MEPC 80: Protect the future of your fleet with LR

The 2023 Biofouling Guidelines entered into force on the day they were adopted by MEPC, 7th July 2023. However, at this point in time, they are non-mandatory within the IMO.

Therefore, unless a flag State stipulates that these guidelines must be enforced, the shipowner may voluntarily use them. However, should one or two administrations decide to apply these Guidelines to ships entering their ports, then this may have the effect that any ship entering the ports of those Administrations would have to apply the guidelines, irrespective of their own flags position.

Noting this, it is entirely possible that this Guidance will become mandatory within the IMO in the coming years. Combined with the potential energy efficiency gains from applying the guidelines, it would be prudent to take good note of the actions set out in the Guidelines today.

The best practice recommendations for the removal of a ship's biofouling need to be considered on a case-by-case basis. LR can provide advisory services to undertake a feasibility study to determine the best technology/option for the ship’s niche areas and hull, including evaluating and ranking different technologies available.

LR is also developing test requirements for such technologies and is working with several manufacturers to evaluate their testing and performance capabilities.

The interim guidelines refer to international certification schemes for the assessment of sustainability criteria.

In certifying the biofuels, many factors are considered, such as feedstock source, direct and indirect land use change, emission during production and transportation, etc. So, it is difficult to say outrightly which biofuels meet the criteria. The only way to determine this is to look at the sustainability certificates issued by certifying bodies such as ISCC or RSB and confirm the well-to-wake emissions of that biofuel with the given value of MGO in the interim guidelines.

Any biofuel which has well-to-wake emissions of 33 gCO2e/MJ or less is considered compliant.

Please note that most of these certificates also refer to EUs Renewable Energy Directive (RED II, document ref L328/156), where typical GHG emission values have been given for various biofuel feedstocks from different production pathways.

Fuel producers, who wish their products to be certified, will get their products certified by complying with the requirements of the certification schemes. Details can be found on the relevant websites.

• ISCC: ISCC System – Solutions for sustainable and deforestation-free supply chains.
• RSB: Sustainable Development and Biomaterials  

The sustainability certification bodies investigate the whole supply chain and then assess its sustainability against different criteria such as feedstock source, direct and indirect land use change, processes involved etc.

Biofuel producers calculate GHG emissions for their industry processes that ISCC auditors then verify. So yes, the well-to-wake emissions will be different for different feedstocks and the production processes involved. 

Biofuels are made from biomass used as feedstock. In contrast, synthetic fuels are produced by chemical conversion of hydrocarbon molecules into synthetic liquid products. Depending on the feedstock and production process, a fuel from biobased feedstock can be biodiesel (biofuel) or e-diesel (synthetically produced fuel). In general, when we use the term biofuel, it is not e-fuel.  

E-fuels are synthesized from e-hydrogen made from green electricity and water electrolysis. E-fuel production must use renewable electricity derived from naturally replenished sources such as solar, wind, hydroelectric, or geothermal energy to achieve real benefits and achieve such low emissions.

Visit the zero carbon fuel monitor to learn more about future fuels

The protocol establishes verification standards for CMD devices to be tested and validated. If PSC chooses to use sampling and analysis to ensure the D2 discharge standards are followed, this is most likely to be undertaken using CMD as they offer relatively easy use and speedy analysis results. Going forwards, it is likely that for both PSC and commissioning testing use of a CMD verified as per the protocol requirements, will be the preferred option.

Unfortunately, the discussion around Carbon Capture is still in the early stages and too many unanswered questions remain. Answering these questions will depend on the industry's operations, available technology and regulatory appetite from different flags and port states, etc. 

Reducing fossil fuel emissions cannot happen instantly; there needs to be an industry-wide step change to achieve the goals we have seen set in the IMO 2023 GHG strategy. The IMO GHG strategy sets an ambition for zero or near zero emission fuels or energy sources with a 5% update by 2030, which implies that there needs to be a paradigm shift away from fossil fuels. 

As an industry, we know that the decarbonisation transition needs to start today. Steps need to be taken to enable assets operating today to move further along the decarbonisation pathway towards net zero emissions.

Carbon Capture is one of the technologies that can help existing assets in this journey to reducing GHG emissions. As such, we may find that carbon capture as a technology is time-limited as existing infrastructure and assets are replaced by newer zero-emission technologies. 

