Pursuant to MEPC. 1 / Circ. 795 / Rev. 8, electronic BDNs are acceptable and should be protected from edits, modifications, or revisions and can be authenticated by a verification method such as a tracking number, watermark, date and time stamp, QR code, GPS coordinates, or other means. A BDN must be retained onboard for at least three years from the date of delivery and made readily available for inspection as required.
BDNs are also critical for emissions reporting, particularly to the IMO Ship Fuel Oil Consumption Database( Regulation 27), as explained further below. Reporting incorrect or inaccurate fuel types and their corresponding Emission Factor can affect a vessel’ s overall Carbon Intensity Indicator calculation. Therefore, shipboard officers and bunker suppliers must ensure accuracy and completeness at the time of each delivery.
Sea, and forthcoming designations in the Norwegian Sea and Canadian Arctic, the industry faces new requirements for fuel quality, emissions reporting, and operational transparency. Amendments to MARPOL Annex VI, including expanded bunker delivery note requirements and enhanced fuel consumption data collection, reflect the IMO’ s drive for greater accountability and innovation within the sector. As these regulations come into force, shipowners, operators, and bunker suppliers must prioritize compliance and adapt to the complexities of the new standards. Proactive engagement with these regulatory changes will not only mitigate the risk of non-compliance but also position maritime stakeholders at the forefront of sustainable shipping practices, supporting both environmental stewardship and long-term industry resilience. p – 2025 BLANK ROME LLP
Collection and Reporting of Ship Fuel Oil Consumption Data
As required by MARPOL Annex VI, Regulation 27, all ships of 5,000 gross tonnage and above have been required to collect fuel oil consumption data since 2018 and to report this data to the IMO starting in 2019. The collection criterion are listed in Appendix IX of MARPOL Annex VI. Notably, MEPC. 385( 81) also adopted amendments to Appendix IX,“ Information to be submitted to the IMO Ship Fuel Oil Consumption Database.” These amendments require vessels, starting on August 1, 2025, to report information beyond the existing requirements, including fuel oil consumption per consumer type( main engines, auxiliary engines, oil-fired boilers, and others), both generally and while not underway. Vessels must also report the total amount of onshore power supplied( in kWh), and, on a voluntary basis, the laden distance traveled. Therefore, shipowners and operators should ensure compliance with the added data collection information.
Conclusion The evolving landscape of maritime emissions regulations underscores the increasing global commitment to reducing the environmental impact of shipping. With the introduction of new ECAs, such as the Mediterranean
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