Biofuels and CII: your questions answered

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.

Access MEPC.1/Circ.905

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.

Circular MEPC.1/Circ.905 contains:

• Reporting requirements for ships using biofuels.
• An interim simplified method until a Cf reflecting its WtW GHG emissions and removals based on the LCA Guidelines is established.

It maintains that:

• Biofuels that have been certified as sustainable through an international certification system should be promoted.
• Biofuels should be eligible according to that certification when they achieve a WtW GHG emissions reduction of at least 65% compared to fossil MGO of a 94gCO2e/MJ emissions intensity (i.e., not exceeding an emissions intensity of 33gCO2e/MJ).
• Biofuels blends should be accounted for based on the weighted average of the Cf for the respective amount of fuel by energy.
   

In a footnote, IMO interim Guidelines contained in Circular MEPC.1/Circ.905 make explicit reference to:

• The ICAO's Approved Sustainability Certification Schemes 
• The CORSIA Sustainability Criteria (chapter 2) for CORSIA Eligible Fuels

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:

• The Cf value shall be calculated on the basis of the value of the fuel’s WtW GHG emissions (expressed in gCO2eq/MJ) according to the Proof of Sustainability (PoS) multiplied by its Lower Calorific Value (LCV, expressed in MJ/g) for the corresponding amount of fuel consumed by the ship.

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:

• A PoS, or a similar document from a recognized scheme. This document must indicate the WtW GHG emissions value of the fuel mentioned, expressed in gCO2eq/MJ.
• The LCV of the specific biofuel, which is expressed in MJ/g, in the form of a laboratory test result or another equivalent document.
• The bunker delivery notes (BDN), and a document confirming the biofuel’s properties, such as a certificate of fuel quality. The supplier will provide these to the ship at each bunkering operation.

Yes, you will need to revise the SEEMP Part II and SEEMP Part III, as appropriate to include, as appropriate:

• The type of fuel intended to be used  
• The proper justification and supporting documentary evidence for its assigned Cf, in accordance with the 2022 Guidelines for the development of a SEEMP (Resolution MEPC.346(78))

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: 

• Container ships
• Tankers
• Bulk carriers
• Cruise ships
• Ro-ro ships