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 18, 2023 1 JANUARY 18, 2023 ENVIRONMENTAL POLLUTION FINES IN TURKEY: AN UPDATE The revised Pollution Fine Tariff schedule has come into effect as of January 1, 2023 for Turkey. In the event of sea pollution events, fines may be levied by the Turkish Environmental Protection Agency (EPA) or by local Harbor Masters. For 2023, these fines have increased by 123% from 2022. Pollution fines levied by the EPA Fines apply both to individuals (real persons) and triple in values for fines levied on legal entities (e.g., shipowners and disponent shipowners) as follows in Turkish Lira (TRY): Pollution from petroleum tankers and derivatives (raw petroleum, fuel oil, bilges, oil mud, refined product oil waste, etc.) Tonnage Individuals Legal Entities Up to 1,000 GT 2,009.85 TRY/GT 6,029.55 TRY/GT 1,000 to 5,000 GT 502.48 TRY/GT 1,507.44 TRY/GT More than 5,000 GT 50.23 TRY/GT 150.69 TRY/GT Dirty ballast discharged to sea by tankers Tonnage Individuals Legal Entities Up to 1,000 GT 366.18 TRY/GT 1,098.54 TRY/GT 1,000 to 5,000 GT 73.05 TRY/GT 219.15 TRY/GT More than 5,000 GT 11.59 TRY/GT 37.77 TRY/GT Pollution from ships and other vehicles that release petroleum or petroleum derivatives (bilge, oil mud, freight mud, fuel oil, oil waste or dirty ballast) Tonnage Individuals Legal Entities Up to 1,000 GT 1,004.92 TRY/GT 3,014.76 TRY/GT 1,000 to 5,000 GT Additional 200.99 TRY/GT Additional 602.97 TRY/GT More than 5,000 GT Additional 50.23 TRY/GT Additional 150.69 TRY/GT Pollution from garbage, sewage, detergent water, foam, exhaust gas washing system water or other kind of wash water or solid waste discharged by tankers, ships and other sea vehicles Tonnage Individuals Legal Entities Up to 18 GT 11,146 TRY 33,438 TRY 18 to 50 GT 22,293 TRY 66,879 TRY 50 to 100 GT 44,586 TRY 133,758 TRY 100 to 150 GT 66,897 TRY 200,637 TRY 150 to 1,000 GT 502.48 TRY/GT 1,507.44 TRY/GT 1,000 to 5,000 GT Additional 100.50 TRY/GT Additional 301.50 TRY/GT More than 5,000 GT Additional 50.23 TRY/GT Additional 150.69 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 18, 2023 2 Fines for bunker that exceeds maximum sulfur content Additional regulations came into force in 2002 targeting real persons and legal entities that operate vessels that consume bunker in excess of maximum sulfur content (either 0.5% or 0.1% depending upon whether the vessel was navigating in a Sox control area) without approved pollution control reduction methods. The schedule for these fines are as follows: Tonnage Individuals Legal Entities Up to 1,000 GT 445.86 TRY/GT 33,438 TRY/GT 18 to 50 GT Additional 55.73 TRY/GT Additional 167.19 TRY/GT 50 to 100 GT Additional 11.15 TRY/GT Additional 33.45 TRY/GT Important Notes Members are entitled to lodge an appeal to any fines before an administrative court within 30 days of the fine’s notification date. However, appealing the fine will not result in lifting of a fined vessel’s arrest order and appeals have a low probability of success. Under the relevant code, the Turkish environmental authorities are entitled to ask for cash settlement of the fine and generally will not acc