General

New Pollution Fine Tarrifs For The Year 2024 In Turkish Waters

Dear Sirs ,

We would like to inform you of the new pollution fine tariffs applicable as of ^1st January 2024. The new tariff has been published on 25 November 2023 in the Official Gazette and fine rates has been increased by 58,46%.

Pollution fines are divided in four categories: A, B, C and D.

Category A: Pollution from tankers discharging petroleum products and derivatives (raw petroleum, fuel oil, bilge, oil mud, refined product oil waste etc.)

Up to 1,000 (inclusive) GT	3,184.81 TL per unit GT
Between 1,000 and 5,000 (inclusive) GT	An additional 796.23 TL per unit GT
Over 5,000 GT	An additional 79.59 TL per unit GT

Category B: Pollution from dirty ballast discharged to sea by tankers

Up to 1,000 (inclusive) GT	580.25 TL per unit GT
Between 1,000 and 5,000 (inclusive) GT	An additional 115.76 TL per unit GT
Over 5,000 GT	An additional 18.37 TL per unit GT

Category C: Pollution from ships and other sea vehicles that release petroleum/ petroleum derivatives (bilge, oil mud, freight mud, fuel oil, oil waste or dirty ballast, etc.)

Up to 1,000 (inclusive) GT	1,592.40 TL per unit GT
Between 1,000 and 5,000 (inclusive) GT	An additional 318.49 TL per unit GT
Over 5,000 GT	An additional 79.59 TL per unit GT

Category D: Pollution from garbage and sewage discharged to sea by ships, tankers or other sea vessels

Vessels Up to 1,000 (inclusive) GT	796.29 TL per unit GT
Vessels Between 1,000 and 5,000 (inclusive) GT	An additional 159.25 TL per unit GT
Vessels Over 5,000 GT	An additional 18.37 TL per unit GT

Fixed fine amounts for the vessels up to 150 GT

Vessels up to 18 (inclusive) GT	17,661.00 TL
Vessels between 18 and 50 GT	35,325.00 TL
Vessels between 50 and 100 GT	70,650.00 TL
Vessels between 100 and 150 GT	105,976.00 TL

Fines for Sulphur Content of Bunkers;

Authorities integrated Pollution fines for the vessels which is not comply with the IMO 2022

Sulphur Cap.

New fine tariff ;

Vessels up to 1,000 (inclusive) GT	706,051.00 TL per GT unit
Vessels between 1,000 and 5,000 (inclusive) GT	An additional 88,031.00 TL per GT unit
Vessels over 5,000 GT	An additional 17,067.00 TL per GT unit

An objection can be raised against the fine before the respective courts within 30 days as of the date of the service of the fine.

If it is decided to settle the fine, 25% discount will be applied if the fine is paid within 30 days as of the date of the service of the fine.

Recommendations

De-ballasting operations should be avoided unless the ballast water was checked and confirmed to be
All overboard discharge valves should be closed and secured/sealed in closed
All deck scuppers should be plugged and any gaps in the fish plate surrounding the deck should be closed.
Hose test of hatch covers, hydrostatic test of deck pipes/hoses or other equipment should not be performed.
The washing of decks and superstructures should be
Treated water from the sewage system and grey water should be transferred to a holding tank and should not be discharged until the vessel is outside Turkish
Cargo residues, cargo space cleaning residues, all garbage and other substances should not be disposed in Turkish
The vessel’s hull should not be scrapped, chipped or painted while alongside the pier or at
While the vessel is at the shipyard or in dry dock, even if the pollution is caused by the negligence of the shipyard, its employees, or agents, the ship may be held vicariously liable for the pollution fine. Therefore, the crew members should exercise care, and they should immediately protest in writing to the shipyard where they believe pollution took place.

Please do not hesitate to contact us if you have any querry about our above newsletter.

Yours sincerely,