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HFW: Timing of contaminated bunkers ‘highly coincidental’

Unnamed sources suggest contaminated bunkers in US Gulf and Singapore derived from same source.
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The following article regarding contaminated marine fuel at Singapore has been written by international law firm HFW and has been shared with Manifold Times:

Bunker Contamination in Singapore – The flow of contaminated bunkers heads East
Following our recent Briefing on bunker contamination in the US Gulf new reports of contaminated bunkers in Singapore have given rise to further concerns, highlighting the potential inadequacy of the conventional testing regime and the need for industry focus on quality controls in the supply chain. It is currently unclear whether the contaminated stems reported in Singapore are linked to those in the US Gulf region.

However, the timing is highly coincidental and some unnamed sources have suggested that the contaminated bunkers in the US Gulf and Singapore derive from the same source.

Bunker contamination in Singapore – what we know so far
At least one report suggests that six samples of marine fuel recently sold in Singapore led to numerous technical problems for vessels. These include severe sludging at centrifuges, clogged pipelines and overwhelmed fuel filters.

The scale of the contamination is still undetermined. However, given Singapore's position as the world's largest bunkering port, this latest round of contamination could have far-reaching implications throughout Southeast Asia. Initial reports suggest that 'Estonian type oil shale' and 'US type fracked shale oil' are at the root of the issue, whilst principle contaminants identified include both styrene and phenol. Styrene is a liquid hydrocarbon used to manufacture polystyrene, a widely used plastic, and phenol, also identified in the list of US Gulf off-spec bunker contaminants, is an organic compound used in the manufacture of a variety of products.

As the scale of the contamination becomes clearer over time, the issues for ship owners, charterers and bunkers suppliers will become increasingly apparent. The legal and practical issues arising will be analogous to those already addressed by us in the wake of the recent US Gulf contamination 1.

Problems and solutions
Like the US Gulf contamination, the off-spec bunkers reported in Singapore were not apparently detected by the ISO 8217 testing requirements. The reoccurring theme that ISO 8217 testing alone is inadequate to detect a host of contaminants raises the question whether it is practical or feasible to overhaul the ISO 8217 to bring about more stringent testing to try and identify harmful compounds before they pass the ship's manifold – prevention will always be the best cure. To underscore this, we are informed by marine surveyors in Singapore that they are now under greater pressure to release testing results more speedily.

In light of the problems it is clear that quality control, and how this will be implemented, must be an industry focus, particularly in the lead up to the 2020 Low Sulphur Regulations coming into force on 1 January 2020. The concern is that the increased blending expected in order to meet low sulphur requirements will greatly increase the potential of importing contaminants potentially harmful to a vessel.

In this regard, the latest sixth edition of ISO 8217 released in May 2017 (i.e. ISO 8217:2017) is set to be updated to deal with the introduction of the 2020 Low Sulphur Regulations 2, but may need further review if the current contamination issues persist.

The drafters of the ISO 8217:2017 clearly recognised the problem of bunker contamination and the challenges faced. This latest version attempts to place greater emphasis at Annex B on the supplier monitoring quality control, requiring that the "refinery, fuel terminal or any other supply facility, including supply barges and truck materials, having in place adequate quality assurance and management of change procedures to ensure that the resultant fuel is compliant with the requirements of Clause 5". (Clause 5 is the clause that provides that the fuel shall be free from harmful material). Annex B also refers to the difficulty of testing the fuel for material that can cause it to be unacceptable, underlining the technical and practical problems arising in the hunt for harmful contaminants.

Subject to expert input, in light of the recent spate of contamination issues, a shorter term solution for concerned parties might involve an annex to bunker supply or time charterparty contracts requiring the testing for specific problematic compounds identified in recent cases, such as phenols.

Given the serious consequences arising from burning off-spec bunkers and the challenges faced under the current testing regime, it is increasingly important for parties to focus their minds on the contractual allocation of responsibility and liability with respect to bunker quality. Clear drafting and allocation of risk is the best way to try and avoid costly litigation.

Finally, greater transparency of the supply chain is a key issue to the longer term strategy for quality control and accountability. We are pleased to note recent reports that trials of blockchain technology are now underway in the marine fuel industry, a potential solution hypothesised in our previous briefing.

We will continue to monitor developments on bunker contamination within affected regions as matters continue to unfold. At this stage, key stakeholders are recommended to exercise caution when purchasing marine fuel in Singapore and the US Gulf Coast region and to seek the necessary assurances.

