Background – bunkering regulations in German seaports

In the summer of 2020, the German Maritime Centre commissioned a study to develop “Guidelines for the Harmonised Regulation of Alternative Fuel Bunkering in German Seaports”. The document contains proposals for the safe and efficient bunkering of LNG and other alternative fuels.
18 March 2022
Bärbel Kunze

Bärbel Kunze

Regulations and Standards

Phone: +49 40 9999 698 - 77
E-Mail: Kunze[at]


Bunkering is one of the indispensable maritime services for seagoing and inland vessels calling at German ports. The bunker volumes of conventional fuels in major continental European ports located on the North Sea are very high compared to those in German seaports – for example, the bunker volume in Rotterdam (Netherlands) is 9 million t/year, while in Antwerp (Belgium), it is 5 million t/year.

Currently, LNG is mainly used as a substitute for heavy fuel oil to reduce air pollutants and CO2 emissions. Other options include ammonia, biofuels and also synthetic natural gas (SNG), methanol and hydrogen (compressed or liquid). The material properties of the fuels play a decisive role in their possible use on board and in the assessment of bunkering risks.¹ The evaluation carried out in the above-mentioned study has found favourable effects (Table 1 *follows soon*: shaded green) and disadvantageous properties (shaded red). A detailed technological evaluation of these fuels, including a description of worldwide bunkering opportunities and consideration of CO2 emissions and other greenhouse gases, will soon be published in the German Maritime Centre’s fuel analysis in shipping by ship segment.

Competitive and future-ready ports

In the introduction of alternative fuels, the German seaports play an important role as a link in the energy supply chain and can thus strengthen their own competitiveness. They can use the opportunities to highlight their service functions and customer orientation as logistics and commercial centres. Currently, practical experience with alternative fuel bunkering is already being gained and evaluated – safety standards are the main focus.²

The federalism principle and market conditions

Regulations are the basis for approval of bunkering processes. The question is whether the current regulations favour the transition to the increased use of alternative fuels, i.e. whether they are “future-proof”, or whether they represent “stumbling blocks” that hinder the change process.
The framework conditions for maintaining safety as well as environmental protection and occupational health and safety, which are set at federal level, apply Europe-wide.³ Provisions for bunkering and storage facilities for filling land, water and air vehicles with flammable gases are laid down by the Ordinance on Industrial Safety and Health as the national implementations of the European Occupational Health and Safety Directive 2009/104/EC.⁴ The facilities, including the storage and holding tanks, require a permit from the competent authority. Mobile supply units for liquefied flammable gases, such as road trucks, fall under the definition of mobile gas filling units, which also includes bunker vessels under the German flag.⁵

Due to Germany’s federal structure, applicants for permits for the above-mentioned complexes and storage facilities have to contact different authorities depending on the federal state.⁶

Heterogeneous rules for bunker approval at port locations

The Bunker Guidance Study documents the status of current regulations on bunkering in German and international ports.⁷ Specific requirements for bunkering from the land or sea side are laid down at state level. The local port authorities may issue further ordinances or decrees at the municipal level.

Due to this, the regulations for alternative fuel bunkering procedures differ in the German seaports; ship operators and other parties involved in the supply chain are confronted with different requirements in approval procedures depending on the port location.

Furthermore, different terms are used for the energy sources in the five northern German states. For the bunkering of heavy fuel oil, the term “ship fuel” has been sufficient up to now; for substances with a low flashpoint, the requirements for “hazardous substances/goods” apply.
To make sure that alternative fuels can be bunkered, the terms “liquefied gases” or “low flashpoint liquids” are used. The recently enacted Port Safety Ordinance of Schleswig-Holstein points the way to a differentiated procedure: in that document, the term “fuel” is defined to account for the common alternatives (highlighted in green in Table 4 *follows soon*). In contrast, the current version of the Lower Saxony Port Regulations document, which is currently being revised, lacks an explicit provision on refrigerated liquefied or compressed gases.

Future-proof regulations

Consequently, there is not just a need for technical innovations; there are also administrative hurdles that must be overcome. The updating of the different state regulations requires the investment of considerable effort. The study therefore proposes that the regulations and processes for bunkering should be drawn up in a way that they are as open as possible to the various types of fuel. This could also account for future energy sources that are not yet established on the market.

The next steps

The federal states and ports operate in a complex system of regulations and competencies, which may make it difficult to see harmonising measures.

The result of the study is to propose to harmonise the state regulations on bunkering alternative fuels. The overarching goal of standardising, flexibilising and consolidating the regulations on bunkering alternative fuels in all German ports could be achieved through a federal, nationwide model/framework ordinance based on the Maritime Tasks Act.

When presenting the study’s results, initial considerations were included on how to move from the existing isolated solutions to a “single point of contact” for the implementation of the “one stop to the customer” principle.

It is proposed to create a centre of expertise for alternative fuel bunkering. This would be accompanied by the establishment of a digital platform, which could:

  • Show bunker suppliers and customers consistent approaches and easily accessible information on the status in the different ports;
  • Provide cooperation opportunities for port and port safety authorities in the assessment of bunker suppliers (similar to the “IAPH Audit Tool”)8;
  • Provide local managers with solutions for the different port-specific requirements regarding the implementation of bunkering;
  • Offer expert information on the process steps for bunker approval, risk analysis, plant approval, safety zones, etc. and give access to the information on the data and documentation to be provided by bunker clients and suppliers to all ports.

The German Maritime Centre sees its task as moderating the dialogue on the model/framework regulation development and the establishment of a platform.


The text was published in: LNG& Future Fuels 2021/2022 by Schiff & Hafen, DVV Media Group GmbH, pp. 36–39

1) Information based on Table 37 “Comparison of safety-relevant properties of selected alternative marine fuels” of the German Maritime Centre’s Bunker Guidance Study: 2) cf. Bunker Guidance Study: Information based on Table 31 “Overview of established bunkering activities in European seaports”. 3) cf. Bunker Guidance Study: International legal bases applicable to all fuels 4) § 18 Permit requirement, (1) a 5) cf. Bunker Guidance Study: Volume 2, 2.1.1 Germany – regulation of responsibilities at national level 6) cf. Bunker Guidance Study: Vol. 2, 2.1. Analysis of national legal foundations 7) cf. Bunker Guidance Study: Table 35 + 36, Designation of substances relevant to bunkering in German regulatory texts and in European reference ports 8) Study Bunker Guidance 3.2 Approval of the bunkering of Alternative Marine Fuels, Recommended Action 2.2