De-bunkering non-compliant fuel

De-bunkering is the removal of fuel oil from a ship after delivery, usually because it does not comply with the MARPOL Annex VI sulphur limit or is off-specification. MEPC.1/Circ.881 of 21 May 2019 lists it among the contingency measures a port State may accept for non-compliant fuel, alongside retention on board and other methods acceptable to the port State.

The full article will cover the Circ.881 options, discharge to another ship as cargo or to a shore facility, flushing and dilution after discharge, and the role of the FONAR in the port State’s decision. It will cover how charter clauses allocate the cost, including the BIMCO Bunker Quality and Liability Clause 2011 and the BIMCO 2020 Fuel Transition Clause.

It links to FONAR and BDN sulphur compliance evidence and off-spec bunkers under a time charter .