Should you have any questions, please do not hesitate to contact the authors of this briefing.

Footnotes

  1. http://www.hfw.com/Bunker-contamination-in-the-US-Gulf-Legal-and-practical-implications
  2. A separate briefing considering the practical and legal issues arising from the forthcoming implementation of the 2020 Low Sulphur Regulations will follow. Paul Deanis HFW's representative on BIMCO's subcommittee established for the development of a charterparty clause that will address the 2020 global sulphur limit of no more than 0.50% that will come into force on 1 January 2020. Rory Grout is assisting.

Readers with further questions may contact the authors below:

Paul Dean
Partner, London
T +44 (0)20 7264 8363
E [email protected]

Toby Stephens
Partner, Singapore
T +65 6411 5379
E [email protected]

Wole Olufunwa
Senior Associate, Singapore
T +65 6411 5344
E [email protected]

Rory Grout
Senior Associates, London
T +44 (0)20 7264 8198
E [email protected]

William Pyle
Associate, Singapore
T +65 6411 5323
E [email protected]

Photo credit: HFW
Published: 11 September, 2018
 

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Vessel Arrest

Malaysia: MMEA detains two vessels over suspected illegal ship-to-ship transfer off Johor

Other than the vessels, MMEA also seized a cargo of oil, bringing the total value of the seizure to MYR 260 million (USD 61.9 million).
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3 days ago

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September 3, 2026

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Malaysia: MMEA detains two vessels over suspected illegal ship-to-ship transfer off Johor

The Malaysian Maritime Enforcement Agency (MMEA) detained tugboat and dredger suspected of conducting an unauthorised ship-to-ship (STS) transfer in Malaysian waters.

The two Malaysian-registered vessels were detained at around 3.20am on Wednesday by an MMEA patrol boat after the agency received public information about two suspicious vessels seen operating alongside each other about 1.4 nautical miles northwest of Tanjung Buai.

MMEA Tanjung Sedili Zone Acting Director Maritime Commander Mohd Najib Sam said further inspection found that the tugboat was operated by five crew members, including its skipper, comprising Malaysian and Indonesian nationals aged between 26 and 58.

The dredger was operated by 13 crew members, including its skipper, all Malaysian nationals aged between 22 and 51.

“Further inspection also found a quantity of oil cargo believed to be without any documents relating to ownership and delivery,” Najib said.

Both vessels and the oil cargo have been seized for further investigation. The total value of the seizure, including the two vessels and the oil cargo, is estimated at MYR 260 million (USD 64 million).

The case is being investigated under Section 491B(1)(K) of the Merchant Shipping Ordinance (MSO) 1952 for allegedly conducting ship-to-ship activities without authorisation from the Malaysian Director of Marine.

The vessels are also being investigated under Section 491B(1)(L) of the MSO 1952 for allegedly anchoring without permission, as well as under the Customs Act 1967 in connection with the oil cargo suspected of lacking the required documentation.

 

Photo credit: Malaysian Maritime Enforcement Agency
Published: 3 September, 2026

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Bunker Claim

Rajah & Tann: Bunker disputes are won in the first 48 hours

Partner V Bala says bunker disputes depend heavily on evidence gathered in the first 48 hours, making disciplined preservation, accurate reporting and early expert involvement critical to protecting a claim or defence.
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4 days ago

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September 2, 2026

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Rajah & Tann: Bunker disputes are won in the first 48 hours

V Bala, a partner in Rajah & Tann Singapore’s Shipping & International Trade practice group, has highlighted the critical importance of preserving evidence in the first 48 hours of a bunker incident, outlining best practices for ship managers to protect potential claims and defences:

A vessel somewhere in the Indian Ocean reports abnormal fuel behaviour. Sludge is forming. Filters are clogging. Consumption looks wrong. Within hours, owners, charterers, managers, suppliers and insurers are exchanging messages. Everyone asks the same question: is there a claim? It is reasonable. It is also often premature. The better question is: what evidence will still exist in 48 hours to explain what happened?

For all the technical sophistication around modern bunker disputes, many are decided less by expert reports than by the first two days after trouble appears. The tribunal may sit years later. The factual foundation is usually laid before the vessel reaches its next port.

Bunker claims are commonly treated as technical contests about fuel specifications, ISO standards and competing laboratory results. They are that. But experienced litigators quickly notice a simpler pattern: the strongest cases are rarely built by the cleverest lawyers. They are built by the best recordkeepers.

