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BIMCO Bulletin: FONAR, the expensive tool shipowners should avoid

Manager, Maritime Technology & Regulation at BIMCO, explains FONAR is not a ‘get-out-of-jail-free card’.
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7 years ago

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The following article originally entitled ‘FONAR: The expensive tool shipowners should avoid’ first appeared in the September edition of the BIMCO Bulletin here; it has been shared with Manifold Times:

The Fuel Oil Non-availability Report (FONAR) is not a get-out-of-jail-free card. What is meant as a useful last resort for a ship arriving with non-compliant fuel at a port could come with an expensive price tag.

“There is a reason why at least half of the first page in the FONAR template is dedicated to explaining that this is not a get-out-of-jail-free card,” says Manager, Maritime Technology & Regulation at BIMCO, Christian Bækmark Schiolborg.

“The FONAR should be looked at as the last resort if you are in a bad situation. My advice to shipowners is don’t plan on using it,” he says.

Think evidence

If a ship, against all efforts, ends up in a situation where the only solution is to bunker non-compliant fuel, the ship is at the outset non-compliant in accordance with regulation 18.2 of MARPOL Annex VI.

In this situation, the FONAR is a record of actions that ought to be taken by the ship in the attempt to bunker compliant fuel oil and to provide evidence of attempts to purchase compliant fuel oil in accordance with the ship’s voyage plan. It therefore serves to provide mitigating circumstances when the port state authority decides on appropriate control actions.

A ship could be non-compliant – burning fuel with a sulphur content above 0.50% (and from 1 March 2020, even carrying it without a scrubber) – if it found that only high sulphur fuel was available at the port of departure.

Having filled out the FONAR, there is no guarantee that the authorities at the port of arrival will be lenient towards a non-compliant ship. According to regulation 18.10.2 of MARPOL Annex VI, they are actually required to ensure that appropriate actions are taken to bring the non-compliant fuel into compliance.

“There is no certainty when it comes to the FONAR. It is just a template, giving you an indication of what you need to fill out and what information you need to pass on to authorities, showing that you did all you could to be compliant, but in vain,” Schiolborg says.

The FONAR should be sent in advance to the authorities of the port state at which the ship will arrive, with the ship’s flag state authority copied in, as well as the P&I Club and classification society, so that all parties are informed of the situation in advance.

“But the FONAR will not get you out of the situation. It is not enough just to fill it out. You actually need to be able to provide evidence that you have tried to reach out to other bunker suppliers in the port of departure, and that you also looked at the possibility of taking on board a different type of fuel than you had planned, exploring alternatives that may not be ideal, just to be in compliance,” Schiolborg says.

The high cost of debunkering

Schiolborg warns that even when a ship has done all the FONAR paperwork, gathered all the evidence that it has done what it could to be compliant, and notified all parties well in advance that the ship will arrive non-compliant at a port due to circumstances beyond its control, the bill could be massive. Especially for smaller players.

In the end, it is up to the port state, the flag state and the shipowner to work together to find a solution at arrival, and when the FONAR is used it will be resolved on a case-by-case basis. It will be a question of whether the shipowner has really done everything in his or her power to try to obtain compliant fuel. And whether he or she can prove it.

The reason that the bill could still be huge – and in some cases exceed any possible fine that will be the result of arriving non-compliant – is that the ship will likely have tonnes of non-compliant fuel oil on board and may be required to get rid of it before departure.

“The cost of debunkering may be very high, and could be a lot higher than a fine. Being detained and asked to debunker the non-compliant fuel could have a severe impact,” Schiolborg says, adding: “Sulphur is also in the sediments and therefore the fuel tanks could need to be cleaned. It is a huge operation that could take days. If you are off hire, you are not earning money. In addition, the fuel you debunker may suddenly not be regarded as fuel, and you may not get the market value for it. It may be debunkered as waste oil and need to go to a shoreside reception facility. We are talking tonnes here, and that means very large sums of money to absorb.”

There have been a few cases where the size of fines issued by authorities in cases of non-compliance are publicly known. The highest such recorded fines were in Europe, in Emission Control Areas (ECA), and have been in the range of €50,000 to €100,000.

According to Schiolborg, any shipowner can find him or herself in the unwanted situation of not being compliant, despite all good intentions. In that case, the advice is clear.

“Get statements, get proof and submit it to all entities: the port state; the flag state; classification society; and P&I Club. And do it in a timely manner, even before you leave the port. That will likely put you in a better position, and it allows the authorities time to discuss the situation and not take rushed decisions,” he says.

