Bunkering & MARPOL Annex VI
Ship Bunkering Checklist & ECA 0.10% Fuel Changeover Guide
Bunkering is one of the highest-risk routine operations on any merchant ship or superyacht: an overfilled fuel tank, an unclosed scupper plug, a missing continuous-drip manifold sample or a miscalculated ECA fuel changeover can turn into a marine pollution incident, a off-spec engine failure or a Port State Control detention. Under SIRE 2.0 Chapter 6 & 10, RightShip RISQ 3.2, CDI and MARPOL Annex VI Regulations 14 & 18, inspectors examine the full paper trail from pre-bunkering tank plan to BDN and sample locker.
This guide walks through the before, during and after bunkering checklist, MARPOL Annex VI BDN and sample rules, ISO 8217:2024 fuel quality checks, and 0.10% m/m ECA fuel changeover calculations.
Updated · Written by SeaReady in our own words. Not affiliated with OCIMF, RightShip, CDI, any MoU or any administration — always check the current official documents.
1. Pre-bunkering preparation & tank filling plan
At least 24–48 hours before the bunker barge or road tanker arrives, the Chief Engineer and nominated Bunkering Engineer prepare the written Bunkering Plan and have it reviewed and signed by the Master:
- Segregation of new stem from existing ROB: Never load new fuel on top of an existing batch of different grade or viscosity unless compatibility has been verified. Aim to load new stems into empty, stripped storage tanks to prevent asphaltene precipitation and sludge choking purifiers and fuel filters.
- Tank filling limits (maximum 85%–90% working capacity): Calculate the exact starting ROB, planned loading volume, maximum filling rate (m³/h) and final target sounding/ullage for each tank, never exceeding 85%–90% of tank capacity to allow for thermal expansion.
- High-level (95%) and overfill (98%) alarm tests: Test the independent high-level and overfill alarms on every bunker tank to be loaded, together with remote tank-level gauges and local sounding pipes, and record the test date and time in the Engine Room Logbook and pre-bunkering checklist.
- SOPEP pollution prevention on deck: Plug and cement/seal all deck scuppers mechanically; check that bunker manifold drip trays are clean, empty and drained or plugged; position SOPEP lockers, sawdust/absorbent pads, wilden pumps and portable fire extinguishers at the bunker station; and hoist Bravo flag by day / red all-round light by night.
2. During bunkering: sampling, sounding & barge coordination
Before opening the manifold valve, hold a face-to-face pre-transfer conference with the barge master or terminal PIC and complete the Bunker Delivery Safety Checklist:
- Agree pumping rates and emergency stop signals: Agree the initial slow start rate (to verify line integrity and that fuel is entering the correct first tank), the maximum bulk pumping rate, the reduced topping-off rate, the notice time required before stopping, and the direct VHF / verbal emergency shutdown signal.
- Continuous drip sampling at the receiving ship’s manifold (MEPC.182(59)): Under IMO Resolution MEPC.182(59), the official MARPOL representative sample must be drawn continuously throughout the entire bunker delivery at the receiving ship’s inlet bunker manifold using a clean, tamper-evident continuous-drip sampler. Invite the barge representative in writing to witness the gauge readings and manifold drip sampler before and after transfer.
- Frequent tank soundings & line checks: Sound all receiving tanks and check non-receiving tanks at fixed intervals (and continuously when topping off). Never close a receiving tank valve before opening the next tank valve in the sequence to avoid line over-pressurisation and hose rupture.
- LNG, LPG and Methanol bunkering extras: Where bunkering gas or low-flashpoint fuels under the IGF Code, verify Inert/Purge/Cool-down checklists, Emergency Release Coupling (ERC) and Ship-Shore Emergency Shutdown (ESD-1 / ESD-2) optical/electric link tests, water-curtain protection and hazardous-zone control before transfer starts.
3. Post-bunkering: BDN, 12-month sample locker & ISO 8217:2024
After hoses are blown through (taking care not to blow air into a nearly full tank), drained and blanked, verify the delivered quantity and statutory documentation before signing the Bunker Delivery Note (BDN):
- Mandatory MARPOL Annex VI Appendix V BDN entries: Check that the BDN states: name and IMO number of receiving ship; port and date of commencement of delivery; name, address and telephone number of marine fuel oil supplier; product name(s); quantity in metric tonnes; density at 15°C (kg/m³); sulphur content (% m/m); flashpoint (or statement that flashpoint was measured at ≥ 60°C under SOLAS II-2/4.2.1, added by MEPC.362(79)); and the supplier’s signed declaration that the fuel conforms to MARPOL Annex VI Regulations 14 & 18.
- Sample sealing, labelling & 12-month sample locker log: Witness the mixing and pouring of the cubitainer into the sealed sample bottles (MARPOL ship sample, supplier sample, ship’s commercial lab sample such as VPS/Verifuel/viswa, and barge sample). Verify that every tamper-evident seal number is written on the BDN and entered in the ship’s MARPOL Sample Log in a ventilated sample locker for at least 12 months (BDNs retained for 3 years).
- Oil Record Book Part I (Code H): Record the bunkering entry in Oil Record Book Part I under Code H (Bunkering of fuel or bulk lubricating oil) with exact date, place, type/sulphur content of fuel, tonnes added and total quantity in each tank, matching the BDN and Engine Logbook to the decimal place.
