Issuing agency: Bureau Veritas Marine & Offshore
Column: Business Insights
source: https://marine-offshore.bureauveritas.com/insight/business-insights/biofuels-and-cii-your-questions-answered
Biofuels are both versatile and widely available, providing many benefits to shipowners. They can be used on most ship types, with no significant modification needed, and can be blended with fossil fuels for an immediate reduction in CO2 emissions.However, their full benefit is best judged from a well-to-wake (WtW) approach, whereas IMO’s Carbon Intensity Indicator (CII) is defined on a tank-to-wake (TtW) basis. This has led the IMO to approve "Interim guidance on the use of biofuels under regulations 26, 27 and 28 of MARPOL Annex VI," also known as Circular MEPC.1/Circ.905.MEPC.1/Circ.905 aims to assist with the calculation for IMO DCS and CII for ships using biofuels. Bureau Veritas is here to answer key questions on this guidance.
The CII is defined in the IMO instruments on a TtW basis. Its reference values and the ship's A to E rating boundaries have been established from the fuel consumption collected for 2019. The fuel consumption was then transformed into CO2 emissions using the EEDI 2018 guidelines' Cf emission factors (MEPC 308(73)) and the rating boundaries are defined using a statistical distribution for a given ship category.The Cf is explicitly defined as TtW, and not accounting for the WtW life cycle of fuels may be detrimental to certain biofuels.
Some delegations at IMO have called for greater recognition of the importance of biofuel as a lever to decarbonization. They are asking for more clarity and guidance from the IMO to ensure biofuels get a level playing field in IMO DCS reporting and attained CII calculation.IMO’s comprehensive guidelines on the life cycle greenhouse gas (GHG) intensity of marine fuels (LCA guidelines) have yet to be finalized. But in the meantime, these delegations have stressed biofuels’ ability to reduce GHG emissions in the short term, their current availability, and their ability to assist in CII compliance. Some shipowners are already prepared to invest in accommodating biofuel bunkering, and delegates say such investments to improve compliance performance should be incentivized.
In a footnote, IMO interim Guidelines contained in Circular MEPC.1/Circ.905 make explicit reference to:
Nevertheless, other international certification schemes (e.g., ISSC EU) are likely to be accepted, though subject to Flag agreement.
The date of application for Circular MEPC.1/Circ.905 was 1 October 2023. Biofuels used from that date could be accounted and reported in IMO DCS providing they comply with the provisions of the Circular and are duly declared in the Ship Energy Efficiency Management Plan (SEEMP) Part II and Part III, as appropriate.N.B.: Flag Administrations may have different policies that allow crediting of the use of biofuels from an earlier date (e.g., beginning of the 2023 calendar year).
For the purpose of regulations 26, 27, and 28 of MARPOL Annex VI:
Please refer to examples of biofuel and biofuel blends Cf calculations in Annex I.
The Cf of blended biofuels is to be based on the weighted average of the Cf for the amount of fuel by energy.Please refer to examples of biofuel and biofuel blends Cf calculations in Annex I.
This is not explicitly referenced in Circular MEPC.1/Circ.905 and is therefore subject to the agreement of the Flag.
For the verification of biofuel use and consumption, the following must be provided:
Yes, you will need to revise the SEEMP Part II and SEEMP Part III, as appropriate to include, as appropriate:
Without a specific reporting category from the IMO1 or specific instruction from the Flag, biofuels should be reported under "Other," specifying a user-defined description and Cf value.
For blends, the Guidelines mention the overall value that must be determined (based on the weighted average of the Cf for the respective amount of fuel by energy). Therefore, it is assumed that the biofuel blend data must be entered as a single product, and thus a similar approach to the above may be used to indicate the type of blend.
1Reference: MEPC 79/6/1 para.25 & MEPC 81/6 para.13.2
Please refer to Annex II for impact studies on 5 vessel types:
Example of a PoS emitted by ISCC according to EU Renewable Energy Directive (EU 2018/2001 – RED II) Requirements see here
Bureau Veritas has developed significant expertise to address fuel certification, notably leveraging our track record in ISCC or RedCert schemes. Further to this, we can also support fuel quality assessments with the help of Verifuel’s fuel experts.We’re by your side to help you navigate the decarbonization challenge. As IMO guidelines and requirements evolve, our experts are here to explain what these changes mean for your vessel, so you can make the right decisions.