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MARPOL Annex VI interpretations for electronic Bunker Delivery Notes
  • Post by: SKANReg
  • Date: 30-01-2024

Updated version of unified Interpretations to MARPOL Annex VI relating to electronic Bunker Delivery Notes.

The IMO has formally confirmed the use of Bunker Delivery Notes (BDNs) in electronic format as an acceptable alternative to the conventional hard copy, as long as they conform to the regulations of MARPOL Annex VI.

This follows the 80th session of the Marine Environment Protection Committee, which agreed on an additional unified interpretation of regulations 18.5 and 18.6 of MARPOL Annex VI concerning BDNs. It is now included in the updated consolidation circular MEPC.1/Circ.795/Rev.8.

Bunker Delivery Note (BDN)

The updated interpretation relating to regulations 18.5 and 18.6 can be read in full below. The minimum information to be contained in the BDN remains the same in hard copy or electronic format and is given in Appendix V of MARPOL Annex VI.

An electronic BDN as supplied should also be protected against any edits/modifications/revisions and a verification method used to make authentication possible. See interpretation for Regulation 18 MEPC.1/Circ.795/Rev.8, below. A BDN in electronic format must equally be retained onboard for not less than three years from the date of delivery and made readily available for inspection as required.

Next steps

Certain ports are looking to implement electronic BDNs as part of a wider move towards digitalization, including documentation related to bunkering operations. Ship officers should be aware of these changes such as the method to digitally transfer an electronic BDN from the bunker barge to the receiving ship and the subsequent means to securely retain that electronic record onboard for not less than the required period.


Unified Interpretations to MARPOL Annex VI Regulation 18

Fuel oil availability and quality

Regulation 18.5 reads as follows:

“For each ship subject to regulations 5 and 6 of this Annex, details of fuel oil for combustion purposes delivered to and used on board shall be recorded using a bunker delivery note that shall contain at least the information specified in appendix V to this Annex.”

Regulation 18.6 reads as follows:

“The bunker delivery note shall be kept on board the ship in such a place as to be readily available for inspection at all reasonable times. It shall be retained for three years after the fuel oil has been delivered on board.”


  1. For the application of these regulations, they should be interpreted as applying to all ships of 400 gross tonnage or above and, at the Administration’s discretion, to ships of less than 400 gross tonnage.
  2. The Bunker Delivery Note (BDN) required by regulation 18.5 is acceptable in either hard copy or electronic format provided it contains at least the information specified in Appendix V to MARPOL Annex VI and is retained and made available on board by regulation 18.6. In addition, an
    electronic BDN should be protected from edits, modifications, or revisions and authentication be possible by a verification method such as a tracking number, watermark, date and time stamp, QR code, GPS coordinates, or other verification methods.


Appendix V

Information to be included in the bunker delivery note (Regulation 18.5)

Name and IMO Number of receiving ship Port
Date of commencement of delivery
Name, address, and telephone number of marine fuel oil supplier
Product name(s)
Quantity in metric tonnes
Density at 15°C, kg/m3
Sulphur content (% m/m)
A declaration signed and certified by the fuel oil supplier’s representative that the fuel oil supplied is in
conformity with regulation 18.3 of Annex VI and that the sulphur content of the fuel oil supplied does not
exceed the limits specified in Annex VI.