REPUBLIC OF

THE MARSHALL ISLANDS

MARPOL Annex VI, Chapter 3 –

Requirements for Control of Emissions from Ships

MARITIME ADMINISTRATOR

May/2024 MN 2-013-8
 TABLE OF CONTENTS

PURPOSE .......................................................................................................................................4
APPLICABILITY ..........................................................................................................................4
REQUIREMENTS .........................................................................................................................5
1.0 Chapter 1 – General.......................................................................................................... 5
1.1 Exceptions and Exemptions (Regulation 3) .............................................................5
1.2 Equivalents (Regulation 4) ......................................................................................6
2.0 Chapter 2 – Survey, Certification, and Means of Control ............................................ 6
2.1 Survey and Certification ..........................................................................................6
2.2 Recognized Organizations .......................................................................................7
2.3 Master or Shipowner Responsibilities .....................................................................7
2.4 On-Board Recordkeeping ........................................................................................8
3.0 Chapter 3 - Requirements for Control of Emissions from Ships ................................. 9
3.1 Ozone-Depleting Substances - ODS (Regulation 12) ..............................................9
3.2 Nitrogen Oxide Emissions - NOX (Regulation 13) ..................................................9
3.3 SOX (Regulation 14) ..............................................................................................12
3.4 Volatile Organic Compounds - VOCs (Regulation 15) .........................................13
3.5 Shipboard Incineration (Regulation 16).................................................................14
3.6 Fuel Oil Quality (Regulation 18) ...........................................................................14
3.7 Bunker Delivery Notes and Delivered Fuel Oil Samples (Regulation 18) ............15
3.8 Fuel Oil Availability (Regulation 18) ....................................................................16
Appendix A – Fuel Oil Changeover Plan...................................................................................17
Appendix B – Low Sulphur Fuel Oil Changeover Completion Record ..................................18
Appendix C – Compliant Fuel Oil Non-Availability Report (FONAR) .................................19

i
 REPUBLIC OF Marine Notice
THE MARSHALL ISLANDS
No. 2-013-8
MARITIME ADMINISTRATOR
Rev. May/2024

TO: ALL SHIPOWNERS, OPERATORS, MASTERS AND OFFICERS OF

MERCHANT SHIPS, AND RECOGNIZED ORGANIZATIONS

SUBJECT: MARPOL Annex VI, Chapter 3 – Requirements for Control of Emissions

from Ships

References: (a) MARPOL, International Convention for the Prevention of Pollution from
Ships, Consolidated Edition, 2022
(b) NOX Technical Code 2008 (NTC 2008), Technical Code on Control of
Emission of Nitrogen Oxides from Marine Diesel Engines
(c) IMO Resolution MEPC.307(73), 2018 Guidelines for the discharge of
exhaust gas recirculation (EGR) bleed-off water, adopted 26 October 2018
(d) IMO Resolution MEPC.320(74), 2019 Guidelines for consistent
implementation of the 0.50% sulphur limit under MARPOL Annex VI,
adopted 17 May 2019
(e) IMO Resolution MEPC.340(77), 2021 Guidelines for exhaust gas cleaning
systems, adopted 26 November 2021
(f) IMO Resolution MEPC.361(79) amendments to the annex of the protocol
of 1997 to amend the international convention for the prevention of
pollution from ships, 1973, as modified by the protocol of 1978 relating
thereto (Mediterranean Sea Emission Control Area for Sulphur Oxides and
Particulate Matter), adopted 16 December 2022
(g) IMO Resolution MEPC.362(79), amendments to the annex of the protocol
of 1997 to amend the international convention for the prevention of
pollution from ships, 1973, as modified by the protocol of 1978 relating
thereto; Amendments to MARPOL Annex VI (Regional reception facilities
within Arctic waters, information to be included in the bunker delivery note
(BDN) and information to be submitted to the IMO Ship Fuel Oil
Consumption Database), adopted 16 December 2022
(h) IMO Circular MEPC.1/Circ.795/Rev.8, Unified interpretation of
MARPOL Annex VI, issued 24 July 2023
(i) IMO Circular MEPC.1/Circ.864/Rev.1, 2019 Guidelines for on board
sampling for the verification of the sulphur content of the fuel oil used on
board ships, issued 21 May 2019
(j) IMO Circular MEPC.1/Circ.881, Guidance for Port State Control on
contingency measures for addressing non-compliant fuel oil, issued 21 May
2019

