Regulatory basis
MARPOL Annex VI, Regulation 18 mandates that a Bunker Delivery Note be provided for every bunker supplied to a ship, and that the ship retain it for not less than three years. The retention obligation is on the receiving vessel.
Required contents
Per MARPOL Annex VI, a compliant BDN must contain: name and IMO number of receiving ship; port of delivery; date of commencement of delivery; name, address, and telephone number of fuel oil supplier; product name(s); quantity in metric tonnes; density at 15°C (kg/m³); sulphur content (% m/m); and a declaration signed by the supplier's representative that the fuel oil is in conformity with Regulation 14 (sulphur) and Regulation 18 (fuel oil quality) of MARPOL Annex VI.
Sample retention
A representative sample of the fuel oil delivered must be taken during the bunker transfer, sealed, signed by the supplier's and vessel's representatives, and retained under the ship's control for at least 12 months from the date of delivery. The sample is the primary evidence for any subsequent sulphur or quality dispute.
Practical handling
BDNs are typically received in hardcopy by the receiving engineer or master. Scanned copies should be filed in the vessel's document management system. Originals are retained on board. Many modern bunker suppliers also provide electronic BDNs — these are acceptable if they meet MARPOL content requirements and can be verified.
Common issues
Incorrect vessel IMO number (transcription error); missing or illegible signatures; density at wrong temperature; sulphur content rounded or estimated rather than measured. Any of these can create problems during Port State Control inspection. Verify the BDN contents before the barge leaves.
Port State Control relevance
PSC inspectors frequently request BDNs during inspection as evidence of compliant fuel. A missing, incomplete, or suspicious BDN can escalate an inspection to detention. BDN integrity is a routine PSC checkpoint.
Frequently Asked Questions
Can I accept an electronic BDN?
Yes, if it contains all MARPOL-required information and you can verify authenticity. Retain both the electronic and a printed copy on board.
What if the BDN sulphur content differs from lab test results?
The BDN is based on the supplier's measurement. The lab test of your retained sample is your independent verification. If they disagree materially, formal dispute process begins. The lab test typically carries evidential weight equivalent or superior to the BDN for disputes.
How do I retain BDNs for three years efficiently?
Scan each BDN on receipt, file electronically with clear naming convention (date, port, quantity, grade), and retain paper originals. Your company document management system should include marine document retention.