Its certainly a possibility, but until further discussions take place at ISWG-GHG 16 and beyond, its impossible to provide a definitive answer.

IMO LCA Guidelines are based on the attributional method, and the accounting principles will be based on Mass Balance (as per IPCC etc.) and not on a Book & Claim system. Between now and the next MEPC (81st session), verification/certification schemes will be defined and finalized as part of the IMO LCA Guidelines, and thus more clarity will be given on that aspect, however, it seems very unlikely that IMO will adopt a book & claim system.

The overall industry's future fuel mix will be determined mainly by the cost and availability of resources. It is known that e-fuels availability is limited by renewable energy capacity, and biofuels are limited by sustainable feedstock availability.

To assist in determining the long-term fuel options available, LR has produced The Zero Carbon Fuel Monitor, which identifies key priorities for fuel supply chain stakeholders to deliver an efficient, safe and sustainable transition to zero carbon marine fuels. An insight-based assessment of fuel readiness provides the basis for effective decision-making as the maritime sector navigates the journey to a decarbonised future.

The 2023 strategy sets a clear ambition for the uptake of zero or near-zero emission fuels or energy sources of 5% (striving for 10%) uptake by 2030 as well as the indicative checkpoints at 2030 and 2040 to reduce GHG emissions by 20% and 70% respectively. As such, this is likely to encourage the uptake of alternative fuel sources, such as biofuels, earlier within the timeline to meet these targets. 

At this point in time, impacts on the IBC Code have not been considered. However, it would be expected that the necessary consequential and supporting amendments will be proposed and agreed upon as the industry's use of alternative fuels increases, and more clarity is gained around the most commonly used fuel types. 

Every nation under the Paris Agreement is expected to submit an updated national climate action plan - known as a Nationally Determined Contribution (NDC). In their NDCs, countries will communicate actions to reduce their GHG emissions to reach the agreement's goals.

As such, each nation will have a slightly different approach to reaching the 1.5 deg C target set by the Paris Agreement, which will be dependent upon economics, population, and development of the country, to name some factors. The IMO GHG strategy sets a clear 2050 net zero target which will have global applicability.

The agreed target of reducing CO2 emissions per transport work by at least 40% by 2030 (compared to 2008) within the 2023 GHG strategy is the same as the target set in the initial GHG strategy in 2018. In this regard, this should not change or influence the agreed CII requirements. Further, the CII annual reduction factor (Z) is not yet confirmed post-2026.

The Z factor will be considered as part of the short-term measures review due for completion by 1 January 2026. However, in our understanding, the reduction factor (Z) could follow the current trend of a 2% reduction year on year to achieve the CII reduction targets set in the 2023 GHG strategy.

Zero or low-carbon fuels will have less carbon intensity, improving the ship's CII rating.

Currently, CII only applies to certain types of vessels of 5000GT or over. The applicability to other vessel types and sizes may be considered as part of the short term measures review, due for completion by 1 January 2026.

Following the MEPC80, there have been no correction factors agreed for passenger vessels and other vessel types at this stage. All the proposed CFs are being considered as part of the short-term measures review due for completion by 1 January 2026.

Within MARPOL Annex VI the EEXI enforcement is clear. CII enforcement is likely to be increased after the 2026 review. How it will be enforced will be dependent on the outcome of the discussions in the coming months.

The CII rating should be available typically within 2 months of the data reporting. The reporting and submission of the CII data for the calendar year (Jan to Dec YYYY) should be done within 3 months from the end of the calendar year (i.e, before March YYYY+1)

The amendments agreed at MEPC 80 clarify that the "total transport work" may be reported differently for different ships using metrics based on ship type.

The reporting may be done using tonne-mile and TEU-mile metrics for containerships and similarly using tonne-mile and passenger-mile metrics for passenger vessels, as appropriate (based on ballast/laden voyages). Further, the requirement to collect and report "transport work" data applies only to those ships which are required to comply under regulation 28 of MARPOL Annex VI.

The discussions on URN and Energy efficiency are at a very early stage. More details on the direction of travel for this area of work will hopefully become clearer after the expert workshop is held in September.

At the current time, there is no discussion on any development of mandatory requirements surrounding URN and Energy Efficiency. That is not to say it will not happen at some point in the future, but there is no way of knowing at this stage.