3 of 19

Inquiries concerning the subject of this Marine Notice should be directed to the Republic of the Marshall Islands Maritime Administrator,
11495 Commerce Park Drive, Reston, VA 20191-1506 USA. The most current version of all Republic of the Marshall Islands Marine Notices
may be found at www.register-iri.com .
MI-01, Rev. Apr/2016
 (k) IMO Circular MEPC.1/Circ.883/Rev.1, Guidance on indication of
ongoing compliance in the case of the failure of a single monitoring
instrument, and recommended actions to take if the Exhaust Gas Cleaning
System (EGCS) fails to meet the provisions of the EGCS Guidelines, issued
15 December 2021
(l) IMO Circular MEPC.1/Circ.889, 2020 Guidelines for on board sampling
of fuel oil intended to be used or carried for use on board a ship, issued 7
December 2020
(m) IMO Circular MEPC.1/Circ.892, Guidelines for exemption of unmanned
non-self-propelled (UNSP) barges from the survey and certification
requirements under the MARPOL Convention, issued 9 July 2021
(n) IMO Circular MEPC.1/Circ.895/Rev.1, Unified interpretations to the NOX
Technical Code 2008, as amended, issued 10 June 2022
(o) IMO Circular MEPC.1/Circ.900, 2022 Guidance regarding the delivery of
EGCS residues to port reception facilities, issued 10 June 2022
(p) RMI Marine Notice 2-011-51, International Code of Safety for Ships
Using Gases or Other Low-Flashpoint Fuels (IGF Code)
(q) RMI Marine Guideline 2-13-6, Guidance on the Application of Regulation
13 of MARPOL Annex VI Tier III Requirements to Dual Fuel and Gas-
Fueled Engines
(r) RMI Yacht Technical Circular No. 9, Issuance of IMO Compliant Engine
International Air Pollution Prevention Certificates by Recognized
Organizations Based Upon EIAPP Certificates Issued by United States
Environmental Protection Agency

PURPOSE

This Marine Notice (MN) clarifies the International Convention for the Prevention of Pollution
from Ships (MARPOL) Annex VI, Chapter 3, air emissions requirements for Republic of the
Marshall Islands (RMI)-flagged ships.

This version from the RMI Administrator (the “Administrator”) supersedes Rev. Nov/2023.
Footnote 6 has been amended to reference the latest version of the procedures for port State control,
IMO Resolution A.1185(33), Procedures for Port State Control, 2023.

BACKGROUND

The RMI is signatory to MARPOL Annex VI, which entered into force 19 May 2005. This Annex
sets limits on ship SOX and nitrogen oxide (NOX) emissions. It regulates the deliberate emissions
of ozone-depleting substances (ODS), the emissions of volatile organic compounds (VOCs) from
tankers, and the incineration of certain products on board ships. It also establishes fuel oil quality
standards.

APPLICABILITY

The MARPOL Annex VI, Chapter 3 requirements apply to all RMI-flagged vessels, regardless of
tonnage, except where expressly provided otherwise. This means it applies to vessels of any type

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whatsoever operating in the marine environment, including hydrofoil boats, air-cushion vehicles,
submersibles, floating craft, yachts, and fixed or floating platforms.

All regulations in this MN refer to those in MARPOL Annex VI, unless otherwise specified.

REQUIREMENTS

1.0 Chapter 1 – General

1.1 Exceptions and Exemptions (Regulation 3)

.1 MARPOL Annex VI Regulations do not apply to emissions necessary for

securing the safety of the ship, saving life at sea, or those resulting from
accidents and damage suffered to the ship or its equipment.

.2 Under Regulation 3.2, the Administrator may temporarily exempt ships from
specific provisions of MARPOL Annex VI to conduct trials for:

a. the development of emission reduction and control technologies; and

b. engine design programs.

.3 Section 1.1.2 (above) does not release exempted ships from the requirement
on fuel oil consumption data collection and reporting per Regulation 27.

