Bunker Delivery Note and MARPOL Sampling
The BDN is not just a delivery document: together with the MARPOL sample kept on board, it is the documentary proof of fuel compliance for the following 12 months.
Operational Explanation
The Bunker Delivery Note (BDN) is a mandatory document required by MARPOL Annex VI, Regulation 18, for every fuel delivery: it states the ship's name and IMO number, the port, the date, the supplier's name, the product type, the quantity, the density at 15°C and the sulphur content (% m/m). It must be kept on board for a minimum of 3 years.
Appendix V has ten fields, and this page listed eight
Appendix V of Annex VI, referred to by Regulation 18.5, today has ten entries: 1) name and IMO number of the receiving ship; 2) port; 3) date of commencement of delivery; 4) name, address and telephone number of the supplier; 5) product name; 6) quantity in metric tons; 7) density at 15°C (kg/m³); 8) sulphur content (% m/m); 9) the flashpoint; 10) the declaration signed by the supplier's representative.
The flashpoint is the most recent addition, in force since 1 May 2024 under resolution MEPC.362(79), which inserted the new item 9 and renumbered the declaration as item 10. The text asks for “The flashpoint (°C) specified in accordance with standards acceptable to the Organization, or a statement that the flashpoint has been measured at or above 70ºC”.
The supplier's declaration (item 10, in the form introduced by resolution MEPC.286(71)) is not a formality: it is “A declaration signed and certified by the fuel oil supplier's representative that the fuel oil supplied is in conformity with regulation 18.3 of this Annex and that the sulphur content of the fuel oil supplied does not exceed” one of three values, to be ticked — the global limit of Regulation 14.1, the ECA limit of Regulation 14.4, or a purchaser-specified value, the last only where the fuel is intended for use with an equivalent means under Regulation 4 or in a trial exempted under Regulation 3.2. A BDN with no box ticked is an incomplete BDN.
Declared limit: items 1 to 8 we could not transcribe from an IMO PDF — the documents containing Appendix V open but are truncated before the appendices, and the only full transcription we found sits on a regulatory-republishing portal predating May 2024. We therefore give them as an enumeration, not as a citation. Items 9 and 10 are read from the texts of the two amending resolutions.
And the sample the PSCO actually draws is not the BDN one
The delivered sample is the best known, but it is not the one an inspector physically draws during a sulphur verification. There are three samples, on different regimes.
The MARPOL delivered sample is the Regulation 18.8.1 one, sealed at delivery and kept on board. The in-use sample is “a sample of fuel oil in use on a ship”: drawn from the designated sampling point, downstream of the service tank, with guidelines in MEPC.1/Circ.864/Rev.1, the “2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships”. The onboard sample is “a sample of fuel oil intended to be used or carried for use on board that ship”, that is fuel still in the tanks: guidelines in MEPC.1/Circ.889.
The sampling point is an installation obligation, with a deadline already past. Resolution MEPC.324(75), in force since 1 April 2022, added four paragraphs to Regulation 14. 14.10: “For each ship subject to regulations 5 and 6 of this Annex, sampling point(s) shall be fitted or designated for the purpose of taking representative samples of the fuel oil being used on board the ship”. 14.11 gives the deadline for existing ships: “For a ship constructed before 1 April 2022, the sampling point(s) referred to in paragraph 10 shall be fitted or designated not later than the first renewal survey … on or after 1 April 2023”. 14.12 excludes low-flashpoint fuel service systems. 14.13 says the competent authority uses that point to verify compliance, “as expeditiously as possible without causing the ship to be unduly delayed”.
Every BDN must be accompanied by a representative sample of the fuel supplied, the so-called MARPOL sample: a volume of not less than 600 ml (MSC-MEPC.2/Circ.18, which revokes MEPC.182(59); the volume is not set by Regulation 18), labelled with the same information as the BDN, kept on board for at least 12 months from delivery and in any case until the fuel oil is substantially consumed: the twelve months are a floor, not an alternative that expires earlier (Reg. 18.8.1). The sample is drawn during the delivery by the supplier, in the presence of the ship’s representative, and sealed immediately; once sealed it serves the verification of compliance by the competent authority, under the procedure of Appendix VI to MARPOL Annex VI — in practice Port State Control or the flag Administration, which are the typical cases and not a closed list. Commercial disputes are settled with the commercial samples, not the MARPOL one.
What MEPC.385(81) actually did, and what it did not
MEPC.385(81) — subtitled in full “Low-flashpoint fuels and other fuel oil related issues, marine diesel engine replacing steam system, accessibility of data and inclusion of data on transport work and enhanced granularity in the IMO Ship Fuel Consumption Database (IMO DCS)”, in force since 1 August 2025 — amends, in this order, Regulation 2, Regulation 13, Regulation 14, Regulation 18, Regulation 27, Appendix I and Appendix IX, the last of these replaced in its entirety; in Regulation 27 it adds the new paragraphs 27.14 and 27.15 after paragraph 13. On the BDN side, it extends Regulation 18 to gas and low-flashpoint fuels. It adds the new Regulation 18.4 — “This regulation does not apply to coal in its solid form or nuclear fuels. Paragraphs 5.1, 8.1 and 8.2 of this regulation do not apply to a low-flashpoint fuel or a gas fuel” — and splits paragraph 5 into 18.5.1 and 18.5.2, with a reduced BDN content for those fuels: items 1 to 6 of Appendix V, plus density by a test method appropriate to the fuel type, and sulphur content.
