Abstract: An improved product transfer system is disclosed for a turret moored FPSO. A swivel stack torque tube is provided such that the swivel stack can be recessed below the manifold decks, but still allow swivel torque reactions to be transferred to the ship structure. Recessing of the swivel stack downwardly with respect to the manifold decks reduces the height of the access structure and locates the swivel stack center of gravity closer to the center of gravity of the vessel. This arrangement results in reduced loads to the turret structure, which supports the swivel stack and reduced height and size of the access structure for the swivel stack.