During the 2024 GREEN4SEA Athens Forum, Dr. John Kokarakis, the Technical Director at SEEBA Zone, Bureau Veritas, delivered a comprehensive presentation on the FuelEU Maritime legislation, which is mainly technical and focuses on fuels. He began by thoroughly exploring the primary objectives of the regulation, providing a detailed analysis of its framework, and offering insights into its advantages and disadvantages.
FuelEU Maritime complements the EU ETS by targeting a reduction in greenhouse gas intensity, measured as emissions per unit of energy (grams of carbon dioxide equivalent per megajoule). It promotes the use of onshore electricity supply for specific vessel types and encourages the adoption of RFNBOs—renewable fuels of non-biological origin that do not contain biogenic components.
This initiative is interconnected with other components of the Fit for 55 package. FuelEU addresses fuel demand by determining what we burn. The EU ETS regulates how much we burn. The Renewable Energy Directive governs fuel supply, and the Alternative Fuel Infrastructure Directive oversees fuel distribution.
The regulation will come into force on January 1st, 2025, and will be applicable to vessels over 5000 gt. 100% of emissions will be considered within the EU, and 50% of them if one port in the voyage is outside a Member State. The carbon intensity limit is set on the basis of an average value on the basis of the EU MRV 2020 data, which is equal to 91.16 g CO2e/MJ. This limit will be periodically reduced until it reaches 20% of the initial value in 2050.
Until December 31st, 2029, any ship with an ice class notation may request an exclusion of the additional energy required for sailing in ice conditions. Member states have the discretion to exempt voyages conducted by passenger ships to or from ports on islands with fewer than 200,000 permanent inhabitants.
Examples of voyages eligible for exemption include routes between a port in an outermost region and other outermost regions, such as the French colonies in the Caribbean.
The carbon intensity of a fuel mixture is determined using a formula that factors in various components. The reward factor (RWD), which boosts efficiency and reduces intensity when using certain types of fuel until January 1st, 2034, is included in the denominator. Burning RFNBOs (presumably specific biofuels) reduces intensity by half due to this bonus. Methane and nitrous oxides’ impact on greenhouse gases is considered via their global warming potential compared to carbon dioxide.
The calculation involves both well-to-tank and tank-to-wake phases. In the tank-to-wake phase, emission factors are straightforward, calculated by the carbon content percentage multiplied by 3.666. Biofuel emission factors are detailed in the Renewable Energy Directive, or Delegated Regulation (EU) 2021/22. For ice-class ships until December 31st, 2029, special reductions may apply. Wind-assisted propulsion can also reduce intensity based on the ratio of wind power to total power.
Different fuels have default emission factors detailed in resources like the FuelEU directive or IMO MEPC 76 working papers. However, discrepancies exist between these sources and must be harmonized for accurate calculations.
Efforts to reduce emissions involve enhancing energy efficiency, optimizing logistics, design, operations, and technology, and ultimately minimizing fuel consumption. Well-to-tank emission factors remain a critical missing link, particularly for alternative fuels, even at the International Maritime Organization (IMO) level.
Bunker delivery notes
Bunker delivery notes must contain crucial details such as the lower calorific value, the total greenhouse gas emission intensity, and certification specifying the fuel’s production pathway. For a given fuel, multiple production pathways exist, each defining unique emission factors. Blending information for all components of the blend should also be fully disclosed.
Use of RFNBO’s
Utilization of RFNBOs (renewable fuels of non-biological origin) is incentivized under the FuelEU program through the Reward Factor (RWD). Failure to achieve at least a 1% utilization rate by 2030 results in a 2% increase in requirements starting in 2034. Additionally, penalties are imposed based on the percentage of RFNBOs used by a ship.
RFNBOs are produced using hydrogen sourced from renewable energy and captured carbon. Direct air capture, though feasible, currently presents challenges due to the low concentration of carbon dioxide (0.03%) in the air compared to exhaust gases (5–6%).
Ships with compliance surpluses for a reporting period can bank this surplus for use in subsequent periods, subject to specific conditions. The surplus amount must not exceed 2% of the reference greenhouse gas intensity multiplied by energy consumption and can only be used for one consecutive period. Borrowing from future periods incurs a 10% emission penalty.
Pooling mechanisms leveraging surplus emissions can incentivize overachievers by allowing them to sell excess emissions to ships falling short. This facilitates the rapid adoption of advanced, zero-emission technologies like Efuel.
Regarding loopholes, pooling is effective in 2030, with diminishing effectiveness over subsequent years. For instance, a vessel burning green methanol could balance emissions equivalent to 11 vessels burning HFO in 2030, reducing to 5 after 5 years, and further down to 2. By then, advancements in green fuels are anticipated to make them more affordable, scalable, and accessible.
By addressing these considerations, we aim to improve transparency and encourage the adoption of sustainable fuel practices within the maritime industry.
The FuelEU Maritime Compliance Map is a valuable resource, illustrating the lifecycle emissions of various fuels—from LNG and crude oil to E-fuels and gray fuels. It’s noteworthy that when considering fuels like gray methanol, gray ammonia, and gray hydrogen, burning crude oil may prove to be a more environmentally favorable option.
Above article is a transcript from Dr. John’s Kokarakis presentation during the 2024 GREEN4SEA Athens Forum with minor edits for clarification purposes.
Explore more by watching his video presentation here below
The views presented are only those of the author and do not necessarily reflect those of SAFETY4SEA and are for information sharing and discussion purposes only.
