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Bunker Delivery Notes to include flashpoint details from 1 May 2024

From 1 May 2024, Bunker Delivery Notes (BDNs) must include the tested flashpoint value of the fuel if the flashpoint is below 70°C, respectively a statement indicating that the flashpoint has been measured at or above 70°C. The relevant test method for the flashpoint is ISO 2719:2016, determination of flashpoint – Pensky-Martens closed cup method, Procedure A (for Distillate Fuels) or Procedure B (for Residual Fuels).

This new requirement results from an amendment to MARPOL Annex VI, Appendix V “Information to be included in the bunker delivery note”, which has been approved by the IMO Marine Environment Protection Committee through Resolution MEPC.362(79) (link).

It is the responsibility of the fuel oil suppliers to issue the BDN, which must remain on the vessel for a period of three years after the fuel has been delivered, for inspection purposes, and to provide information on the flashpoint value. For values above 70°C, suppliers may still decide to include the actual flashpoint measurement on the BDN in addition to the adequate statement.

It shall be noted that the flashpoint limit remains unchanged, i.e. no less than 60°C for all oil fuels, unless otherwise specified for emergency generators, where oil fuel with a flashpoint of no less than 43°C may be used (SOLAS Chapter II-2, Regulation 4.2.1).

In cases where the flashpoint information is missing on the BDN, fuel buyers shall notify the supplier and issue a ‘letter of protest’.

Lucy Nusbaumer


Through this Sanctions Desk and thanks to our extensive expertise in shipping, we aim to assist our Clients in complying with the new regulations by providing regular updates and legal analysis on sanctions impacting the shipping industry. Our team is also available to advise maritime operators on the drafting of relevant clauses and to represent them in any disputes regarding sanctions.

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