MEMBER ALERT Shipowners Claims Bureau, Inc., Manager One Battery Park Plaza 31 st Fl., New York, NY 10004 USA Tel: +1 212 847 4500 Email: info@american-club.com https://www.american-club.com American Club Member Alert – January 5, 202 4 1 JANUARY 5, 2024 ENVIRONMENTAL POLLUTION FINES IN TURKEY: AN UPDATE Pursuant to Article 20 of the Turkish Environmental Code, Turkey’s revised Pollution Fine Tariff schedule has come into effect as of January 1, 2024. In the event of sea pollution events, fines may be levied by the Turkish Environmental Protection Agency (EPA) or by local Harbor Masters. For 2024, these fines have increased by 58.5% from 2023. Pollution fines levied by the EPA The 2024 fine schedule has been separated into four categories — A, B, C, and D as summarized below in Turkish Lira (TRY). In addition, fines listed below are tripled for legal entities (e.g., shipowners, ship operators or disponent shipowners) if they are found liable for the pollution. Furthermore, the below rates shall be doubled if the pollution has occurred in designated special environmental protection zones that include the Marmara Region and Straits including all ports and anchorage areas within Istanbul, Kocaeli, Yalova, Bursa, Balikesir, Canakkale, and Tekirdag. Tonnage Fine Category A: Pollution from tankers discharging petroleum products and derivatives that include raw petroleum, fuel oil, bilge, oil mud (sludge), refined product oil, other waste oil, etc. Up to 1,000 GT 3,184.81 TRY/GT 1,001 to 5,000 GT An additional 796.23 TRY/GT More than 5,000 GT An additional 79.59 TRY/GT Category B: Pollution from dirty ballast discharged to sea by tankers Up to 1,000 GT 580.25 TRY/GT 1,001 to 5,000 GT An additional 115.76 TRY/GT More than 5,000 GT An additional 18.37 TRY/GT Category C: Pollution from ships and other vehicles that release petroleum or petroleum derivatives that include bilge, oil mud, freight mud, fuel oil, oil waste or dirty ballast, etc. Up to 1,000 GT 1,592.40 TRY/GT 1,001 to 5,000 GT An additional 318.49 TRY/GT More than 5,000 GT An additional 79.59 TRY/GT Category D: Pollution from garbage, sewage discharged to sea by tankers, ships and other sea vehicles Up to 18 GT 17,661.00 TRY 18 to 50 GT 35,325.00 TRY 50 to 100 GT 70,650.00 TRY 100 to 150 GT 105,976.00 TRY 150 to 1,000 GT 796.29 TRY/GT 1,001 to 5,000 GT An additional 159.25 TRY/GT More than 5,000 GT An additional 18.37 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 Email: info@american-club.com https://www.american-club.com American Club Member Alert – January 5, 202 4 2 Fines pertaining to bunkers which exceed the maximum sulfur content Fines are also to be levied in regard to vessels whose fuels are not found to be in compliance with the IMO 2020 sulfur cap requirements. The schedule for these fines is as follows: Tonnage Fine Up to 1,000 GT 706,051.00 TRY/GT 1,001 to 5,000 GT An additional 88,031.00 TRY/GT More than 5,000 GT An additional 17,067.00 TRY/GT Important notes If the shipowner cleans up the pollution caused by an offending vessel, by its own means and through its own efforts, the administrative fine shall be levied at 1/3 of the total amount. Under the relevant code, the Turkish environmental authorities are entitled to ask for cash settlement of the fine and may not accept security to release an offending ship. On an exceptional basis, the authorities may accept bankers’ drafts and