.4 In accordance with Regulation 3.3.2, express approval by the Administrator

is required to exempt from Regulation 18 hydrocarbons that are produced and
subsequently used on site as fuel. The exemption must be annotated on the
International Air Pollution Prevention (IAPP) certificate1.

.5 Beginning 1 November 2022, unmanned non-self-propelled (UNSP) barges

may be exempt from certain survey and certification requirements depending
on their technical operation. The shipowner or operator must apply to the RO
for the exemption.

a. The exemption certificate may be issued without Administrator

approval, provided that the Recognized Organization (RO) has surveyed
the barge to confirm:

(1) that it meets the definition of a UNSP barge according to

MARPOL Annex VI, Regulation 2.1.32; and

(2) compliance with IMO Circular MEPC.1/Circ.892.

1. This is an RMI national requirement.

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 b. The exemption certificate will cease to be valid if any of the approved
exemption conditions are not met, or any conversion or alteration has
occurred affecting the conditions under which the exemption certificate
is issued.

1.2 Equivalents (Regulation 4)

.1 Requests for equivalencies or alternative arrangements must be submitted to

the Administrator for consideration and formal approval. They must include
a recommendation from the RO confirming that the alternative arrangement
is at least as effective in terms of emissions reductions as required by
MARPOL Annex VI. Send requests to: [email protected].

.2 Exhaust Gas Cleaning Systems

a. Ships that intend to utilize an Exhaust Gas Cleaning Systems (EGCS)

to comply with the SOX emission requirements (Regulation 14) will be
subject to the approval process for an equivalent arrangement.

b. An EGCS installed must be approved in accordance with the IMO

Guidelines for Exhaust Gas Cleaning Systems. Changes affecting the
performance of an EGCS must also be approved2.

.3 Thermal Waste Treatment Devices

a. Ships that intend to utilize a thermal waste treatment device (TWTD)

(Regulation 16) will be subject to the approval process for an equivalent
arrangement.
b. An installed TWTD must be approved in accordance with the IMO
guidelines. Changes affecting the performance of a TWTD must also be
approved3.

2.0 Chapter 2 – Survey, Certification, and Means of Control

2.1 Survey and Certification

.1 Ships of 400 gross tons (GT) and above are subject to surveys as specified in
Regulation 5.1. This includes every fixed and floating drilling rig and other
platform.

.2 As per Regulation 13.1.1, each marine diesel engine with a power output over
130 kilowatt (kW) that is installed (or undergoes major conversion) on a ship,
irrespective of tonnage, must be surveyed and certified in accordance with the
NOX Technical Code 2008 (NTC 2008), as amended.

2. Refer to IMO Resolution MEPC.340(77).

3. Refer to IMO Resolution MEPC.373(80).

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 .3 Ships fitted with selective catalytic reduction or exhaust gas recirculation
(EGR) systems for compliance with the NOX emission requirements
(Regulation 13) are subject to the approval process in accordance with the
NTC 2008, as amended. See IMO Circular MEPC.1/Circ.895/Rev.1 for
relevant unified interpretations.

2.2 Recognized Organizations

The Administrator has delegated, in accordance with IMO requirements, the survey
and certification functions associated with MARPOL Annex VI Chapter 3 to its
ROs who are specifically authorized to:

.1 issue or endorse an IAPP certificate after completion of the relevant surveys

referred to in §2.1.1 above.

.2 issue an Engine International Air Pollution Prevention (EIAPP) certificate,

reflecting that it has been issued on behalf of the RMI:

a. after completion of the relevant surveys referred to in §2.1.2 above; and

b. during change of flag to RMI.4

.3 perform verification of VOC management plans (See §3.4.1b. below).

.4 carry-out approval of shipboard incinerators and TWTDs (See §3.5 below).

.5 review equivalents for compliance with the standards set forth in MARPOL
Annex VI (See §1.2 above).

.6 approve SOX Emissions Compliance Plans and issue a SOX Emission

Compliance Certificate to ships which use an EGCS as an approved
equivalent. IMO Resolution MEPC.340(77) requires the EGCS Technical
Manual (ETM) and Onboard Monitoring Manual to be approved by the RO
on behalf of the Administrator.

