BIMCO comments on the future fuel oil carriage ban that is demanded from the International Maritime Organization and will come into force on March 1, 2020, assisting those interested on the regulatory aspects of whether on board blending can be considered compliant.
Specifically, the fuel oil carriage ban was firstly announced during the MEPC 73 and prohibits the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation onboard – unless the ship has a scrubber fitted.
Accordingly, BIMCO advises that except the already known HSFO ban, it will be prohibited to carry fuel oil intended for use on board that ship, with a sulphur content exceeding 0.50%, unless the ship is equipped with a certified equivalent such as an exhaust gas cleaning system (scrubber).
However, from January 1, 2020, the vessels that will have non-compliant fuel left onboard they should dispose it off before 1 March.
Moreover, ships are also at risk of receiving fuel oil that, on the contrary to what is stated on the Bunker Delivery Note (BDN), turn out to be non-compliant.
In these situations, BIMCO advises that
on board blending could in some cases be an advantageous alternative to de-bunkering.
The regulatory barrier hindering on board blending is found in regulation 18.5 and 18.6 of MARPOL Annex VI, since the Bunker Delivery Note (BDN) is the legal proof of the sulphur content of the fuel oil delivered to a ship.