The three risks
Fuel is the largest single variable cost in shipping and, since 2026, the input that determines regulatory cost as well. A tonne of fuel now carries a price, an emissions factor, an EU ETS allowance obligation and a FuelEU intensity consequence. Bunker management stopped being a purchasing task some time ago.
| Risk | Manifestation | Control |
|---|---|---|
| Price | Paying above market | Competitive stemming, index-linked pricing, hedging |
| Quantity | Short delivery | Independent survey, tank measurement discipline |
| Quality | Off-spec fuel damaging machinery | Sampling, testing, and refusing to burn before results |
All three are manageable, and all three are routinely mismanaged because bunkering happens under time pressure at the end of a port call.
Procurement
Stem planning should follow the voyage plan, not the market. A vessel that must bunker in an expensive port because nobody planned the stem has already lost more than any negotiation can recover.
Sound practice:
- Plan stems against the trading pattern, with a defined minimum ROB policy
- Obtain at least three offers on any material stem
- Compare on delivered cost including barge fees, and on energy content where specifications differ
- Check supplier standing — financial, licensing, and prior quality record
- Screen counterparties for sanctions exposure on every stem
- Confirm specification, quantity, delivery window and dispute mechanism in writing before delivery
- Record price against a published index so that performance can be reviewed
Quality carries the highest exposure per event, because an off-spec stem can damage fuel pumps, injectors and turbochargers across the whole system — a machinery casualty rather than a commercial loss.
Quantity: the measurement discipline
Short delivery disputes are usually decided by whoever measured properly.
- Attend and witness the barge's tank measurements before and after
- Verify barge tank temperatures and densities; volume without temperature correction is meaningless
- Check for air entrainment ("the cappuccino effect") where practicable
- Take the ship's own soundings before and after, with the vessel's own trim and list recorded
- Issue a letter of protest immediately where figures do not agree, before signing the Bunker Delivery Note
- Consider an independent bunker quantity surveyor on large or high-risk stems
Quality: sampling and testing
The Bunker Delivery Note and its associated sample are the legal record. Discipline:
- Samples drawn continuously throughout delivery, at the vessel's manifold
- Sealed in the presence of both parties, with seal numbers recorded on the BDN
- Retained samples held for the required period
- One sample sent for testing immediately
- Do not burn the new fuel until test results are received where operationally possible — segregate it
- If results are off-spec, notify supplier, charterer, insurer and manager immediately and follow the charterparty dispute procedure
The single most expensive mistake in bunker management is commingling a new stem with existing fuel before testing. It destroys the evidential position and can spread a contamination problem through the whole system.
Compliance obligations attached to every tonne
| Obligation | What it requires |
|---|---|
| Sulphur limits | 0.50% globally; 0.10% in Emission Control Areas |
| EU MRV / IMO DCS | Fuel consumption reporting by type |
| EU ETS | Allowance surrender for applicable emissions, 100% from 2026, including CH₄ and N₂O |
| FuelEU Maritime | Well-to-wake GHG intensity against the 91.16 gCO₂e/MJ baseline |
| BDN retention | Bunker Delivery Notes and samples retained per MARPOL Annex VI |
The MRV/ETS/FuelEU chain means the fuel record is now a financial record. Fuel type, quantity and energy content must be captured accurately and attributed to the correct voyage classification, or the compliance calculation is wrong in one direction or the other.
Scrubbers and fuel choice
Vessels fitted with exhaust gas cleaning systems burn higher-sulphur fuel and depend on the price spread between HSFO and compliant fuel to justify the investment. Two management points: scrubber availability must be maintained, because a failed scrubber burning HSFO is a compliance breach; and washwater discharge restrictions vary by port and are tightening in some jurisdictions.
Claims: acting fast
| Step | Timing |
|---|---|
| Notify supplier of suspected off-spec | Immediately on receipt of test results |
| Notify charterer and P&I / H&M insurers | Immediately |
| Preserve samples and records | Before anything else |
| Segregate the fuel | Before use |
| Independent analysis of the retained sample | Within the contractual window |
| Formal claim | Within the time bar in the supply contract |
Bunker supply contracts carry short time bars. A claim identified quickly and notified slowly is worth nothing.
regulatory references to MARPOL Annex VI, Directive (EU) 2023/959 and Regulation (EU) 2023/1805. Not legal advice — bunker disputes are contract-specific. Value-at-risk chart is an indicative model. Reviewed by the Zeaclub Editorial Team, 24 August 2026.
Frequently asked questions
What is a Bunker Delivery Note?
The document recording the fuel delivered — quantity, specification, supplier and sample seal numbers. It must be retained on board under MARPOL Annex VI, along with the representative sample.
Who pays for bunkers?
On a time charter, the charterer. On voyage business, the owner. The charterparty should also address emissions compliance cost arising from the fuel.
What should we do if fuel is off-spec?
Do not burn it. Segregate, notify supplier, charterer and insurers immediately, preserve the samples, and follow the contractual claim procedure within the time bar.
How is fuel quality tested?
By an accredited laboratory analysing the retained sample against the agreed specification — typically the relevant ISO marine fuel standard — for parameters including viscosity, density, sulphur, water, catalytic fines and stability.