.7 issue Exemption Certificates for UNSP Barges.5 See §1.1.4 above.

2.3 Master or Shipowner Responsibilities

.1 Reporting

Whenever an accident occurs or a defect is discovered that affects the

efficiency or completeness of EGCS equipment, the master or shipowner,
must:

4. For yachts see Yacht Technical Circular 9.

5. See IMO Circular FAL.2/Circ.133.

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 a. report this information6 by completing the TEC-02E Form at the earliest
opportunity to the Administrator at: [email protected]; and

b. provide a corrective action plan on actions to be taken to address the

defective equipment.

.2 Discharge and Record Keeping

Ship must follow any local regulations on discharges from open and closed
loop EGCS, EGR systems, or TWTDs in their ports, harbors, estuaries, or
coastal and other territorial waters. Relevant entries must be made in the
EGCS, EGR, or electronic record books as they are subject to inspection by
port State control (PSC). Similarly, TWTD records must be retained on board
in a tamper-proof manner. See further guidance in:

a. IMO Circular MEPC.1/Circ.900 for EGCS;

b. IMO Resolution MEPC.307(73) for EGR; and

c. IMO Resolution MEPC.373(80) for TWTD.

2.4 On-Board Recordkeeping

.1 A MARPOL Annex VI Record Book must be established and maintained on-

board, in the custody of the Chief Engineer, for filing:

a. the Engine Technical Files;

b. the Record Book of Engine Parameters, when the Engine Parametric

Check Method is employed;

c. the Approved Method File, if applicable;

d. Bunker Delivery Notes (BDN); and

e. a tracking and control system for fuel oil samples.

.2 The following may be incorporated into the MARPOL Annex VI Record

Book, provided such entries are maintained separately within independent
sections:

a. Ozone-Depleting Substances (ODS) record book (§3.1.2 below);

b. the record of NOX Tier III engine operational status (§3.2.5 below); and

c. the fuel oil changeover record (§3.3.3 below).

6. For notifications on EGCS malfunctions, see IMO Circular MEPC.1/Circ.883/Rev.1 and IMO Resolution
Α.1185(33), Appendix 18.

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3.0 Chapter 3 - Requirements for Control of Emissions from Ships

3.1 Ozone-Depleting Substances - ODS (Regulation 12)

Deliberate emissions of ozone-depleting substances are prohibited.

.1 Applicability

All ships with installations7 containing ODS must comply with Regulation
12, except for permanently sealed equipment where there are no refrigerant
charging connections or potentially removable components that contain ODS.

.2 ODS Record Book

a. The ODS Record Book is required for the following that have
rechargeable systems containing ozone-depleting substances:

(1) ships of 400 GT and above; and

(2) drill rigs and platforms regardless of tonnage.

b. The ODS Record Book may be incorporated into the MARPOL Annex
VI Record Book. See §2.4.2 above.

3.2 Nitrogen Oxide Emissions - NOX (Regulation 13)

It is prohibited to operate a marine diesel engine8 with a power output of more than
130 kW and which is installed or undergoes a major conversion on or after
1 January 2000, unless it complies with the applicable NOX emission limits and
requirements specified in Regulation 13.

.1 Applicability

Regulation 13 applies to any ship (including yachts and fishing vessels),

irrespective of tonnage.

7. As defined in Regulation 2.1.17.

8. As defined in Regulation 2.1.21.

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 .2 NOX Tier III Emission Control Areas (NECA)

Marine diesel engines installed on a ship must comply, based on the date of
ship construction, with the NOX Tier III emission standards when the ship is
operating in an Emission Control Area (ECA)9.

Engine Compliance Required10 for Ships

NOX Tier III ECA
Constructed on or after
Baltic Sea Area
1 January 2021
North Sea Area

North America
1 January 2016
United States Caribbean Sea

.3 Application to Yachts

a. Under MARPOL Annex VI Regulations 13.5.2.1 and 13.5.2.3, NOX

Tier III requirements do not apply to marine diesel engines installed on
a ship specifically designed, and used solely, for recreational purposes
when:

(1) it is less than 24 meters in length; or

(2) it is over 24 meters in length, less than 500 GT, and was
constructed prior to 1 January 2021.

b. For Regulations 13.5.2.1 and 13.5.2.3, the term “for recreational

purposes” applies to private yachts (PYs), private yachts limited charter
(PYLCs), commercial yachts (CYs), yachts engaged in trade (YETs),
and passenger yachts (PAXYs).

