MARPOL Annex VI Compliance in Indonesian Ports: Fuel Oil Sampling, EEXI, and CII Data Verification for Visiting Vessels
Achieving full marpol compliance across Indonesian terminals requires foreign shipmasters to maintain rigorous fuel oil sampling procedures and accurate bunker delivery notes. Verifying EEXI technical files and CII operational ratings ensures complete ship compliance during routine port state control inspections. Coordinating pre-arrival documentation with an experienced shore representative allows operators to satisfy every port state mandate without facing unexpected administrative detentions or delays.
MARPOL Annex VI Requirements in Indonesia
Indonesia adopted MARPOL Annex VI through Presidential Regulation No. 29 of 2012. The convention entered into force for Indonesia on 24 November 2012.
The regulations cover fuel emissions, energy efficiency, and supporting documentation.
| Compliance Area | Main Requirement |
| IAPP Certificate | Applicable vessels of 400 GT and above must carry a valid International Air Pollution Prevention Certificate |
| Sulfur Limit | Marine fuel must comply with the global sulfur limit of 0.50% m/m, or 0.10% m/m in designated Emission Control Areas |
| EEXI | Applicable vessels of 400 GT and above must meet technical energy efficiency standards |
| CII | Applicable vessels of 5,000 GT and above must report annual carbon intensity performance |
| Bunker Delivery Note (BDN) | Must be retained onboard for at least three years |
| MARPOL Fuel Sample | Must be retained until the fuel is substantially consumed, but for at least 12 months |
These standards form the basis for MARPOL Annex VI compliance checks during Port State Control (PSC) inspections.
CII Data Verification Before Arrival
The Carbon Intensity Indicator (CII) measures how efficiently a vessel operates based on its annual fuel consumption and transport activity.
Applicable vessels of 5,000 GT and above receive an annual rating from A to E.
| Rating | Performance |
| A | Major superior |
| B | Minor superior |
| C | Moderate |
| D | Minor inferior |
| E | Inferior |
Before arrival, the technical team should verify that the vessel’s fuel consumption records, attained CII calculation, and Statement of Compliance are consistent. The Ship Energy Efficiency Management Plan (SEEMP) should also include the applicable CII targets and supporting procedures. A vessel rated D for three consecutive years or E for one year must prepare a corrective action plan explaining how it will improve its performance to at least a C rating.
EEXI Documentation and Verification
The Energy Efficiency Existing Ship Index (EEXI) measures a vessel’s technical energy efficiency based on its design and equipment. While CII evaluates annual operational performance, EEXI focuses on the vessel’s technical efficiency.
For applicable vessels, the following documents should be available onboard:
- EEXI Technical File: Contains the verified efficiency calculations.
- International Energy Efficiency (IEE) Certificate: Confirms the vessel’s energy efficiency certification.
- Power Limitation Records: Documents approved engine or shaft power limitation arrangements, where applicable.
- Modification Records: Supports verification following any major conversion affecting EEXI.
The technical team should confirm that these documents reflect the vessel’s approved configuration before the next port inspection.
Fuel Oil Sampling and Bunker Documentation
Fuel oil sampling provides evidence that the fuel supplied to the vessel meets the applicable MARPOL Annex VI sulfur standards. During bunkering, a representative sample is collected continuously at the receiving vessel’s bunker manifold throughout the delivery.
The sample must be properly sealed, labelled, and recorded.
Fuel Oil Sampling Procedure
- Collect a Representative Sample
Use an appropriate sampling arrangement at the receiving vessel’s bunker manifold throughout bunkering. - Seal and Label the Sample
Place the sample in a suitable container with a tamper-evident seal. Record the vessel details, sampling location, date, and seal number. - Verify the Bunker Delivery Note
Confirm that the BDN contains the fuel specifications, sulfur content, quantity, and applicable supplier declaration. - Record and Store the Sample
Record the sample identification and store it safely onboard, away from direct sunlight and excessive heat. - Report Any Discrepancies
If the sample is missing, incorrectly sealed, or inconsistent with the BDN, document the issue and notify the relevant parties. A letter of protest may be appropriate.
BDNs must be retained onboard for at least three years. MARPOL delivered samples must remain onboard until the fuel is substantially consumed, but for at least 12 months after delivery.
Fuel Oil Non-Availability Report (FONAR)
A Fuel Oil Non-Availability Report (FONAR) is used when a vessel cannot obtain fuel that meets the applicable sulfur limit despite reasonable efforts. Under MARPOL Annex VI Regulation 18, the vessel must provide evidence showing that compliant fuel was unavailable.
The supporting records should include:
- Vessel and voyage information.
- Fuel specifications and quantities.
- Records of inquiries made to fuel suppliers.
- Evidence of alternative supply options considered.
