The new bunker certificate rule does NOT require an additional certificate from the suppliers. The main changes to the BDN are as follows.
Currently, every BDN had wording which mentioned that the fuel will be in compliance to regulation 14.1 or 14.4 and regulation 18.3 of Annex VI of Marpol.
Here is an example.
New BDN’s will need to include the following :
The BDN shall include 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 MARPOL Annex VI and that the sulphur content of the fuel oil supplied does not exceed:
- the limit outside ECAS (currently 3.50%, falling to 0.50% from 1 January 2020) under regulation 14.1;
the limit in emission control areas (0.10% m/m) under regulation 14.4; or
- the purchaser’s specified limit value, on the basis of the purchaser’s notification that the fuel oil is intended to be used:
in combination with an equivalent means of compliance; or
- is subject to a relevant exemption for a ship to conduct trials for sulphur oxides emission reduction and control technology research.
The items highlighted in blue are new. The new rule does not require an additional certificate from the suppliers.
The current process where the suppliers enter the exact sulfur value will continue. The new rule means that suppliers can supply fuel with sulfur higher than 0.5% if the buyer notifies then that they have a scrubber onboard.
This is mainly to protect the supplier from any liability when the carriage ban comes into play in 2020 and ships will not be allowed to carry greater than 0.5% sulfur fuels without a scrubber onboard.
link to an article from IBIA with a summary of the changes: https://ibia.net/new-regulatory-bdn-requirement-from-1-january-2019-what-it-means/
Any further questions or inquiries please comment below or send a mail to firstname.lastname@example.org
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