.4 Exemptions

a. Emergency Equipment

Emergency diesel engines and engines installed in lifeboats, devices, or

equipment intended to be used solely for emergencies are exempted
from the Regulation 13 requirements.

b. Dual-Fuel and Tier II Marine Diesel Engines

As of 1 January 2019, ships subject to NOX Tier III requirements that

are fitted with dual-fuel or only Tier II marine diesel engines are
temporarily exempted from complying with NOX Tier III emission

9. Refer to Regulation 13.6. See also IMO Circular MEPC.1/Circ.778/Rev.4 for a comprehensive list of ECAs.
10. Refer to Regulation 13.5.1.2.

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 standards under specific operational circumstances. The exemption is to
allow such ships to be built, converted, repaired, or maintained at
shipyards or repair facilities located within NOX Tier III ECAs.

c. Explicit authorization from the Administrator is not required, provided

the following conditions are met:

(1) the subject marine diesel engines meet the NOX Tier II emission
standards;

(2) the ship is not permitted to load or unload cargo for the duration
of the exemption;

(3) the ship is only permitted to sail directly to or from the shipyard
or other repair facility; and

(4) the ship follows any additional specific routing requirements

specified by the relevant port State(s).

d. For additional guidance, see Marine Guideline 2-13-6.

.5 Recordkeeping

a. Ships whose marine diesel engines are certified to both Tier II and Tier
III or which are certified to Tier II only, must maintain a record of their
marine diesel engine tier and operational (on/off) status upon entry into
and exit from a NOX Tier III ECA, or when their status changes within
such an area, together with the date, time and position of the ship. See
IMO Circular MEPC.1/Circ.795/Rev.8.

b. The recording of the tier and on/off status of marine diesel engines
(MARPOL Annex VI, Regulation 13.5.3) may be incorporated into the
MARPOL Annex VI Record Book. See §2.4.2 above.

.6 Approved Method

Existing marine diesel engines with a power output greater than 5,000 kW
and a per-cylinder displacement at or above 90 liters, installed on a ship
constructed on or after 01 January 1990, but before 01 January 2000, may be
subject to compliance with the NOX emission limits (Tier I) if an approved
method exists for that engine. For information on the availability of such
approved methods refer to the MARPOL Annex VI module (Regulation
13.7.1) of the Global Integrated Shipping Information System (GISIS).11

11. Registration is free and required for new users.

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 3.3 SOX (Regulation 14)

.1 Sulphur Content of Fuel Oil

a. Fuel oil used onboard any ship, irrespective of tonnage, must be

compliant with the applicable sulphur content standards of Regulation
14. The fuel oil supplier is required to provide documentation as
evidence the fuel complies with the required content levels (see §3.7
below).

b. In addition to the current SOx Emission Control Areas (SECAs)

designated under Regulation 14.3, the Mediterranean Sea has been
included as a new SECA with an effective date of 1 May 2025. See IMO
Resolution MEPC.361(79).

.2 Non-Compliant Fuel Oil Carriage Prohibition

a. The carriage of fuel oil for use on board the ship with a sulphur content
exceeding 0.50% m/m is prohibited under Regulation 14.1. This
prohibition does not apply to non-compliant fuel oil carried for use
onboard a ship with an approved EGCS installed as an alternative means
of compliance under Regulation 4.1 (see §1.2 above).

b. Under exceptional circumstances, the Administrator may permit a ship

to carry non-compliant fuel oil, with concurrent approval by the
competent authorities for the port of destination and port of departure,
as relevant. IMO Circular MEPC.1/Circ.881 must be considered. See
§3.8 below on reporting fuel oil non-availability.

