1 Introduction

Pollution damage caused by bunker oil is covered by the CLC 1992 only where it is caused by bunker oil of tankers, whether loaded or in ballast. The compensatory regime ensured by the CLC 1992 and the Fund Convention, extended generally to hazardous and noxious substances by the HNS Convention 1996 as amended by the Protocol of 2010, left a gap in respect of damage caused by bunker of dry cargo ships, that was excluded from their scope of application, even though bunker oil of dry cargo ships as well as of passenger ships, that in large ships can be of thousands of tons,1 can cause considerable pollution damage. That gap has been filled by the International Convention on Civil Liability for Bunker Oil Pollution Damage, adopted on 23 March 2001 and entered into force on 21 November 2008. As of July 2014, there were 77 States Parties to this Convention.2