July 9, 2025
NorthStandard P&I Club warns of the fact that the Turkish authorities impose significant fines on any vessel causing pollution.
According to NorthStandard, fines imposed by authorities in respect of accidental pollution are, in principle, covered by P&I under rule 3.16.3, subject to shipowner’s terms of entry. In this article we highlight the Turkish authorities’ approach to pollution fines and discuss mitigating action which can be taken.
Pollution fines in Turkiye are:
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Imposed on a strict liability basis, meaning shipowners can face fines even where pollution has occurred without any negligence. Authorities use various methods to identify polluters such as photographs, video recordings, satellite images, and sample collection. However, under the regulations, fines can also be issued based solely on an official report and minimal evidence.
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Calculated on a vessel’s gross tonnage. Fines automatically triple for corporate owners (which is always the case), double in Special Environmental Protection Zones (e.g., the Marmara region), and increase tenfold for hazardous waste spills, turning minor incidents into million-dollar fines. Additionally, fines are adjusted annually based on inflation, with an increase in 2025 of approximately 19% in USD terms.
Any pollution allegation results in vessel arrest. Release is only possible via direct payment of any fine or after provision of an LOU with a specific wording as approved by the authorities.
A 25% discount on the penalty amount is granted if the fine is paid within 30 days. Although it is possible to lodge an objection within the 30 day period, lodging an objection does not prevent enforcement of the fine. In addition to fines, masters and chief engineers may face criminal investigations, often requiring legal assistance.
Recommendations
To minimize the risk of pollution and fines, shipowners should implement strict preventive measures when entering Turkish waters such as;
- closing all bilges,
- avoiding ballast operations and overboard discharges,
- and refraining from deck washing or waste disposal.
If a pollution incident occurs, operators should immediately notify the Club and seek assistance. It is essential that a local correspondent and surveyor are appointed promptly to ensure collection of all relevant evidence and to start the process of discussing provision of an LOU (something which is always subject to the discretion of the Club).
Given the severity of Turkiye’s pollution fines, shipowners are strongly advised to remain vigilant and proactive in order to avoid pollution fines by ensuring compliance with environmental regulations and implementing necessary preventive measures, NorthStandard concludes.