.3 Fuel Oil Changeover Procedures and Recordkeeping

a. Ships using separate fuel oils when operating within a SECA12 must
carry a written fuel oil changeover procedure,13 developed specifically
for that ship.

b. A record14 of the changeover operation must be maintained. It must

include the date and time of the operation, position of the ship, and the
low sulphur fuel oil volumes in each tank.

c. The fuel changeover record may be incorporated into the MARPOL

Annex VI Record Book. See §2.4.2 above.

12. Refer to Regulation 14.3.

13. Procedures for changing over from high to low sulphur fuel oil are provided in Appendix A.
14. A sample record is provided in Appendix B.

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 .4 Fuel Oil Samples, Testing, and Verification

If a competent authority requires a sample to be analyzed, it must be done in

accordance with Appendix VI of MARPOL Annex VI. The sample must be
sealed by the representative of the competent authority in the presence of the
ship's representative. The ship must retain a duplicate sample.

a. In-use fuel oil samples must be obtained in accordance with IMO

Circular MEPC.1/Circ.864/Rev.1. The in-use fuel oil sampling point(s)
must be fitted or designated for the purpose of taking these samples15 as
follows:

(1) For existing ships constructed before 1 April 2022, no later than
the first MARPOL Annex VI renewal survey on or after 1 April
2023;

(2) For new ships with the keel laid on or after 1 April 2022, on
delivery.

b. Onboard samples of fuel oil intended to be used or carried for use must
be obtained in accordance with IMO Circular MEPC.1/Circ.889. An
onboard sample may be drawn directly from:

(1) the fuel oil tank; or

(2) the ship’s transfer system.

(3) An alternative sampling approach may be used provided it is

representative of the fuel oil at the location from where it is drawn.

c. MARPOL delivered fuel oil samples must be obtained and analyzed

as provided in §3.7.3 below.

3.4 Volatile Organic Compounds - VOCs (Regulation 15)

.1 Tankers

a. Tankers subject to vapor emissions control must be fitted with a vapor

collection system, approved by an RO on behalf of the Administrator,
within three years after a port/terminal has notified the IMO of its
regulation of tanker VOC emissions. See GISIS module for ports or
terminals where VOCs are controlled.

b. The VOC management plan, required for all tankers carrying crude oil,
must be approved by the Administrator, or an RO on behalf of the
Administrator.

15. Not applicable to low-flashpoint fuel used for combustion purposes for propulsion or onboard operation.

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 .2 Gas Carriers

Gas carriers must comply with the requirements of this section only if their
loading and containment systems allow safe retention of non-methane VOCs
on board, or their safe return ashore.

3.5 Shipboard Incineration (Regulation 16)

.1 Applicability

All ships, irrespective of tonnage, must comply with the regulations on

shipboard incineration under Regulation 16. Special rules on incineration
under domestic law may apply in some ports and may exist in some special
areas. Operation of shipboard incinerators may require permission from
individual coastal or port authorities concerned.

.2 Approvals

An incinerator on a ship constructed on or after 01 January 2000, or installed

on or after 01 January 2000 must be approved by an RO on behalf of the
Administrator, considering the standard specification for shipboard
incinerators. For approval standards refer to Regulations 16.3 and 16.6.1.

.3 Alternative Waste Treatment Devices

The Administrator permits the development, installation, and operation of

alternative TWTDs that meet or exceed the requirements of Regulation 16.
Refer to §1.2 above.

3.6 Fuel Oil Quality (Regulation 18)

.1 Fuel oil delivered to and used onboard any ship must meet the standards of
Regulation 18.3.1 which addresses the composition of hydrocarbons to be
used for combustion purposes. This includes a fuel oil which is a blend of not
more than 30% by volume of biofuel or synthetic fuel16.

.2 Fuel oil for combustion purposes derived from methods other than petroleum
refining must meet the composition standards of Regulation 18.3.2. This
includes a fuel oil which is a blend of more than 30% by volume of biofuel or
synthetic fuel17. Additionally, it must not exceed the sulphur content
requirements (Regulation 14) or cause an engine to exceed the NOX emission
limits (Regulation 13).

