Learn everything about the Bunker Delivery Note (BDN) under MARPOL Annex VI. This comprehensive guide explains its legal requirements, real-world importance, compliance challenges, and future trends. Perfect for seafarers, students, and maritime professionals.
Why the Bunker Delivery Note Matters
Imagine being the Chief Engineer on board a bulk carrier, receiving fuel at a busy port in Singapore. You check the hose connections, monitor the pumping rates, and confirm fuel tank levels. But the most critical piece of paper in your hand is not the fuel receipt—it’s the Bunker Delivery Note (BDN).
This document is not just paperwork. It is a legal record required under MARPOL Annex VI and serves as evidence that the fuel supplied meets international regulations on sulfur content and other pollutants. Mistakes or negligence here can lead to hefty fines, vessel detentions, and even reputational damage to the shipowner.
With global shipping consuming over 300 million tonnes of fuel oil annually (UNCTAD, 2023), the role of the BDN has never been more vital. It ensures compliance with emission control limits, helps trace fuel quality, and strengthens accountability between suppliers, shipowners, and regulators.
This article dives deep into the BDN—its structure, purpose, legal standing, and real-world implications.
What Is the Bunker Delivery Note?
The Bunker Delivery Note (BDN) is a standardized document issued by the fuel supplier (bunker barge, truck, or shore terminal) to the receiving ship.
It serves as:
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A legal certificate of the fuel’s compliance with MARPOL Annex VI requirements.
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A traceable record of fuel quality and source, kept on board for inspection.
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An evidence document in case of disputes, Port State Control inspections, or pollution investigations.
According to the International Maritime Organization (IMO), every fuel delivery to a ship engaged in international voyages must be accompanied by a BDN, retained on board for at least three years.
Why the Bunker Delivery Note Matters in Modern Maritime Operations
Ensuring MARPOL Annex VI Compliance
MARPOL Annex VI sets strict limits on sulfur oxides (SOx) and nitrogen oxides (NOx) emissions from ships. From 1 January 2020, the global sulfur cap was reduced to 0.50% m/m, while within Emission Control Areas (ECAs), the limit is 0.10% m/m.
The BDN provides documentary proof that the fuel taken on board complies with these limits.
Reducing Risk of Penalties
Authorities such as Paris MoU, US Coast Guard, and AMSA can detain vessels if their BDNs are missing, inaccurate, or fraudulent. Some fines exceed USD 1 million, especially in jurisdictions like the U.S. where environmental enforcement is strict.
Supporting Investigations and Accountability
In the event of disputes—such as contaminated fuel leading to engine damage—the BDN becomes crucial for legal claims and insurance settlements. P&I Clubs often highlight its role as primary evidence.
Key Requirements of the Bunker Delivery Note
According to IMO Resolution MEPC.182(59), a valid BDN must contain the following minimum information:
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Name, IMO number, and port of registry of the receiving ship.
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Name, address, and telephone number of the fuel supplier.
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Product name(s).
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Quantity in metric tonnes.
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Density at 15°C (kg/m³).
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Sulfur content (% m/m).
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Date and place of delivery.
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Supplier’s representative signature.
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A declaration that the fuel complies with Regulation 14 (SOx) and Regulation 18 (fuel oil quality).
Since 2022, amendments also require suppliers to state whether the fuel is biofuel blends or contains other alternative components.
Fuel Oil Sample and BDN – The Critical Link
Alongside the BDN, a MARPOL sample must be taken at the ship’s bunker manifold. This sample is sealed, signed by both parties, and retained on board for at least 12 months.
The BDN and the sample are inseparable:
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BDN = Paper evidence
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Sample = Physical evidence
If discrepancies arise, authorities test the sample against the BDN declaration.
Challenges and Compliance Issues
Fraudulent or Inaccurate BDNs
Cases of suppliers misrepresenting sulfur content are still reported. In 2022, Singapore’s Maritime and Port Authority (MPA) suspended licenses of several bunker suppliers over discrepancies.
Contaminated Fuel Incidents
Even if the BDN states compliance, off-spec fuels can cause catastrophic damage. For instance, the 2018 Houston fuel contamination crisis affected over 100 ships.
Verification and Enforcement Gaps
Port State Control inspectors cannot test every fuel sample instantly. They rely heavily on the BDN’s accuracy, making it both a strength and a vulnerability.
Real-World Examples
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Rotterdam, 2021: Several vessels were detained after BDN inspections revealed sulfur levels above limits.
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Singapore, 2022: Over 200,000 tonnes of contaminated fuel were delivered despite proper BDNs, causing widespread engine failures.
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U.S. Gulf, 2019: A tanker was fined USD 2.5 million for presenting false BDNs during bunkering operations.
These cases highlight the real-world stakes of getting the BDN right.
Digitalisation of the BDN
With IMO’s push for digitalisation, electronic Bunker Delivery Notes (e-BDNs) are gaining traction.
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Advantages: Reduced paperwork, real-time data transfer, improved traceability.
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Platforms: Class societies like DNV and companies like Inmarsat are piloting blockchain-based BDN systems.
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Outlook: By 2030, digital BDNs could become industry standard, integrated with GISIS and port state databases.
Case Study: Port State Control in the Mediterranean
The Paris MoU 2021 Annual Report showed that nearly 3% of ship detentions were linked to fuel issues and Annex VI non-compliance. In the Mediterranean, where Sulfur Emission Control Areas may soon be implemented, reliance on accurate BDNs will increase dramatically.
Ships bunkering in Piraeus, Genoa, or Barcelona already face tighter inspections, with PSC officers requesting not only BDNs but also fuel system logbooks and MARPOL samples.
Future Outlook
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Biofuels and Alternative Fuels: BDNs must evolve to reflect new fuels like methanol, LNG, and ammonia.
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Blockchain Verification: Prevents tampering and fraud.
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Global Standardisation: The IMO and ISO are working toward harmonising BDN formats.
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Integration with Ship Digital Twins: Real-time fuel quality data could sync with operational dashboards.
Frequently Asked Questions (FAQ)
1. How long should a BDN be kept on board?
At least three years, as required by MARPOL Annex VI.
2. Who signs the BDN?
The supplier’s representative signs it, and the ship’s officer acknowledges receipt.
3. Can BDNs be electronic?
Yes, provided they meet IMO requirements and are accepted by the flag and port state.
4. What happens if the BDN is missing?
The vessel may face detention, fines, or delays during PSC inspections.
5. What is the difference between a BDN and a fuel receipt?
The BDN is a legal compliance document, while the receipt is primarily commercial.
6. What if the BDN sulfur value is different from lab test results?
The sealed MARPOL sample is tested; discrepancies can lead to investigations and penalties.
7. Are BDNs required for LNG bunkering?
Yes, but with specific details reflecting LNG quality parameters.
Conclusion
The Bunker Delivery Note is far more than a routine document—it is the cornerstone of compliance under MARPOL Annex VI. For ship operators, engineers, and suppliers, accurate BDNs are a shield against legal, financial, and reputational risks.
As the shipping industry transitions toward greener fuels and digital operations, the BDN will continue to evolve, becoming a bridge between traditional compliance and the digital future of maritime governance.
For maritime students, professionals, and shipowners alike, understanding the BDN is essential—not just to pass inspections, but to build a safer, cleaner, and more transparent industry.
References
Read more here:
Marine Fuel Standards for Ships: The Complete Guide to ISO 8217, ISO 8216, and MARPOL Annex VI ⚓️🧪