“If you are not prepared in advance, and using a FONAR without evidence, you will find yourself in a very bad situation.”

What is FONAR?
A Fuel Oil Non-availability Report (FONAR) is necessary if a ship, despite best efforts, was unable to obtain compliant fuel. In such a scenario, the ship’s Flag State and the competent authority of the port of destination should be notified with a FONAR.

A completed FONAR should not be expected to result in an exemption from compliance with the global sulphur limit, but it may serve as evidence when the port state authority assesses whether the unavailability of compliant fuel is a sufficient reason for a ship not having compliant fuel.

The FONAR is a record of actions taken by the ship in her attempts to bunker compliant fuel oil and provides evidence of attempts to purchase compliant fuel oil in accordance with her voyage plan. Interpretation, as well as action by the authorities, will be up to individual countries.

Published: 30 September, 2019
 

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Ammonia

AM Green plans to build green ammonia plant at Indian port

Initiative also includes development of green ammonia handling, storage and bunkering infrastructure, pilot bunkering operations, safety procedures and training programmes, says VOC Port Authority.

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20 hours ago

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June 3, 2026

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VO Chidambaranar (VOC) Port Authority on Friday (29 May) said it has signed a Memorandum of Understanding (MoU) with India’s ammonia producer AM Green Ammonia to collaborate in the development of a green ammonia production plant.

The plant will have a capacity of one million tonnes per annum (MTPA) at Tuticorin.

The initiative also includes development of green ammonia handling, storage and bunkering infrastructure, pilot bunkering operations, safety procedures and training programmes. 

The project is expected to support the development of green fuel corridors connecting VOC Port with major ports in Europe and Asia, thereby strengthening India’s position in the global green fuels value chain.

VOC Port also signed a Memorandum of Understanding (MoU) with Bureau Veritas (India) Pvt. Ltd., to collaborate on Green Port certification, emissions accounting, ESG reporting, safety validation, development of green bunkering practices, and establishment of a Centre of Excellence for green fuels and sustainability.

The port also plans for an upcoming 750 m³ green methanol bunkering facility.

 

Photo credit: Naveed Ahmed on Unsplash
Published: 3 June, 2026

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Port & Regulatory

Study: Major drop in ship sulphur emissions confirmed following IMO regulations

National Centre for Atmospheric Science study found that the average sulphur content in ship fuel dropped nearly tenfold in open ocean areas following IMO’s 2020 regulation.
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6 months ago

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December 8, 2025

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Recent global regulations have significantly reduced sulphur emissions from ships, helping to improve air quality in coastal regions – confirmed by a recent international study led by researchers at the National Centre for Atmospheric Science. 

The research, published in Environmental Science: Atmospheres, used aircraft and ground-based instruments to measure sulphur dioxide and nitrogen oxides emitted by ships in the North-East Atlantic and European coastal waters between 2019 and 2023.

The team found that the average sulphur content in ship fuel dropped nearly tenfold in open ocean areas following the International Maritime Organization’s 2020 regulation, which capped sulphur content in marine fuel at 0.5%. 

Before the change, many ships exceeded the previous 3.5% limit. After 2020, only a small number of ships were found to breach the new standard.

In European sulphur Emission Control Areas (SECAs), such as the English Channel and the Port of Tyne, sulphur levels were even lower – well below the stricter 0.1% limit. Interestingly, ports outside these zones, like Valencia in Spain, also showed low sulphur levels, likely due to EU rules requiring cleaner fuel when ships are docked for extended periods.

This is the first study to use aircraft-based measurements and predictions from the Ship Traffic Emission Assessment Model (STEAM3) to assess ship emissions outside of sulphur control zones since the 2020 regulation came into effect. The findings support the widely held view that ships now emit around seven times less sulphur than before the rule change – an important step toward cleaner air and healthier coastal environments.

Note: The research, titled ‘SO2 and NOx emissions from ships in North-East Atlantic waters: in situ measurements and comparison with an emission model’ can be found here. 

 

Photo credit: shraga kopstein on Unsplash
Published: 8 December, 2025

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Interview

IBIA Annual Convention 2025: ‘Exciting times’ for post IMO 2020 bunker suppliers, states Equatorial

Choong Sheen Mao, Chief Operating Officer, Equatorial, describes to Manifold Times the pre/post IMO 2020 challenges and evolution of bunker suppliers.
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7 months ago

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October 31, 2025

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Sheen Mao MT

The International Bunkering Industry Association (IBIA) will be hosting its flagship Annual Convention in Hong Kong at the Hong Kong Convention Exhibition & Convention Centre between 18 to 20 November 2025, as part of Hong Kong Maritime Week.