16. Refer to IMO Circular MEPC.1/Circ.795/Rev.8. For the purposes of this Regulation:
i. a biofuel is a fuel oil which is derived from biomass and hence includes, but is not limited to, processed used
cooking oils, fatty-acid-methyl-esters (FAME) or fatty-acid-ethyl-esters (FAEE), straight vegetable oils
(SVO), hydrotreated vegetable oils (HVO), glycerol or other biomass to liquid (BTL) type products.
ii. a synthetic fuel is a fuel oil from synthetic or renewable sources similar in composition to petroleum distillate
fuels.
17. Refer to IMO Circular MEPC.1/Circ.795/Rev.8, including for acceptable routes to demonstrate NOX emission
compliance.

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 .3 Flashpoint

a. The minimum flashpoint requirements for marine oil fuel are specified
in the International Convention for the Safety of Life at Sea (SOLAS)
II-2/4.2.1.

b. On or after 1 May 2024 a BDN must contain either the flashpoint

specified in accordance with ISO 2719:2016, or a statement that the
flashpoint has been measured at or above 70ºC (IMO Resolution
MEPC.362(79)).

3.7 Bunker Delivery Notes and Delivered Fuel Oil Samples (Regulation 18)

.1 Applicability

a. For every ship of 400 GT and above, details of fuel delivered for
combustion purposes must be documented by means of a BDN
accompanied by a representative sample of the fuel oil, in accordance
with the requirements as provided under Regulation 18.8.1.

b. The requirements of this section do not apply to gas fuels such as

liquefied natural gas, compressed natural gas, or liquefied petroleum
gas. However, the sulphur content of gas fuels delivered to a ship
specifically for combustion purposes on board that ship must be
documented by the supplier. See MN 2-011-51.

.2 Bunker Delivery Note

The BDN, including electronic versions, must be provided in the format

specified under MARPOL Annex VI, Appendix V. See also IMO Resolution
MEPC.362(79).

.3 MARPOL delivered sample

Representative samples of bunkered fuel oil must be obtained in accordance

with IMO Resolution MEPC.182(59). If a competent authority requires this
sample to be analyzed, then it must be verified in accordance with Part 1 of
Appendix VI of MARPOL Annex VI. A written statement for the request
should be provided to the ship18.

.4 Alternative Manner

For every ship of 400 GT and above, on scheduled services with frequent and
regular port calls which would render compliance with the requirements of
this section impracticable, an alternative documentation and sampling storage

18. See IMO Circular MEPC.1/Circ.884/Rev.1.

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 plan may be approved by the Administrator, after consideration of the
circumstances involved and consultation with the affected States concerned.

.5 Non-Compliance

If a Bunker Delivery Note or representative sample is not provided by the

bunker supplier or fuel oil is found not to be in compliance with that stated
on the Bunker Delivery Note or the flashpoint requirement of SOLAS II-
2/4.2.1, details must be recorded in the ship’s log. The Administrator must be
notified at: [email protected].

3.8 Fuel Oil Availability (Regulation 18)

.1 If a ship, despite all best efforts, is unable to obtain the required fuel oil to
meet the applicable emission requirements, the Administrator must be
promptly notified at: [email protected]. Notification must also be
made to the competent authorities of the port of destination and port of
departure, as relevant.

.2 When a ship has presented evidence of the non-availability of compliant fuel

oil, the Administrator will subsequently notify the IMO in accordance with
Regulation 18.2.5. To do so, the following information must be provided to
the Administrator:

a. a record of actions taken to attempt to achieve compliance;

b. copies of BDNs;

c. post-bunkering laboratory analysis of drip samples taken to determine

the percent concentration of sulphur found within the stemmed fuel oil;
and

d. evidence that the ship attempted to purchase compliant fuel oil in

accordance with its voyage plan and, if it was not made available where
planned, that attempts were made to locate alternative sources for such
fuel oil and that despite best efforts to obtain compliant fuel oil, no such
fuel oil was made available for purchase.

.3 Ships unable to purchase compliant fuel oil must use the standard format for
reporting fuel oil non-availability set out in Appendix C. This is referred to
as Fuel Oil Non-Availability Reporting (FONAR) and is based on IMO
Resolution MEPC.320(74). The Administrator must be notified at:
[email protected].

