Operational Guide · Registers & Logbooks

# 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.

BDN MARPOL Annex VI bunker sample MEPC.385(81)

## 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.

Every BDN must be accompanied by a representative sample of the fuel supplied, the so-called MARPOL sample: a minimum of 400 ml, labelled with the same information as the BDN, kept on board for at least 12 months from delivery or until the fuel is substantially consumed, whichever is earlier. The sample may only be taken and analysed by PSC authorities or the Flag Administration, under the verification procedure of Appendix VI to MARPOL Annex VI.

Since 1 August 2025, further amendments (Resolution MEPC.385(81)) have entered into force concerning fuel sampling, the BDN, relevant engine conversions and the sharing of fuel consumption data, with more granular requirements.

## 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 on sampling, the BDN and data sharing.

## Scope of Application

Every ship subject to MARPOL Annex VI that carries out bunkering operations.

## Procedure / How to Complete It

1. Before bunkering, verify that the supplier is authorised and that the intended BDN will contain all fields required by Regulation 18.
2. Take the representative MARPOL sample (minimum 400 ml) at the time of delivery, per the procedure agreed with the supplier.
3. Label the sample with the required information: sampling location, product name, quantity, density at 15°C, declared sulphur content.
4. File the BDN and the sample in a secure and traceable location on board, keeping the sample for at least 12 months from delivery.
5. 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.

## Real Cases

Cases of fuel off-specification relative to the sulphur content declared in the BDN have, on several occasions reported by the industry, been identified precisely thanks to analysis of the MARPOL sample kept on board — showing how correctly retaining the sample is a concrete protection for the ship in the event of a subsequent dispute.

## 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

## PSC Observations

PSCOs check the presence and completeness of the BDN, the consistency of the declared sulphur content with the operating area, and the availability of the MARPOL sample correctly labelled and retained for the required period.

## 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.

## Checklist

- 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

How long must the Bunker Delivery Note be kept?
For a minimum of 3 years, as required by MARPOL Annex VI Regulation 18.
Who may analyse the MARPOL sample kept on board?
Only Port State Control authorities or the Flag Administration, under the verification procedure set out in Appendix VI to MARPOL Annex VI.
What changes with the MEPC.385(81) amendments in force since 1 August 2025?
They introduce more granular requirements on fuel sampling, the Bunker Delivery Note, relevant engine conversions and the sharing of fuel consumption data under IMO DCS.
🎬 Additional photos, videos and interactive diagrams for this topic will be available in a future version of the platform.

## Related Topics

Fuel Oil Changeover (ECA)MARPOL Annex VI Bunkering Operations (IT)

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