Is blending fuel on board allowed to achieve compliance?

Overview

The fuel oil carriage ban from the International Maritime Organization (IMO) that will come into force on 1 March 2020 has raised questions regarding the possibility of blending fuel on board ships to achieve compliance. The questions have prompted BIMCO to offer its view to members on the regulatory aspects of whether on board blending can be considered compliant.

From 1 March 2020, not only the use of fuel oil with a sulphur content exceeding 0.50% will be prohibited, but even carrying fuel oil intended for use on board that ship, with a sulphur content exceeding 0.50%, will be prohibited, unless the ship is equipped with a certified equivalent such as an exhaust gas cleaning system (scrubber).

Yet, from 1 January 2020 (when the IMO 0.50% sulphur regulation takes effect) some ships may have non-compliant fuel left on board which will then have to be disposed off before 1 March.

This situation has prompted some members to ask whether it will be possible to blend the non-compliant fuel on board in order to achieve compliance and thereby avoid the very costly process of de-bunkering and potential loss of value of the non-compliant fuel oil.

Going forward, ships are also at risk of receiving fuel oil that, in contradiction with what is stated on the Bunker Delivery Note (BDN), turn out to be non-compliant. In such situations, on board blending could in some cases be an advantageous alternative to de-bunkering.

The regulatory barrier hindering on board blending is found in regulation 18.5 and 18.6 of MARPOL Annex VI, since the Bunker Delivery Note (BDN) is the legal proof of the sulphur content of the fuel oil delivered to a ship.

Interpretation of the BIMCO Secretariat

BIMCO members can read the interpretation of the BIMCO Secretariat as well as more details about the regulatory aspects of fuel blending on board on BIMCO’s website.

 

Christian Baekmark Schiolborg
in Copenhagen, DK

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