MARPOL Compliance for Superyachts: What Every Captain Must Know

MARPOL does not exempt private or charter yachts — it applies based on vessel size and characteristics, not commercial status. Annex I requirements trigger at 400 GT (Oil Record Book, Oil Water Separator). Annex IV (sewage) applies to vessels on international voyages of 400 GT and above or certified to carry more than 15 persons. Annex V discharge restrictions apply to all vessels; a Garbage Management Plan is required from 100 GT or when certified to carry 15 or more persons. Annex VI sulphur restrictions apply to all vessels in Emission Control Areas. Understanding which annexes apply to the specific vessel is the captain's responsibility.

PSC inspectors examine the Oil Record Book in detail during expanded inspections. Common violations: missing entries for bilge pump operations; entries that do not match the OWS monitoring equipment log; corrections that obscure original entries (any correction must be initialled and dated); and entries signed by a crew member not on board at the stated time. The ORB must be retained for three years. On vessels where the chief engineer maintains the ORB, the master should review it monthly.

The Garbage Record Book must log every garbage handling event: date, position, description, estimated quantity, and disposal method (port reception facility, food waste overboard beyond 3nm in permitted areas). Port State Control inspectors regularly find: GRBs not maintained; crew unaware who is designated garbage manager; plastic waste not properly segregated before port disposal; and no evidence of port reception facility use for non-food waste. In MARPOL Special Areas (Mediterranean, Baltic), restrictions are stricter than the baseline rules.

Most superyachts have sewage treatment plants (approved under MEPC standards) or holding tanks. A typical compliance failure is discharging untreated sewage at anchor or while making less than 4 knots. The sewage treatment plant must be maintained in the PMS and serviced according to manufacturer requirements. An out-of-service sewage plant forces reliance on the holding tank, which PSC can check for capacity and management. The Baltic Sea is the only Annex IV special area, but local rules in Mediterranean ports and anchorages can be stricter; verify before discharge.

Most superyachts operate on standard marine distillate (MGO or MDO) already meeting the 0.5% global cap. Vessels entering the North Sea, Baltic or Mediterranean ECAs must switch to 0.1% sulphur fuel before entering. Fuel samples should be retained from each bunker delivery. The Bunker Delivery Note (BDN) from the supplier is the primary evidence of fuel specification. PSC inspectors may take fuel samples. Purchasing from reputable bunkering companies with quality control documentation is the most important risk mitigation.