- Wait for lab analysis before burning new fuel: Whenever operational ROB allows, keep the newly bunkered stem segregated until the commercial fuel analysis report (against ISO 8217:2024 — checking cat fines `Al+Si ≤ 60 mg/kg`, viscosity, water, CCAI, total sediment, acid number, flashpoint and chemical contaminants) confirms the fuel is safe to burn.
4. Emission Control Areas (ECAs) & 0.10% fuel changeover calculations
Under MARPOL Annex VI Regulation 14.4 & 14.6, ships operating without an approved Exhaust Gas Cleaning System (EGCS / scrubber) must complete the changeover to fuel oil with a sulphur content of ≤ 0.10% m/m before crossing into any SOx Emission Control Area:
| Emission Control Area / Jurisdiction | Sulphur Limit | Regulatory Basis & Operational Rule |
|---|---|---|
| Global Sulphur Cap (outside ECAs) | ≤ 0.50% m/m | MARPOL Annex VI Reg. 14.1 (in force since 1 Jan 2020; carriage ban on >0.50% fuel unless fitted with an approved EGCS / scrubber). |
| North Sea, Baltic Sea, North American & US Caribbean ECAs | ≤ 0.10% m/m | MARPOL Annex VI Reg. 14.4 & Appendix VII — fuel changeover must be completed before crossing the ECA boundary inwards. |
| Mediterranean Sea SOx ECA (Med ECA) | ≤ 0.10% m/m | IMO Res. MEPC.361(79) — mandatory 0.10% m/m sulphur limit in force since 1 May 2025 across the entire Mediterranean Sea. |
| Norwegian Sea & Canadian Arctic ECAs | ≤ 0.10% m/m (from 1 Mar 2027) | IMO Res. MEPC.392(82) — amendments entered into force 1 March 2026; 0.10% m/m fuel sulphur limit takes effect 1 March 2027. |
| EU / UK / Turkey At-Berth & South Korea / China Domestic ECAs | ≤ 0.10% m/m | EU Directive (EU) 2016/802 (at berth >2 hours, changeover as soon as possible after arrival and as late as possible before departure), Korea SECA, and China coastal/inland ECAs. |
- Dilution volume & thermal shock protection: Flushing high-sulphur or VLSFO (`0.50%`) out of the settling tank, service tank, piping, heaters and viscosity regulator down to `≤ 0.10%` typically requires burning several times the total system volume, while controlling fuel temperature change at ≤ 2°C per minute so main-engine fuel pumps and injectors do not seize. Use the SeaReady ECA Changeover Calculator to work out the exact start time before the ECA waypoint.
- Four mandatory logbook data points (MARPOL Annex VI Reg. 14.6): Every ECA entry and exit must record in the Engine Logbook, Deck Logbook and Fuel Oil Changeover Record Book: (1) the volume of low-sulphur fuel oil (`≤ 0.10%`) in each tank; (2) the date and time; (3) the ship’s latitude and longitude when changeover was completed prior to ECA entry (or commenced after ECA exit); and (4) the OOW and Engineer signatures.
Questions seafarers ask
How long must Bunker Delivery Notes (BDNs) and MARPOL fuel samples be kept on board?
Under MARPOL Annex VI Regulation 18.6 and 18.8.1, every Bunker Delivery Note (BDN) must be retained on board for at least 3 years after the fuel oil was delivered. The sealed representative MARPOL sample taken at the receiving ship’s inlet bunker manifold (under IMO Resolution MEPC.182(59)) must be retained under the ship’s control until the fuel oil is substantially consumed, but in any case for not less than 12 months from the time of delivery.
What are the three types of fuel oil samples checked under MARPOL Annex VI?
Under MARPOL Annex VI Regulation 18 and MEPC.1/Circ.864/Rev.1 / MEPC.1/Circ.889: (1) the MARPOL Delivered Sample taken by continuous drip at the receiving manifold during bunkering; (2) the In-Use Sample drawn from the designated sampling point downstream of the fuel service system serving the engines; and (3) the On-Board Sample drawn from fuel oil storage or settling tanks to verify compliance with the 0.50% carriage ban.
What must be recorded in the logbook during an ECA 0.10% fuel changeover?
Under MARPOL Annex VI Regulation 14.6, before entering an Emission Control Area (or after departing one), the ship must follow a written fuel-oil changeover procedure that allows sufficient time for the fuel service system to be fully flushed of all fuel exceeding 0.10% m/m sulphur. The Chief Engineer and OOW must record in the Flag-prescribed logbook (Engine Room Logbook, Deck Logbook and Fuel Changeover Record Book): the volume of low-sulphur fuel oil in each tank, as well as the date, time and geographical position (latitude and longitude) when the fuel-changeover operation was completed prior to entry or commenced after exit.
When should the Chief Engineer issue a Bunkering Letter of Protest (LoP)?
A Letter of Protest should be issued immediately — signed by the barge master or terminal representative and filed with the BDN — whenever there is a quantity shortage exceeding the ship/barge tolerance (after applying ASTM Table 54B temperature and density corrections), suspected air entrainment ("cappuccino effect"), a manifold drip-sampling dispute (barge refusing to witness continuous manifold sampling at the receiving ship’s rail), missing flashpoint/sulphur declarations on the BDN, or delayed barge pumping rates.
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