Choong Sheen Mao, Chief Operating Officer, Equatorial Marine Fuel Management Services (Equatorial), speaks to bunkering publication Manifold Times about the challenges of a post IMO 2020 bunker supplier.

MT: How does Equatorial continue to offer customer assurance and maintenance of marine fuel quality to ISO8217 standards despite increasing complexity of bunker fuel blends?

We maintain our focus to provide compliant, quality and competitively priced products to our customers. There is no shortcut. We source our products from a wide range of cargo producers and suppliers. We continue to be strict and vigilant with our testing programme for our products before delivering them to our customers. Equatorial has deepened our engagement with the wider industry to have a better and up-to-date understanding of the existing and new marine fuels.

MT: Can you share the evolution of commercial marine fuel procurement, blending and trading strategies on the back of increasing fuel types (pre/post IMO 2020)?

Pre IMO 2020, the main types of marine fuel procured and consumed by vessels were high-sulphur fuel oil, marine diesel oil and marine gas oil. Trading strategies were therefore closely linked to that within the oil industry.

However, many of the new fuel types are from other industries. For example, biofuels, methanol and ammonia are mainly products from the chemical and agriculture industries. There are marked differences between these industries and the energy industry (in particular, the marine fuels industry). LNG is from the gas industry which is distinct from the oil industry.

Without an existing liquid paper market for many of these commodities (especially as a marine fuel), the price risk management is less straightforward. Furthermore, commodity prices are no longer the sole consideration for price itself. The price of compliance must be considered. This could range from guaranteeing the origin of the marine fuel, its sulphur properties as well as its carbon intensity. The list goes on.

MT: Operational wise, what are the changing role and responsibilities of a bunker supplier to date, compared to before IMO 2020?

The role and responsibility of a bunker supplier have evolved. Fundamentally, it has been about providing quality marine fuels at competitive prices. Quantity assurance has been a critical concern which led to the mandatory implementation of the mass flow meter system for bunkering in the Port of Singapore. Interestingly, due to the nature of credit terms in the bunker industry, bunker suppliers also performed the role of “bankers” by extending favourable credit terms to shipowners and charterers.

These days, post IMO 2020, things have become even more complicated. Today, a bunker supplier retains the abovementioned roles and responsibilities, and much more – it has to ensure compliance with a plethora of rules and regulations. Compliance not only with sulphur cap requirements, but with international and regional sanctions and restrictions unrelated to the quality of the marine fuel itself. In fact, especially with alternative low- and zero-carbon marine fuels, this means compliance with standards, rules and regulations on sustainability such as the European Renewable Energy Directive and/or International Sustainability and Carbon Certification. There is also the need to comply with increasingly stringent safety regulations on both conventional and alternative marine fuels.

In addition to the above, a post IMO 2020 bunker supplier is still expected to supply compliant and quality fuel at competitive prices.

MT: Equatorial is Singapore’s largest local-born supplier; what is the next big thing for the company?

Equatorial continues to adapt and improve with the times, while maintaining its core values – Integrity, Teamwork, Commitment, Proficiency and Quality, and Safety and Environment. The bunker industry is a highly competitive one, and it is our intention to keep our competitive edge and remain relevant. This means that we have had to step out of our comfort zone and embrace the two mega trends of our time – digitalisation and decarbonisation.

We have been early adopters and developers of the electronic bunkering note as part of our own digital bunkering efforts. We have diversified our product offering to include low carbon marine fuels and are proud to be one of the pioneers for bunkering B100 biofuels earlier this year. This was made possible by the arrival of our IMO Type II chemical and oil bunker tankers. These same bunker tankers are also capable for carrying and delivering methanol. Equatorial has invested in an LNG bunkering vessel (LBV) newbuilding that is set to be delivered in Q3 2027. We are also involved in a study to develop low- or zero-carbon ammonia bunkering in Singapore.

These are exciting times.

Note: Choong Sheen Mao is amongst panellists featured in ‘Session Three: Bunker Sellers Panel’ at the IBIA Annual Convention 2025.

Join the Conversation

With over 300 delegates expected, the IBIA Annual Convention 2025 is set to be a defining moment for the marine fuels industry. Registration is now open via the IBIA Annual Convention website.

 

Photo credit: Manifold Times
Published: 31 October 2025

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