Bunker Delivery Notes

Bunker Delivery Notes


The Marine Environment Protection Committee, at its eightieth session (3 to 7 July 2023), approved unified interpretations to regulations 18.5 and 18.6 of MARPOL Annex VI, concerning electronic bunker delivery notes. It is now included in the updated consolidation circular MEPC.1/Circ.795/Rev.8.


The regulation numbers in the unified interpretations refer to the 2021 Revised MARPOL Annex VI, as adopted by resolution MEPC.328(76), which entered into force on 1 November 2022, as amended by resolutions MEPC.361(79) and MEPC.362(79) which will enter into force on 1 May 2024.



Unified Interpretations to MARPOL Annex VI Regulation 18

Fuel oil availability and quality


Regulation 18.5 reads as follows:

“For each ship subject to regulations 5 and 6 of this Annex, details of fuel oil for combustion purposes delivered to and used on board shall be recorded by means of a bunker delivery note that shall contain at least the information specified in appendix V to this Annex.”


Regulation 18.6 reads as follows:

“The bunker delivery note shall be kept on board the ship in such a place as to be readily available for inspection at all reasonable times. It shall be retained for a period of three years after the fuel oil has been delivered on board.”



  1. For the application of these regulations, they should be interpreted as being applicable to all ships of 400 gross tonnage or above and, at the Administration’s discretion, to ships of less than 400 gross tonnage.
  2. The Bunker Delivery Note (BDN) required by regulation 18.5 is acceptable in either hard copy or electronic format provided it contains at least the information specified in appendix V to MARPOL Annex VI and is retained and made available on board in accordance with regulation 18.6. In addition, an electronic BDN should be protected from edits, modifications or revisions and authentication be possible by a verification method such as a tracking number, watermark, date and time stamp, QR code, GPS coordinates or other verification methods.


Appendix V

Information to be included in the bunker delivery note (Regulation 18.5)

  • Name and IMO Number of receiving ship Port.
  • Date of commencement of delivery
  • Name, address and telephone number of marine fuel oil supplier.
  • Product name(s)
  • Quantity in metric tonnes
  • Density at 15°C, kg/m3
  • Sulphur content (% m/m)
  • 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 Annex VI and that the Sulphur content of the fuel oil supplied does not exceed the limits specified in Annex VI.


  • Appendix V on the information to be included in the BDN from 1 May 2024, below Sulphur content (% m/m). Existing item 9 is renumbered.
  • Refer to the MEPC.362(79): “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 “ with a reference note “ *ISO 2719:2016, Determination of flash point – Pensky-Martens closed cup method, Procedure A (for Distillate Fuels) or Procedure B (for Residual Fuels).”



  • Certain ports are looking to implement electronic BDNs as part of a wider move towards digitalization, including documentation related to bunkering operations. Ship officers should be aware of these changes such as the method to digitally transfer an electronic BDN from the bunker barge to the receiving ship and the subsequent means to securely retain that electronic record onboard for not less than the required time period.


Source IMO


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