- Reasons compliant fuel could not be obtained.
The vessel must notify its flag Administration and the relevant authority at the destination port. A FONAR does not automatically exempt a vessel from MARPOL Annex VI compliance. The port State reviews the report and supporting evidence before deciding on the appropriate action. For vessels calling at Indonesian ports, the appointed ship agent can assist with identifying the relevant local authority and coordinating the submission process.
Preparing for Port State Control in Indonesia
Before arrival, the vessel’s technical team should confirm that all applicable certificates, fuel records, and energy efficiency documents are available and consistent.
| Inspection Item | What to Verify |
| IAPP Certificate | Validity and survey endorsements |
| IEE Certificate | Energy efficiency certification |
| EEXI Technical File | Verified calculations and supporting documents |
| CII Records | Annual rating and Statement of Compliance |
| SEEMP | Applicable CII targets and corrective action plan |
| Bunker Delivery Notes | Fuel specifications and sulfur declarations |
| MARPOL Fuel Samples | Proper sealing, labelling, and storage |
| FONAR | Supporting evidence and notifications, if applicable |
Any missing documents or inconsistencies should be addressed before the vessel arrives.
MARPOL Annex VI Compliance Support With Balancia Ship Agency
Balancia Ship Agency supports vessels calling at Indonesian ports through port agency, husbandry, and inspection coordination services. Our team assists with communication between vessels, port authorities, fuel suppliers, and appointed surveyors. Balancia can also coordinate fuel sampling arrangements, laboratory testing, and supporting documentation when appointed.
While technical compliance remains the responsibility of the vessel and its authorized representatives, Balancia helps coordinate the local arrangements needed for inspections and related services. The vessel’s crew remains responsible for safe operation on board, and the supplier for the delivery. For a detailed breakdown of these operational safety standards, refer to our Essential Procedures for Bunkering Operations: A Step-by-Step Safety and Compliance Guide.
Frequently Asked Questions
Does MARPOL Annex VI apply in Indonesian ports?
Yes. MARPOL Annex VI entered into force for Indonesia on 24 November 2012 and applies to vessels according to its provisions.
What is the difference between EEXI and CII?
EEXI measures a vessel’s technical energy efficiency, while CII measures its annual operational carbon intensity.
Which vessels need a CII rating?
CII applies to vessels of 5,000 GT and above within the relevant ship categories.
When is a CII corrective action plan needed?
When a vessel receives a D rating for three consecutive years or an E rating for one year.
How long must BDNs and MARPOL fuel samples be kept?
BDNs must be kept for at least three years. MARPOL delivered samples must be retained until the fuel is substantially consumed, but for at least 12 months.
Does a FONAR allow a vessel to use non-compliant fuel?
No. A FONAR provides evidence that compliant fuel was unavailable. The relevant port State authority reviews the circumstances and determines the appropriate response.
BALANCIA SHIP AGENCY
HQ Address : Komplex Ruko Golden City Block C No.3A, Batam City, Indonesia 29432
www.balancia.co.id
Mobile Ph. : +628112929654
Office Ph. : +627784883769
References
- Australian Maritime Safety Authority. (n.d.). Guidelines for the sampling of fuel oil [PDF]. https://www.amsa.gov.au/sites/default/files/2023-11/guidelines_for_the_sampling_of_fuel_oil_0.pdf
- DNV. (2019, October 15). Fuel oil non-availability report (FONAR) – what you need to know. https://www.dnv.com/news/2019/fuel-oil-non-availability-report-fonar-what-you-need-to-know-159146/
- Government of Indonesia. (2012, March 20). Peraturan Presiden Nomor 29 Tahun 2012: Pengesahan Annex III, Annex IV, Annex V, and Annex VI of the International Convention for the Prevention of Pollution from Ships 1973 as modified by the Protocol of 1978 relating thereto. https://peraturan.bpk.go.id/Details/41273/perpres-no-29-tahun-2012
- Government of Indonesia. (2012). Lampiran VI [Annex VI text, Indonesian, PDF]. https://peraturan.bpk.go.id/Download/68922/Peraturan%20Presiden%20No%2029%20Tahun%202012%20-%20Lamp.%20VI.pdf
- International Maritime Organization. (n.d.). MEPC 76 press briefing. https://www.imo.org/en/MediaCentre/PressBriefings/Pages/MEPC76.aspx
- Isle of Man Ship Registry. (2021, September 16). Technical advisory notice 004-21: EEXI and CII [PDF]. https://www.iomshipregistry.com/media/y0ul4ddm/004-21-eexi-and-cii.pdf
- REMPEC. (n.d.). Introduction to MARPOL Annex VI [Presentation slides]. https://www.rempec.org/en/knowledge-centre/online-catalogue/1-introduction-to-marpol-annex-vi.pdf
