Bunker Delivery Note and MARPOL Sampling

BDNs and samples: distinguish conventional and gas/low-flashpoint fuels, required data, custody and MARPOL/SOLAS checks.

Operational Explanation

The BDN documents fuel delivered to ships within regulation 18.5 and is retained for at least three years. Fields and sampling depend on fuel type. The note alone does not guarantee future compliance of blended fuel actually in use.

Conventional BDN fields

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.

The basis for items 1–8 is Appendix V of MEPC.328(76), read with the subsequent amendments to items 9–10 cited above.

Delivered, in-use and onboard: three distinct samples

The delivered sample represents the supply; in-use and onboard samples concern fuel in use and intended for use respectively. The competent authority selects the relevant check: the delivered sample is not irrelevant to PSC and the in-use sample is not the only possible evidence.

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.

Sampling points: check the individual ship’s deadline. MEPC.324(75) requires fitted or designated points for fuel in use. For ships built before 1 April 2022, 14.11 sets the deadline at the first 5.1.2 renewal from 1 April 2023; this is not a deadline already passed for every ship in September 2026. Check survey history. Regulation 14.12, amended by MEPC.385(81), excludes gas and low-flashpoint service systems. Authority sampling follows 14.13.

Where 18.8.1 applies, take a representative sample during delivery and prepare the retained sample under MSC-MEPC.2/Circ.18 (at least 600 ml). Its label has its own fields and is not a BDN copy. Keep it under ship control until the fuel is substantially consumed and for at least 12 months after delivery, satisfying both conditions. The competent authority may arrange laboratory analysis for relevant MARPOL and/or SOLAS verification with documented custody, opening and resealing. Use commercial samples for ordinary commercial disputes.

Gas and low-flashpoint fuels

Gas and low-flashpoint fuels follow 18.5.2: Appendix V items 1–6, density determined by the appropriate method with its associated temperature, sulphur determined by an appropriate method or declared below 0.001% m/m with agreement of the supply-port authority, and the supplier representative’s signed/certified declaration of conformity with 18.3. Regulations 18.5.1, 18.8.1 and 18.8.2 do not apply to these fuels: do not order a conventional 600 ml bottle sample for LNG. Other relevant controls and safety procedures remain.

MEPC.362(79) added flashpoint to the conventional BDN from 1 May 2024; MEPC.385(81), from 1 August 2025, addresses the separate gas/low-flashpoint regime.

Since 1 January 2026 SOLAS II-2/4.2.1.6, amended by MSC.520(106), requires the supplier’s signed/certified declaration before bunkering on fuel conformity with 4.2.1 and the flashpoint test method, within its SOLAS scope. It is separate from the subsequent BDN and does not derive from the MARPOL documentary threshold.

Regulatory Reference

Retained-sample label (Circ.18, §8): sampling location and method, delivery start date, bunker tanker/installation name, ship name and IMO number, both representatives’ names and signatures, seal identification and product name. Record the seal on the BDN for cross-reference. Circ.18 §10 specifically concerns SOLAS testing; sulphur verification follows the applicable MARPOL procedure.

Scope of Application

Ships subject to Regulations 5 and 6 of Annex VI when they receive fuel oil: every ship of 400 GT and above, and every fixed or floating drilling rig and other platform irrespective of that tonnage threshold. Regulation 18.5.1, introduced by MEPC.385(81), records delivered fuel by BDN for this complete group. An ordinary 300 GT ship that is not a drilling rig or other platform remains outside Regulation 18.5.1.

Procedure / How to Complete It

1. Confirm Regulation 5/6 applicability, including fixed or floating drilling rigs and other platforms.
2. Before supply establish the conventional or 18.5.2 gas/low-flashpoint regime. Obtain the prior SOLAS declaration where required and verify supplier and expected documents.
3. Assess sulphur against intended use, areas and compliance method: compliant fuel or a regulation 4 approved equivalent for the actual consumers covered. Distinguish fuel for use from cargo carried.
4. Only where the 18.8.1 sample applies: representative collection at the receiving ship’s inlet manifold throughout delivery, using a Circ.18-permitted method and in the presence of supplier and ship representatives. Manual dripping is not the only permitted method.
5. Distinguish primary and retained samples: homogenize the primary sample before filling the clean, dry container, obtain at least 600 ml and fill the container to 90% ±5% of capacity (Circ.18, paragraph 7.3). Seal and label ship/supply identity, location/method/period, both representatives’ names and signatures and seal number.
6. Keep securely outside accommodation, away from heat and sunlight, with traceability. Retain until substantial consumption and at least 12 months; keep the BDN at least three years. Statutory analysis follows the authority/laboratory route with documented custody.

Practical Example

Scenario: LNG receives complete 18.5.2 documentation, not an order for a conventional 600 ml sample. For conventional fuel used with an approved EGCS, compare the BDN with the method and consumers covered, not just the port location. At month thirteen, fuel not substantially consumed still requires retention of the applicable sample.

What Typically Goes Wrong

A BDN declaring conformity and a properly kept sample are evidence, not automatic guarantees of fuel in use. Discrepancies require the relevant verification procedure and safe fuel management.

Common Mistakes Mistake Library

Avoid sampling LNG as conventional fuel, copying the BDN onto the label, making representatives optional, discarding at month twelve without checking consumption, or opening the statutory sample for an ordinary commercial claim.

What the PSCO Checks

A PSCO may check the BDN and sample where required, completeness/custody and compliance against the approved method and actual use. Gas/low-flashpoint fuels require their documentary branch, not the conventional procedure.

Operational Tips

• Prepare separate checks by fuel type.
• Manage both sample-retention conditions, not a single expiry date.
• Link BDN, seal, tank, intended use and approved equivalence where relevant.

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.

• Regulation 5/6 scope checked, including drilling rigs and other platforms
• Fuel regime and correct fields selected
• Prior SOLAS declaration obtained where required
• 18.8.1 sample only where applicable: representatives, homogeneity, container, label and seal
• Safe custody until substantial consumption and at least 12 months
• BDN retained at least three years
• Sulphur assessed against use, area and approved equivalent method

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Last substantive revision of this page: 15 September 2026 · page fingerprint 685403abb337