Eleni Antoniadou, Lawyer at Gard P&I Club, and Neil Henderson, Senior Executive, Legal and Corporate Affairs – Industry Liaison at Gard P&I Club present three key solutions for FuelEU Maritime compliance.
Solutions for compliance
How can shipping companies comply with FuelEU Maritime? According to Gard, in the long term, it will primarily be through the use of Renewable Fuels of Non-Biological Origin (RFNBOs). To further incentivize this take-up, the energy used from RFNBOs will count twice for the vessel’s calculated attained GHG intensity.
According to the authors, in the near term the availability of RFNBOs and the number of ships capable of burning them is limited, and so other methods will be needed:
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The most likely solution is biofuels, which can be blended with conventional fuels to sufficiently reduce GHG intensity, but only if the biofuel is produced using non-food or feed crop. The bunker supplier will be required to provide a Sustainability Annex to the Bunker Delivery Note (BDN), providing the fuel carbon intensities and the required date for calculation of fuel emissions for the FuelEU obligations.
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Another solution that is gaining momentum is wind-assisted propulsion systems (WAPS). If fitted or retrofitted, the shipping company is entitled to a ‘Wind Reward Factor’, which is applied to reduce the overall GHG intensity of the energy used. No other energy efficiency technologies such as heat-recovery systems or air lubrication receive a similar reward factor.
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Shipowners will also be able to use onshore power supply (OPS) at berth, which is treated as zero-rated GHG intensity. It will be voluntary at first, but from 2030 passenger vessels and cruise ships will have to use OPS where it is available and face financial penalties for not doing so. Of course, the availability of OPS and ability of ships to use it means that this is likely to have limited take-up in the near term.
As yet, there is no reduction of GHG intensity for Onboard Carbon Capture (OCC), but this will likely be reconsidered in 2027 when the legislation is due for review.
The full version of this article has been published in Gard’s website and can be found here.