

From 1st January this year, ships of 5,000 gt and above had to start collecting data on their fuel consumption, under the mandatory data collection reporting requirements, which entered into force in March, 2018.

The aggregated data is reported to the flag state for each calendar year and the flag state, having determined that the data has been reported in accordance with the requirements, will issue a Statement of Compliance to the ship. 

Flag states are also required to subsequently transfer this data to an IMO Ship Fuel Oil Consumption Database. IMO is required to produce an annual report to the MEPC, summarising the data collected.


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