Clyde & Co: Suppliers Should Prepare for New Regs on Supply of Low Flashpoint Bunkers

Puneet Sareen, Master Mariner, Clyde & Co LLP. Image Credit: Clyde & Co LLP

Puneet Sareen, a Master Mariner with global law firm Clyde & Co LLP, has advised bunker suppliers to begin planning for upcoming changes to the supply of low flashpoint marine fuels.

While the use of marine fuels with a flashpoint below 60˚C is already prohibited under the International Convention for Safety of Life at Sea (SOLAS), there is currently no prohbition on the supply of such bunkers.

Recent amendments to Regulation 4.2.1 of Chapter II-2 of SOLAS have been introduced that, amongst other things, will require bunker suppliers to provide the receiving vessel with a bunker delivery note (BDN) that either states the flashpoint of the bunkers or that the flashpoint has been measured at or above 70˚C.

In instances where bunkers are supplied below a flashpoint of 60˚C relevant state authorities are required to notify the IMO and take “appropriate action” against the bunker supplier.

Exactly what action should be taken is not specified.

The new rules come into effect from January 1, 2026.

"Although some years away, it would be advisable for bunker suppliers and other stakeholders in the bunkering industry to prepare in advance for these amendments, reviewing their practices and ensuring that their bunker delivery notes will fall in line with the new requirements due to take effect in 2026," Screen said in a post today on the company's website.

The International Bunker Industry Association (IBIA) made a number of recommendations as part of the revisions to SOLAS, including a strong recommendation that only values below 70°C needed to be specifically documented.

"A majority of the working group recognised that testing to determine if the fuel has a flashpoint above 70°C is sufficient to guarantee it is above the 60°C minimum," IBIA said at the time.