Fuel oil non-availability report (FONAR)

The FONAR under MARPOL Annex VI Regulation 18: what a master must show, what evidence flag and port states expect, and what it does not excuse.

A fuel oil non-availability report (FONAR) is the notification a master submits when a ship has been unable to obtain compliant fuel oil, made under MARPOL Annex VI Regulation 18.2.4 in the standard format of appendix 1 to MEPC.320(74). It is a report to the flag administration and the relevant port state, not an exemption, and treating it as an exemption is the most common and most expensive misunderstanding in low sulphur compliance.

The full article will set out what Regulation 18 requires: the duty on Parties to promote fuel availability, the duty on the ship to take all reasonable steps to obtain compliant fuel, and the notification duty that follows failure. It will cover the evidence a flag or port state expects, including the record of the search for compliant fuel, the suppliers contacted, the voyage plan, and the previous FONARs the ship has made to the same country in the last 12 months. Regulation 18.2.2 states that the ship should not be required to deviate from its intended voyage or delay it unduly to achieve compliance, and the appendix to MEPC.321(74) states that the cost of compliant fuel is not a valid basis for a claim.

The article will then address enforcement. A FONAR does not authorize the ship to burn non-compliant fuel. Note 3.2 of the format allows a Party to require more documentation for insufficiently supported or repeated claims, and the ship may face more extensive inspection in port. It links to FONAR and BDN sulphur compliance evidence , marine gas oil , fuel switching operations and emission control areas .