.4 Providing the information above does not indemnify the ship from PSC action
in the event compliant fuel oil could not be obtained. The relevant authorities
for the port of destination, if Party to MARPOL Annex VI, are to consider all
relevant circumstances in addition to the evidence provided when
determining the appropriate action to take. Therefore, prompt notification is
required when requesting any deviation from the standards in §3.3.

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Republic of the Marshall Islands
 APPENDIX A – FUEL OIL CHANGEOVER PLAN

1.0 Written Procedures

1.1 Written procedures must be developed for timely changing over between separate
fuel oils. They should:

.1 address safety issues, including whether it is appropriate to change to Low

Sulphur Fuel Oil (LSFO) with the engine room unmanned (if applicable);

.2 ensure that adequate quantities of ready-to-use fuel oil for engines and boilers
used for propulsion and generating plant remain continuously available
during any changeover procedures;

.3 confirm with engine and equipment manufacturers that main and auxiliary
engines, and associated fuel treatment equipment are suitable for use of the
intended fuel oil;

.4 implement a procedure on board the ship to check the compatibility of the

different fuels to be used for the changeover dilution process. This may be by
using a compatibility spot test kit onboard or, preferably, by sending samples
of the two fuels to an independent testing service;

.5 seek approval from the vessel’s RO for any proposed changes to piping
systems, drawings, or fuel storage arrangements that are planned to
accommodate the use of LSFO onboard; or

.6 include information on coastal State emission requirements, including any

regional or local mandates.

1.2 Several organizations and ROs have developed fuel oil changeover calculators,
which provide an estimate of the time required to dilute or flush out the fuel oil
service system to meet the applicable ECA limit. It should be noted that these
calculations are an estimate for guidance purposes only and that spot samples to
check actual sulphur content at various stages of the process are recommended to
account for any operations not considered.

Rev. May/2024 17 of 19 MN 2-013-8

Republic of the Marshall Islands

 APPENDIX B – LOW SULPHUR FUEL OIL CHANGEOVER COMPLETION RECORD

Volume of Low Sulphur Fuel Oils in

Ship’s Position
Each Tank Fuel Oil Chief Engineer
Date Time
Consignment Signature
Latitude Longitude Location Quantity

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Republic of the Marshall Islands
APPENDIX C – COMPLIANT FUEL OIL NON-AVAILABILITY REPORT (FONAR)

Notes:

The MI-112, Compliant Fuel Oil Non-Availability Report, must be sent to the Administrator and
to the competent authorities in the relevant port(s) of destination in accordance with Regulation
18.2.4 of MARPOL Annex VI. As provided by IMO Resolution MEPC.320(74):

1.0 The report must be sent as soon as it is determined that the ship/operator will be unable to
procure compliant fuel oil and preferably before the ship leaves the port/terminal where
compliant fuel cannot be obtained. A copy of the FONAR should be kept on board for
inspection for at least 36 months.

2.0 This report should be used to provide evidence if a ship is unable to obtain fuel oil
compliant with the provisions stipulated in Regulations 14.1 or 14.4 of MARPOL Annex
VI.

3.0 Before filing a FONAR, the following should be observed by the ship/operator:

3.1 A fuel oil non-availability report is not an exemption. According to Regulation 18.2
of MARPOL Annex VI, it is the responsibility of the Party of the destination port,
through its competent authority, to scrutinize the information provided and take
action, as appropriate.

3.2 In the case of insufficiently supported or repeated claims of non-availability, the

Party may require additional documentation and substantiation of fuel oil non-
availability claims. The ship/operator may also be subject to more extensive
inspections or examinations while in port.

3.3 Ships/operators are expected to take into account logistical conditions and
terminal/port policies when planning bunkering, including but not limited to having
to change berth or anchor within a port or terminal in order to obtain compliant fuel.

3.4 Ships/operators are expected to prepare as far as reasonably practicable to be able

to operate on compliant fuel oils. This could include, but is not limited to, fuel oils
with different viscosity and different sulphur content not exceeding regulatory
requirements (requiring different lube oils) as well as requiring heating and/or other
treatment on board.

Rev. May/2024 19 of 19 MN 2-013-8

Republic of the Marshall Islands