FOSFA banned list and acceptable previous cargoes explained

The FOSFA banned list names the substances a ship's tank may not have carried as its immediate previous cargo before it loads oils and fats. The list of acceptable previous cargoes names what the tank may have carried before, when the sale contract adopts it through clause AS9. EU law and Codex Alimentarius set their own tests alongside, looking back up to three cargoes.

Operium is not a FOSFA member and holds no FOSFA approval. The lists are FOSFA's, published on its website; the previous cargo check below only looks a cargo up in them, with the edition dates shown.

Why the previous cargo of a tank matters

Codex names residues of a previous material as one route by which oils and fats in bulk become contaminated. The EU records that seagoing vessels reserved for foodstuffs are too few to serve the trade (recital 1 of Regulation (EU) No 579/2014). So edible oil goes into tanks that carried something else, and the lists decide what is tolerable.

How the FOSFA banned list and the acceptable list work

FOSFA keeps two lists, and they are not mirror images.

• The list of banned immediate previous cargoes is a negative list. A substance on it rules the tank out. Standard FOSFA contract terms apply this list unless the parties expressly agree otherwise.
• The list of acceptable previous cargoes is a positive list of foodstuffs, processing aids and other materials known to be compatible with oils and fats. It applies through the optional clause AS9: the immediate previous cargo must be on it.

Under the default terms a substance on neither list is not automatically banned; under AS9 it is rejected. Both parties need to be clear, when the sale contract is made, which list applies.

Each list comes with a flowchart. The one attached to the banned list, issued January 2021, treats a previous cargo as qualifying when it filled 60% or more of the tank. The immediate previous cargo is checked against the list whatever its volume. If it filled less than 60%, it is recorded and the check moves to the cargo before it, and so on until a qualifying cargo is reached. The summary on fosfa.org writes "> 60%"; work from the flowchart. Some restrictions reach back over the three previous cargoes, and some depend on whether the tank is stainless steel, inorganic coated or organic coated. The flowchart adds that other criteria apply, set out in FOSFA's Qualifications and Operational Procedures for ships carrying oils and fats in bulk.

The lists that count are those in force on the bill of lading date, not on the contract date. As of September 2026 the banned list is revised and effective from 1 September 2026, the acceptable list from 1 September 2025. Both are revised, so take the current edition from fosfa.org, not a saved copy. For the federation behind the lists and the contracts, see what FOSFA is and does.

What EU law requires: Regulation (EU) No 579/2014

Commission Regulation (EU) No 579/2014 of 28 May 2014 derogates from Annex II to Regulation (EC) No 852/2004 on the hygiene of foodstuffs. It lets liquid oils and fats for human consumption travel in seagoing vessels not reserved for foodstuffs, on conditions, and it repealed Commission Directive 96/3/EC of 26 January 1996, which had carried the EU's list until then (Article 4). The test differs from FOSFA's:

• Article 2(1) requires the previous cargo to be a substance, or mixture of substances, listed in the Annex.
• Article 2(2), oils and fats to be processed: in a stainless steel tank, or one lined with epoxy resin or a technical equivalent, the immediately previous cargo must be a foodstuff or on the Annex list. In a tank of other materials, the three previous cargoes must meet that test.
• Article 2(3), oils and fats not to be further processed: the tank must be stainless steel or lined with epoxy resin or a technical equivalent, and the three previous cargoes must all have been foodstuffs. The Annex list does not help here.
• Article 3: the master keeps documentary evidence of the three preceding cargoes and of the effectiveness of cleaning between them, for the competent authority on request, including after transhipment.

The Annex has been amended by Commission Regulation (EU) 2016/238 of 19 February 2016 and by Commission Regulation (EU) 2019/978 of 14 June 2019, the latter adding two substances after a European Food Safety Authority opinion. FOSFA's EU1 clause follows Article 2(2), its EU2 clause Article 2(3). The consolidated text and the Annex are on eur-lex.europa.eu.

Codex, China and NIOP

The Codex Code of Practice for the Storage and Transport of Edible Fats and Oils in Bulk, CXC 36-1987 (revised 2026), carries an acceptable list in Appendix II and a banned list in Appendix III. Cargoes on neither list may only be used if the competent authorities of the importing country agree, and the three previous cargoes in a ship's tank should be declared to the charterer.

China now applies the Codex lists. GACC Announcement No. 147 of 2025, issued 17 July 2025, requires the previous cargo to be food or on the Codex acceptable list, bars tanks that carried a cargo on the Codex banned list, and asks importers or their agents to declare the cargoes of at least three previous voyages. It repealed China's own AQSIQ rules of 2012. In the US trade, NIOP's trading rules carry their own acceptable prior cargo lists. The contract terms and the destination together decide which tests apply.

What a surveyor checks at the tank inspection

Based on the working practice of our sector specialist: 25 years in the port, 20 of them as a cargo surveyor. Previous cargoes are checked against the FOSFA and EU lists.

The checks below are a working sequence, not a single published procedure:

1. The master's declaration of previous cargoes, normally three deep, with tank numbers and fill volumes, to identify the qualifying cargo.
2. The cleaning record: method, media, temperature, duration, and evidence that cleaning was verified, not only logged.
3. The tank itself: dryness, odour, residues, scale and coating condition, plus the lines, valves, pumps and heating coils serving it.
4. Any cleanliness test the contract or the receiver calls for.
5. A report stating whether each tank is accepted or rejected. Sampling and sealing follow at loading.

FOSFA describes this work of its member superintendents as inspecting tank cleanliness, coating condition and cargo compatibility. In feed, the GMP+ scheme calls its equivalent check a loading compartment inspection (LCI). For what goes into the report, see the inspection certificate and inspection report; for the samples drawn at loading, the sampling rules used in agri trade. A cargo inspection checklist sets out the stages before, during and after loading, for dry bulk holds as well as oil tanks.

What happens when a previous cargo is not acceptable

Before loading, the tank is rejected under the flowchart; in practice it is then re-cleaned and re-inspected, or the parcel is allocated elsewhere. After loading, oil carried outside the conditions of Regulation (EU) No 579/2014 does not benefit from the derogation, and the competent authority can ask the master for the Article 3 records. If the sale contract's previous cargo clause (the standard banned-list term, AS9, or FOSFA's EU1 or EU2 clause) has been breached, the buyer may have remedies that depend on the contract and its rules; keep the declaration, the sealed samples and any letter of protest with the file for a cargo claim.

The previous cargo check looks a cargo up in the FOSFA banned list (1 September 2026), the FOSFA acceptable list (1 September 2025), the Codex list of banned immediate previous cargoes (CXC 36-1987, Appendix III, revised 2026), the Codex list of acceptable previous cargoes (CXC 36-1987, Appendix II, revised 2026) and the EU list (Regulation (EU) No 579/2014). It is a working aid: it does not replace the lists FOSFA publishes, and the contract decides which lists apply.

FOSS is software for inspection companies and the port, with a sector specialist at the table. Measurements are entered once, and samples are tracked. If your inspection paperwork is where the time goes, see FOSS or get in touch.