The flashpoint in the BDN does not come from here. It comes from MEPC.362(79), in force since 1 May 2024, that is fifteen months earlier. The finding that attributed it to 385(81) is unfounded, and the distinction matters: anyone looking for the flashpoint in the wrong resolution concludes it is not yet mandatory.
And there is a SOLAS thread falling due on 1 January 2026. Resolution MSC.520(106) amends SOLAS Regulation II-2/4.2.1, adding that “ships carrying oil fuel shall prior to bunkering be provided with a declaration signed and certified by the oil fuel supplier's representative, that the oil fuel to be supplied is in conformity with paragraph 2.1 of this regulation, and the test method used for determining the flashpoint”. It is an advance declaration, to be held before bunkering, distinct from the entry that will later appear on the BDN. Two obligations, two moments, two Conventions.
Regulatory Reference
MARPOL Annex VI, Regulation 18 (fuel oil quality and Bunker Delivery Note) and Regulation 14 (SOx and sulphur content); sample verification procedure under Appendix VI; amendments MEPC.385(81), in force since 1 August 2025, amending Regulations 2, 13, 14, 18 and 27, Appendix I and Appendix IX (replaced in its entirety) and, on the BDN side, extending Regulation 18 to gas and low-flashpoint fuels (new Reg. 18.4, 18.5.1 and 18.5.2; 18.5.1 sets the scope by reference to Regulations 5 and 6). The flashpoint in Appendix V is instead res. MEPC.362(79), in force since 1 May 2024. In-use fuel oil sampling: res. MEPC.324(75), Regulations 14.10–14.13, in force since 1 April 2022, with sampling points fitted or designated by the first renewal survey on or after 1 April 2023; guidelines MEPC.1/Circ.864/Rev.1 for the in-use sample and MEPC.1/Circ.889 for the onboard sample. Advance flashpoint declaration: SOLAS II-2/4.2.1 as amended by res. MSC.520(106), in force from 1 January 2026.
Scope of Application
Ships subject to Regulations 5 and 6 of Annex VI — that is, those of 400 GT and above — when they receive fuel oil. The new Regulation 18.5.1, introduced by MEPC.385(81), reads: “For each ship subject to regulations 5 and 6 of this Annex, details of fuel oil delivered to and used on board that ship shall be recorded by means of a bunker delivery note that shall contain at least the information specified in appendix V to this Annex”. A 300 GT ship is subject to Annex VI, but not to Regulation 18.5.1.
Procedure / How to Complete It
- Before bunkering, verify that the supplier is authorised and that the intended BDN will contain all fields required by Regulation 18.
- Take the MARPOL sample at the receiving ship’s inlet bunker manifold, drawn continuously throughout the bunker delivery period, in a volume of not less than 600 ml. The sampling point is what decides a quality dispute: only there does the sample reflect the fuel that entered before mixing with the ROB.
- Seal and label the sample with all the information prescribed by MSC-MEPC.2/Circ.18: identification of the ship and of the delivery, place and method of sampling, the sampling period, the parties' representatives with their signatures, and the seal identification. Do not copy the BDN fields in place of the label: density and sulphur content belong to the delivery note, while the label identifies the sample and documents its custody.
- File the BDN and the sample in a secure and traceable location on board, keeping the sample under the ship's control until the fuel oil is substantially consumed and in any case for not less than 12 months from delivery. Both conditions hold together: twelve months are not enough while the fuel is still on board.
- Keep the BDN for a minimum of 3 years, even after the fuel has been consumed, per the general documentary requirement.
Practical Example
Example check: at the end of bunkering, the Chief Engineer verifies that the BDN correctly states the declared sulphur content, consistent with the operating area (ECA or not), and checks that the MARPOL sample has been correctly taken, sealed and labelled before filing.
What Typically Goes Wrong
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| MARPOL sample not taken, or taken without a traceable procedure | Unable to prove fuel compliance in a subsequent check | Always take the sample under a traceable, documented procedure, with witnesses if possible |
| BDN filed for less than the required 3 years, or lost before expiry | PSC deficiency for missing documentation | Systematically file every BDN for at least 3 years, with a centralised tracking system |
| Sample kept for less than the required 12 months, or consumed/discarded prematurely | Unable to verify in the event of inspection or dispute | Keep the sample for at least 12 months from delivery, even if the fuel has already been consumed |
What the PSCO Checks
Operational Tips
- Always take the MARPOL sample under a traceable procedure, ideally with more than one person present.
- File BDNs and samples with a centralised system that automatically flags retention deadlines.
- Check the consistency between the sulphur content declared in the BDN and the intended operating area, not only at the time of bunkering.
Preparation checklist
Educational checklist. This summary supports learning and preparation only. It does not replace the vessel’s approved procedures, manuals, statutory documents, company SMS, or applicable official requirements. Completing it demonstrates neither compliance nor readiness for an inspection: it shows that a list has been read, not that the ship is in order. Always verify the current documents carried on board.
- BDN complete with all fields required by Regulation 18
- MARPOL sample correctly taken, labelled and sealed
- Sample kept for at least 12 months from delivery
- BDN filed for at least 3 years
- Declared sulphur content checked against the operating area
FAQ
Related Topics
Last substantive revision of this page: 28 August 2026 · page fingerprint ecdee8884991