PHOENIX REGISTER OF SHIPPING
Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels
Action Date: 01 August 2025
The IMO MEPC 81 has adopted amendments to MARPOL Annex VI through Resolution MEPC.385(81), entering into force on 1 August 2025. These amendments address the regulatory treatment of:
low‑flashpoint fuels,
the replacement of steam systems with marine diesel engines, and
improved accessibility and reporting of fuel consumption data under the IMO Data Collection System (IMO DCS).
Early application of the data‑reporting provisions had already been invited since 1 January 2025.
For low‑flashpoint fuels, new definitions have been introduced, including “gas fuel” (aligned with the IGF Code) and “low‑flashpoint fuels.” Requirements for in‑use and on-board sampling points, as well as MARPOL representative samples (Regulations 14.10, 14.11 and 18.8), will not apply to gas and low‑flashpoint fuels.
However, bunker delivery notes (BDN) remain mandatory for these fuels to document key parameters such as sulphur content. The definition of “fuel oil” has also been updated, replacing “for combustion purposes for propulsion” with “for use,” ensuring technology‑neutral application.
The amendments to Regulation 13.2.2 clarify that replacing a steam system (main boiler and steam turbine) with a marine diesel engine constitutes a “major conversion.” This requires the installed engine to comply with the NOx Tier standard in effect at the time of the replacement. Resolution MEPC.386(81) has also adopted revised 2023 Guidelines, providing criteria for approving Tier II engines when Tier III compliance is not feasible, together with a reporting template for Administrations.
Regarding fuel consumption reporting, the amendments to Regulation 27 and Appendix IX add new data fields, including transport work, and require a higher level of detail in reporting. Under strict confidentiality, IMO DCS data may now be shared for research and analysis, and companies may request the publication of their ships’ fuel consumption data in non‑anonymized form.
These changes require ship-owners and operators to review fuel management procedures, update bunker delivery note processes, plan engine replacements in accordance with the revised standards, and prepare for the new data reporting and transparency requirements.
For any questions, please do not hesitate to contact us at technical@phrs.gr .