The Vanishing Evidence Problem 

Unlike a collision, fire or grounding, bad bunkers leave few obvious visual traces. The evidence is scattered across tanks, samples, engine records, maintenance logs, performance data and electronic communications. Much of it can deteriorate, disappear or become contaminated with surprising speed.

A discarded sample cannot be recreated. A cleaned filter may tell a different story from one preserved immediately after failure. Electronic records overwritten in routine operations may never be recovered usefully. Crew change. Memories fade. The difficulty is that bunker incidents rarely feel like casualties when they first arise. They look like operational nuisances.

The Pressure to Move On 

A ship manager’s first duty is to keep the vessel trading. Engineers solve the immediate problem. Technical managers assess options. Owners watch delay. Charterers want assurance. The commercial pressure to restore normality is intense. It is also the moment when evidential mistakes are most easily made.

Fuel is blended before investigations are complete. Samples are mishandled. Machinery is repaired before it is properly photographed. Internal messages fill with theories. By the time experts arrive, the most useful evidence may already have changed.

The Danger of Instant Certainty 

Modern communication has made this harder. A concern raised in the engine room can reach executives across continents within minutes. The advantages are obvious. So are the risks.

The earliest explanations are often the least reliable. When machinery problems arise shortly after bunkering, the fuel is naturally blamed because it is the most visible recent change. Sometimes that is right. Sometimes it is not.

Yet once a theory enters circulation, it acquires momentum. Months later, early WhatsApp messages or emails written under pressure may be attached to witness statements, analysed by experts and scrutinised by lawyers. A passing operational remark can begin to look like a settled conclusion.

The Documentary Ship 

Shipping remains a documentary business. Despite digitalisation, disputes still turn on engine logs, maintenance reports, fuel transfer records, sounding measurements and superintendent correspondence.

What matters is not merely whether those records exist, but what story they tell together. Tribunals value contemporaneous documents because they were created before positions hardened. They are the closest thing to a real-time account.

Ship Managers at the Centre 

Ship managers sit at the centre of the network: owners, financiers, charterers, bunker suppliers, insurers and regulators. In bunker matters, their role now goes beyond technical operation. It includes preserving enough information to understand what happened if the matter becomes a claim.

What the Best Operators Do Differently 

If bunker disputes are won in the first 48 hours, what do the best operators do differently? They treat fuel incidents as evidential events as well as operational ones. While engineers restore function, someone asks: if this becomes a dispute, what will we wish we had preserved today?

They resist instant certainty. Communications distinguish facts from theories. There is a difference between recording that power loss followed consumption from a particular tank and declaring that the supplier delivered bad fuel.

They know samples are useful only if identity, seals, labels and custody can be proved. They keep samples alongside the full operational record: delivery documents, tank soundings, transfer history, engine logs, alarms, purifier settings, maintenance data and ship-to-shore messages.

They preserve physical evidence before routine work alters it. Filters, residues and affected components may contain information that disappears once cleaned or discarded. Photographs should capture the condition found, not just the condition after repair.

Finally, they bring the right expertise to the problem early. They also involve the right people early: surveyors, laboratories, technical experts, insurers and lawyers. A surveyor or technical expert can help identify what should be sampled, photographed, retained and recorded before the evidence changes. Lawyers and insurers can help ensure that notifications are made, communications remain measured and contractual deadlines are not overlooked. The point is not to turn every operational problem into litigation. It is to avoid discovering, months later, that the ingredients of a sound claim or defence were lost during the first voyage after the incident.

The first 48-hour discipline 

PRESERVE Segregate the suspect fuel where practicable. Secure representative samples, seals, labels and a documented chain of custody. Retain affected filters, residues and components before cleaning or disposal.
RECORD Capture tank soundings, transfer history, consumption sequence, engine parameters, alarms, purifier settings, maintenance data and photographs. Preserve original electronic records and contemporaneous logs.
COMMUNICATE Report observed facts, not untested conclusions. Keep a disciplined chronology of what happened, when it happened, who was informed and what action was taken.
NOTIFY Check contractual notice provisions and inform the relevant owner, charterer, supplier, manager, insurer or P&I club promptly. Delay can damage both evidence and rights.
DEPLOY Involve the appropriate surveyor, laboratory, technical expert and legal team before the condition of the evidence changes, not after positions have hardened.

The lesson is simple. In bunker disputes, the law often comes late. The evidence comes early. The party that preserves it calmly, completely and without premature blame gives itself the best chance of winning the argument when the dispute finally arrives.

