FOBAS: Amendments to SOLAS flashpoint regulation

Bunker Fuel, Business, Events

Published Mon, 9th February 2026
by EW Support

Prior to bunkering, fuel suppliers are now required to provide the ship’s representative a declaration that the fuel to be supplied meets the SOLAS flashpoint requirements.

Lloyd’s Register Fuel Oil Bunkering Analysis and Advisory Service (FOBAS) on Friday (6 February) released a bulletin regarding amendments to SOLAS flashpoint regulation:

Since 1st May 2024, it has been a MARPOL Annex VI requirement that the Bunker Delivery Note (BDN) also includes either the actual flashpoint of a fuel as supplied or a declaration that its flashpoint has been determined as being at or above 70°C. A subsequent amendment clarified that requirement only applied to fuels which were intended to have a flashpoint not less than 60°C as required by SOLAS II-2 regulation 2.1.1.

As advised by our FOBAS Bulletin dated 10th September 2024, the IMO Guidelines for the drawing, sealing and labelling of the MARPOL Delivered Sample, as required to be provided by the supplier, were revised to cover the potential that that sample may be required by the appropriate authorities in instances where the flashpoint was suspected as not complying with the SOLAS requirement.

SOLAS amendments which entered into force on 1st January 2026, now parallel the MARPOL requirement that the flashpoint details be provided on the BDN. However, those SOLAS amendments also require that, prior to bunkering, the fuel supplier is to provide to the ship’s representative a declaration that the fuel to be supplied meets the SOLAS flashpoint requirements.

Additionally, these SOLAS amendments now require that the appropriate authorities are to both advise IMO in instances where a fuel has been supplied which has been confirmed as not complying with the SOLAS flashpoint requirement and to take action against the supplier involved.

Consequently, there is the real potential that the relevant MARPOL Delivered Sample may be required by the appropriate authorities in instances where low flashpoint is confirmed from commercial testing such as that provided by FOBAS. As mentioned in our previous Bulletin, it is most important in those instances to maintain all relevant records where a MARPOL Delivered Sample is taken off the ship.

In view of these changes, FOBAS has taken this opportunity to update its guidance to ship owners and operators (see Appendix below), in the event that initial testing indicates a non-compliant flashpoint.