Electronic Bunker Delivery Notes (e-BDN) 13.01.2024 12:40The 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.
The updated interpretation relating to regulation 18.5 and 18.6 of MARPOL Annex VI can be read in full below.
An electronic BDN (e-BDN) as supplied should also be protected against any edits/modifications/revisions and a verification method used to make authentication possible.
A e-BDN must equally be retained onboard for a period of not less than three years from the date of delivery and made readily available for inspection as required.
Certain ports are looking to implement e-BDNs as part of a wider move towards digitalisation, including documentation related to bunkering operations. Ship officers should be aware of these changes such as the method to digitally transfer e-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 time period.
MEPC.1/Circ.795/Rev.8 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 by means of 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 a period of three years after the fuel oil has been delivered on board."
Interpretation:
1. For the application of these regulations, they should be interpreted as being applicable 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 in accordance with 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.