 

Photo credit: Rajah & Tann Singapore
Published: 2 September, 2026

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Winding up

Singapore: Notices of intended dividend issued for Hua An Shipping and related firms

Creditors will need to produce proofs of debt to liquidators of Hua An Shipping, Hua Guang Shipping, Nan Hai Maritime, Nan Sia Maritime and Nan Zhou Maritime by 11 September.
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Published

6 days ago

on

August 31, 2026

By

RESIZED Drew Beamer

Notices of intended dividend for Hua An Shipping Pte Ltd, Hua Guang Shipping Pte Ltd, Nan Hai Maritime Pte Ltd, Nan Sia Maritime Pte Ltd and Nan Zhou Maritime Pte Ltd were published on the Government Gazette on Friday (28 August). 

The following are the details of the notice of Hua An Shipping Pte. Ltd:

Name of Company : Hua An Shipping Pte. Ltd. (In Creditors’ Voluntary Liquidation)
Unique Entity No. / Registration No. : 200610919Z
Address of Registered Office : c/o Grant Thornton Singapore Private Limited, 8 Marina View, #40-04/05 Asia Square Tower 1, Singapore 018960
Last Day for Receiving Proofs : 11 September 2026 at 5:00 pm by email to [email protected]
Name of Liquidators : Paresh Tribhovan Jotangia and Ho May Kee
Address : c/o Grant Thornton Singapore Private Limited, 8 Marina View, #40-04/05 Asia Square Tower 1, Singapore 018960

Details of the notice of intended dividend for Hua Guang Shipping Pte. Ltd are as follows:

Name of Company : Hua Guang Shipping Pte. Ltd. (In Creditors’ Voluntary Liquidation)
Unique Entity No. / : 200610922R Registration No.
Address of Registered Office : c/o Grant Thornton Singapore Private Limited 8 Marina View #40-04/05 Asia Square Tower 1 Singapore 018960
Last Day for Receiving Proofs : 11 September 2026 at 5:00 pm by email to [email protected]
Name of Liquidators : Paresh Tribhovan Jotangia and Ho May Kee
Address : c/o Grant Thornton Singapore Private Limited 8 Marina View #40-04/05 Asia Square Tower 1 Singapore 018960

Details of the notice of intended dividend for Nan Hai Maritime Pte Ltd are as follows:

Name of Company : Nan Hai Maritime (Pte.) Ltd. (In Creditors’ Voluntary Liquidation)
Unique Entity No. /Registration No. : 200814299M
Address of Registered Office : c/o Grant Thornton Singapore Private Limited 8 Marina View #40-04/05 Asia Square Tower 1 Singapore 018960
Last Day for Receiving Proofs : 11 September 2026 at 5:00 pm by email to [email protected]
Name of Liquidators : Paresh Tribhovan Jotangia and Ho May Kee
Address : c/o Grant Thornton Singapore Private, Limited 8 Marina View #40-04/05 Asia Square Tower 1 Singapore 018960

Details of the notice of intended dividend for Nan Sia Maritime Pte Ltd are as follows:

Name of Company : Nan Sia Maritime (Pte.) Ltd. (In Creditors’ Voluntary Liquidation)
Unique Entity No.  / Registration No.  : 200814320Z
Address of Registered Office : c/o Grant Thornton Singapore Private Limited 8 Marina View #40-04/05 Asia Square Tower 1 Singapore 018960
Last Day for Receiving Proofs : 11 September 2026 at 5:00 pm by email to [email protected]
Name of Liquidators : Paresh Tribhovan Jotangia and Ho May Kee
Address : c/o Grant Thornton Singapore Private Limited 8 Marina View #40-04/05 Asia Square Tower 1 Singapore 018960

Details of the notice of intended dividend for Nan Zhou Maritime Pte Ltd are as follows:

Name of Company : Nan Zhou Maritime (Pte.) Ltd. (In Creditors’ Voluntary Liquidation)
Unique Entity No. / Registration No.: 200814295H
Address of Registered Office : c/o Grant Thornton Singapore Private Limited, 8 Marina View, #40-04/05 Asia Square Tower 1, Singapore 018960
Last Day for Receiving Proofs : 11 September 2026 at 5:00 pm by email to [email protected]
Name of Liquidators : Paresh Tribhovan Jotangia and Ho May Kee
Address : c/o Grant Thornton Singapore Private Limited, 8 Marina View, #40-04/05 Asia Square Tower 1, Singapore 018960

 

Photo credit: Drew Beamer

Published: 31 August, 2026

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