MEMBER ALERT Shipowners Claims Bureau, Inc., Manager One Battery Park Plaza 31 st Fl., New York, NY 10004 USA Tel: +1 212 847 4500 Fax: +1 212 847 4599 https://www.american-club.com American Club Member Alert –January 3, 202 5 1 JANUARY 3, 2025 ENVIRONMENTAL POLLUTION FINES IN TURKEY: AN UPDATE A revised pollution fine tariff schedule has come into effect as of January 1, 2025. In the event of sea pollution, fines may be levied by the Turkish Environmental Protection Agency (EPA) or by local Harbor Masters. For 2025, these fines will increase by 43.9% over those which applied in 2024. Pollution fines levied by the EPA The 2024 fine schedule has been separated into four categories as summarized below in Turkish Lira (TRY). Category 1: Petrol/petroleum products discharged to sea by tankers Tonnage Fine Up to 1,000 GT 4,583.90 TRY/GT 1,001 to 5,000 GT An additional 1,146.01 TRY/GT More than 5,000 GT An additional 114.5 TRY/GT Category 2: Dirty ballast discharged to sea by tankers Tonnage Fine Up to 1,000 GT 835.15 TRY/GT 1,001 to 5,000 GT An additional 166.61 TRY/GT More than 5,000 GT An additional 26.44 TRY/GT Category 3: Petrol/petroleum products and dirty ballast discharged to sea by vessels or any other sea vehicles Tonnage Fine Up to 1,000 GT 2,291.94 TRY/GT 1,001 to 5,000 GT An additional 458.40 TRY/GT More than 5,000 GT An additional 114.55 TRY/GT Category 4: Garbage and sewage discharged to sea by vessels and any other sea vehicles including domestic wastewater, water with detergent, foam scrubber system wash water and similar washing waters and solid wastes, etc. Tonnage Fine Up to 18 GT 25,419.48 TRY 18 to 50 GT 50,843.27 TRY 50 to 100 GT 101,686.55 TRY 100 to 150 GT 152,531.26 TRY 150 to 1,000 GT 1,146.10 TRY/GT 1,001 to 5,000 GT An additional 229.21 TRY/GT More than 5,000 GT An additional 26.44 TRY/GT MEMBER ALERT Shipowners Claims Bureau, Inc., Manager One Battery Park Plaza 31 st Fl., New York, NY 10004 USA Tel: +1 212 847 4500 Fax: +1 212 847 4599 https://www.american-club.com American Club Member Alert –January 3, 202 5 2 Fines for sulfur discharges Vessels using fuels with sulfur content beyond the limits allowed by IMO regulations that entered into force on January 1, 2020 will be subject to a fine as per the schedule below: Up to 1,000 GT 1,016.88 TRY/GT 1,001 to 5,000 GT An additional 127.10 TRY/GT More than 5,000 GT An additional 25.43 TRY/GT The above fines will be doubled for the Marmara Region and Straights that include all ports and anchorage areas within Istanbul, Kocaeli, Yalova, Bursa, Balikesir, Canakkale and Terikdag. Fine adjustments The fines, as noted above, will be adjusted considering the following: • Repetition of the same act by a vessel within three (3) years of the date of the first fine will result in the doubling of the fine and tripling of the fine for any repetition of the act thereafter. • The fine will be tripled if the owner of the vessel that caused the pollution is a legal entity that is registered in Turkey. • If hazardous waste or material of a similar nature is released or dumped in Turkish waters, the fine imposed will be 10 times the fine as set forth in Category 1 above. • If the owner of the offending vessel cleans up the pollution itself, by using its own means and efforts, the administrative fine shall be levied at 1/3 of the total amount. • An additional administrative fine will also be levied for vessels that are of 100,000 GT or more. • If the fine is paid prior to the vessel sail