Marine Fuel Availability: FONAR Friend? in Marine Insurance P&I Club News 21/04/2026 Executive Summary The continuing fragility of the security situation in the Middle East has materially disrupted global energy and marine fuel supply chains. As a vital energy corridor, disruption to the Strait of Hormuz has already resulted in vessel congestion, sharp increases in marine fuel prices, and growing concerns among Owners and Charterers regarding the physical availability of compliant marine fuels. In this context, this article examines a number of recurring questions raised by Members since the outbreak of the Conflict, focusing on the following key operational, contractual, and regulatory risk areas: Seaworthiness and due diligence: Where marine fuel scarcity is foreseeable, inadequate voyage planning and bunkering arrangements may expose Owners to allegations of unseaworthiness on delivery or at the commencement of a voyage. Charterparty risk allocation: Disputes may arise as to which party bears responsibility for procuring compliant marine fuel, the availability of contractually nominated fuels, and what alternative procurement measures were reasonable in the prevailing circumstances. Fuel Oil Non-Availability Reports (FONARs): FONARs remain a measure of last resort under MARPOL Annex VI and are only appropriate where compliant fuel is physically unobtainable despite all reasonable efforts. High prices or commercial inconvenience alone do not justify their use, and misuse can lead to Port State Control sanctions. Deviation and operational adjustments: Decisions to deviate from customary routes, reduce speed, or alter voyage plans in order to obtain or conserve fuel must be carefully assessed against charterparty obligations and applicable liberty clauses. Unreasonable deviation may also carry insurance implications and should be discussed with the Club at an early stage. Documentation and early engagement: Members are strongly encouraged to maintain clear and contemporaneous records of fuel enquiries, voyage planning, operational decisions, and compliance efforts. Strengthening fuel quality safeguards, consideration of targeted contractual amendments, and early engagement with counterparties and the Club will be key to managing disruption-related risks and ensuring ongoing regulatory compliance. Introduction The situation in the Middle East (the “Conflict”) has deteriorated sharply following the de facto closure of the Strait of Hormuz by Iranian forces on 28 February 2026. Despite the recent announcement of a ceasefire between the U.S. and Iran, talks over the weekend failed to reach a wider peace agreement. Reports suggest that the Iranian Revolutionary Guard Corps’ (“IRGC”) intend to continue measures aimed at disrupting commercial shipping, with the U.S. in turn now threatening their own retaliatory measures. Against this backdrop, the risk of ongoing disruption, and further attacks on commercial vessels, is likely to have significant implications for marine fuel availability globally. Approximately 25% of global crude oil and 20% of worldwide LNG shipments normally pass through this corridor, making it one of the most critical maritime chokepoints in global energy logistics. The attempted closure has already caused marine fuel prices to more than double in key supply hubs, with Owners increasingly concerned not only about price volatility but also the physical availability of compliant marine fuel. As Owners and Charterers increas