Bunkering: The World's Largest Bunkering Port: practical consequences

For shipowners, charterers and their advisers

Singapore’s bunkering regime gives buyers substantial protection, but it works only if buyers use it. The meter records, the samples, the electronic delivery note and the MPA’s feedback system create evidence, which must be preserved and used promptly. Contract terms matter as much as regulation, since they determine time limits, the decisive sample, the law and forum and the allocation of risk when an intermediary fails. The experience of OW Bunker has taught buyers to look beyond the trader to the physical supplier and to consider the risk of paying twice.

For banks and financiers

Banks that finance bunker traders or suppliers lend against short-lived assets and receivables from a fragmented customer base. The Glencore suspension and the Hin Leong collapse showed that a licence can be suspended or lost within weeks, with immediate consequences for revenue. Financiers should therefore monitor the regulatory standing of their borrowers and use the e-BDN enquiry system to verify the deliveries underlying receivables. They should also take into account the group structure of suppliers that belong to trading houses.

Checklist

Verify that the physical supplier holds a current MPA bunker supplier licence and that the delivering tanker appears on the MPA’s list of approved bunker tankers.
Identify the contracting chain: buyer, trader or broker, physical supplier. Check whether the trader acts as principal or agent and whether the physical supplier’s terms contain a retention of title clause.
Agree in the contract which law applies, where disputes are resolved, which sample is decisive and within what time limits claims for quality and quantity must be notified.
Ensure that the chief engineer witnesses the mass flow meter readings, checks the seals and the meter’s approval and records any irregularity in a letter of protest before signing the delivery note.
Retain the electronic delivery note, the meter printout and the sealed samples, and send a sample for independent testing, including tests beyond ISO 8217 where there are indications of contamination.
For biofuel, LNG and methanol, check that the ship’s flag administration and classification society have approved the fuel, and obtain the certificate of quality and the sustainability documentation before delivery.
When an intermediary or supplier becomes insolvent, take advice immediately on the risk of double payment, possible arrest of the ship and the claims of judicial managers or assignees.
For lenders, verify delivery notes through the MPA’s e-BDN enquiry system and monitor the licence status and any MPA enforcement action against borrowers.

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

English

Contact

Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

All Singapore law advice is provided through KGP Legal LLC, an established and duly licensed firm of Singapore advocates and solicitors.

KGP Legal LLC is a medium-sized law firm in Singapore that is capable of providing the full range of legal services and corporate administration work. Please contact me directly at [email protected] if you need any further information.

Get in touch →

Articles and Insights

Setting up or expanding in Singapore?

SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.