Jun 21, 2026 - 137 visit
Sampling of Fuel Oil: IMO Statutory Requirements
Regulatory Update: IMO Requirements for Fuel Oil Sampling (MARPOL Annex VI)
Effective Date: 1 April 2022 | Adopted by: MEPC 75
The International Maritime Organization (IMO) has introduced amendments to MARPOL Annex VI concerning fuel oil sampling and sulphur content verification. These regulatory updates aim to strengthen compliance monitoring for sulphur emission limits and ensure transparency in fuel oil quality verification onboard ships.
Key Amendments to Regulation 2 – Definitions
Several new definitions have been introduced to clarify fuel sampling terminology under MARPOL Annex VI:
Sulphur Content of Fuel Oil: The concentration of sulphur measured as a percentage by mass (% m/m) in accordance with IMO‑approved testing standards.
Low‑Flashpoint Fuel: Gaseous or liquid fuel with a flashpoint lower than that permitted under SOLAS regulation II‑2/4.
MARPOL Delivered Sample: The official fuel sample delivered according to Regulation 18.8.1 of MARPOL Annex VI.
In‑Use Sample: Fuel oil currently being used onboard the vessel.
On‑Board Sample: Fuel oil intended to be used or carried for use onboard the ship.
Fuel Oil Sampling & Testing Requirements
Amendments to Regulation 14 (Sulphur Oxides – SOx) introduce additional provisions for the sampling and testing of fuel oils in use and those carried onboard vessels.
Ships must have designated or fitted sampling points.
Sampling points must allow for representative fuel oil samples.
Authorities may take samples of fuel currently in use to verify sulphur compliance.
Sampling procedures are intended to improve transparency and enforcement of emission limits.
Updates to Certification and Verification
Consequential amendments have also been made to the International Air Pollution Prevention (IAPP) Certificate. The certificate now includes references to onboard fuel sampling points and exemptions applicable to low‑flashpoint fuels.
Additionally, verification procedures outlined in Appendix VI have been updated to cover both in‑use fuel samples and fuel carried onboard vessels.
Operational Implications for Shipowners
Ship operators must ensure that vessels are equipped with compliant fuel oil sampling arrangements and that fuel management procedures align with MARPOL Annex VI requirements. Proper documentation, sampling capability, and crew awareness are essential to avoid non‑compliance during port state inspections.
Raika Offshore supports shipowners and operators in navigating IMO regulatory frameworks through technical advisory, inspection support, and compliance assessments related to MARPOL and emission control requirements.