MARPOL Annex VI - Reported Instances of Bunker Supplier Non-Compliance

Members will be aware that if a bunker supplier provides fuel or documentation that does not comply with MARPOL Annex VI requirements or fails to follow the sampling procedures set out in IMO Resolution MEPC.96(47), the receiving vessel should issue a Note of Protest to the supplier and send copies to the local port state authority, the vessel’s flag administration and the company. A copy should also be retained on board.

Under MARPOL Annex VI, Regulation 18.9 there is a requirement for the flag administration to advise IMO of such matters for promulgation to parties to the Convention and IMO members. In response to this obligation IMO has recently published MEPC.1/Circ.851 Implementation and Enforcement of MARPOL Annex VI which contains a summary of the Notes of Protest received by Cyprus and Liberia between 1 July 2014 and 31 December 2014.

Almost all of the reported instances involve fuel which, according to the Bunker Delivery Note, contained a permissible amount of sulphur. However, following independent analysis arranged by the shipowner, a higher level of sulphur was found making the fuel non-compliant.

Members requiring further guidance should contact the Loss Prevention department.