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Clyde & Co: An introduction to decarbonisation in shipping

Law firm examines various IMO and EU regulations which are due to come into force over the next few years and discusses legal considerations they raise for stakeholders.

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International law firm Clyde & Co LLP on Thursday (8 September) published a market insight as part of a series of articles to examine various IMO and EU regulations which are due to come into force over the next few years with the aim of regulating and reducing shipping’s carbon footprint through various initiatives. 

Associate Kirsten Cottrell-Conacher discusses the key practical and legal considerations they raise for owners, charterers, and other stakeholders:

IMO

There are two upcoming IMO measures directed at reducing greenhouse gas emissions from ships, both added to MARPOL Annex VI in 2021. The two new measures are the Energy Efficiency eXisting ship Index (EEXI), a one-off certification assessing the design, construction, and technical features of the ship; and the Carbon Intensity Indicator (CII), an ongoing measure of how environmentally friendly a ship’s operations are. The IMO’s stated goal is to reduce the carbon intensity of all ships by 40% by 2030 and 70% by 2050 (as against 2008 levels), and EEXI and CII build on existing measures to try and achieve this.

Energy Efficiency Existing Ship Index (EEXI)

EEXI is a one-off classification of the energy efficiency of a ship’s design, construction, and technical features, and seeks to impose a minimum standard on the global fleet. A wide range of ship-types are caught by the EEXI regulations (all existing ships of 400 GT and above falling under MARPOL Annex VI) and existing vessels will be required to have their EEXI technical files prepared by the time of their next International Air Pollution Prevention (IAPP) Certificate Renewal from 1 January 2023. Newbuilds will be required to do so by their initial survey before entering service. Information from various vessel documents is used to assist in preparing the EEXI technical file, including capacity plan/lightweight certificate, the trim and stability booklet, any sea trial reports, NOx technical files, the IAPP and, for newer vessels, the EEDI (Energy Efficiency Design Index) technical file.

There is not a single, universal EEXI figure for all vessels – rather, a “required EEXI” exists based on ship type, capacity, and engine and the “required EEXI” represents the minimum standard for each ship type. Each individual ship is then ascribed a calculated “attained EEXI”. The “attained EEXI” for that ship needs to be less than or equal to the required EEXI for that ship type in order to comply with the regulations.  

The EEXI describes the ship’s anticipated carbon emissions, expressed per cargo ton and mile, taking into account factors like engine power, fuel oil consumption, and cargo capacity. These factors are all added into a formula which calculates the ship’s EEXI value. Improvements to the carbon intensity of the ship’s design and technical features will reduce its EEXI value.

While EEXI compliance does not necessarily require technical modifications to a ship, in practice this is likely to be required for many vessels in order to achieve the minimum required EEXI rating of “C” or above. The regulations do not prescribe any particular modifications or means of achieving compliance. The most popular choice of measures is Engine Power Limitation (EPL) and/or Shaft Power Limitation (SHAPOLI) as these are relatively cheap, quick, and straightforward to implement (though such modifications can have detrimental effects on speed and other performance metrics, with potentially adverse consequences for any warranties given to charterers, an issue which we will consider in greater detail in a future article in this series).

In 2021, BIMCO published a model EEXI transition clause for time charterparties, specifically addressing EPL/SHAPOLI modifications. Major charterers and/or shipowners also have their own bespoke clauses which we have seen being used, more than the BIMCO “standard” clause.

Other options which may enhance a ship’s EEXI classification include increasing cargo capacity, installing more efficient propellers and associated equipment, or potentially more radical (and expensive) alternatives such as switching to carbon-neutral fuel or introducing entirely green power technologies.

It is important to note that EEXI is a theoretical figure, based on a ship’s design and technical features, not an indicator of its actual carbon emissions. This aspect is covered by the CII.

The IMO intends (under MARPOL Annex VI Regulation 25.3) to review the effectiveness of the EEXI measures by 1 January 2026 to assess their effectiveness, and will possibly make amendments to them once there is real-world data available on the effectiveness of the measures and their practical consequences (such as what steps owners take to ensure vessel compliance; what, if any, consequences vessels with poor EEXIs face; and whether the measures result in a significant reduction of shipping’s contribution to global carbon emissions).

Note: The full article can be viewed here while the podcast series accompanying the article series can be found here

 

Photo credit: william william on Unsplash
Published: 3 January, 2022

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Bunker Fuel

Singapore: Bunker fuel sales soar by 7.5% on year in June 2025

4.59 million mt of various marine fuel grades were delivered at the world’s largest bunkering port in June, up from 4.27 million mt recorded during the similar month in 2024, according to MPA.

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Singapore: Bunker fuel sales soar by 7.5% on year in June 2025

Sales of marine fuel at Singapore port increased by 7.5% on year in June 2025, according to Maritime and Port Authority of Singapore (MPA) data.

In total, 4.59 million metric tonnes (mt) (exact 4,594,700 mt) of various marine fuel grades were delivered at the world’s largest bunkering port in June, up from 4.27 million mt (4,274,900 mt) recorded during the similar month in 2024.

Deliveries of marine fuel oil, low sulphur fuel oil, ultra low sulphur fuel oil, marine gas oil and marine diesel oil in June (against on year) recorded respectively 1.70 million mt (+8.6% from 1.56 million mt), 2.31 million mt (-7.2% from 2.33 million mt), 1,900 mt (from zero), 4,500 mt (-88% from 8,000 mt) and zero (from zero).

Singapore: Bunker fuel sales soar by 7.5% on year in June 2025

Bio-blended variants of marine fuel oil, low sulphur fuel oil, ultra low sulphur fuel oil, marine gas oil and marine diesel oil in June (against on year) recorded respectively 38,800 mt (+671.7% from 2,500 mt), 114,300 mt (+97.9% from 45,400 mt), zero (from zero), zero (from zero) and zero (from zero). B100 biofuel bunkers, introduced in February this year, recorded 1,000 mt of deliveries in June.

LNG and methanol sales were respectively 55,400 mt (-7.8% from 51,700) and zero (from zero mt). There were no recorded sales of ammonia for the month and so far in 2025.

Related: Singapore: Bunker sales volume raises to year record high of 4.88 million mt in May
Related: Singapore: Bunker fuel sales increase by 4% on year in April 2025
Related: Singapore: Bunker fuel sales increase by 0.5% on year in March 2025
Related: Singapore: Bunker fuel sales down by 8.1% on year in February 2025
Related: Singapore: Bunker fuel sales down by 9.1% on year in January 2025

A complete series of articles on Singapore bunker volumes reported by Manifold Times tracked since 2018 can be found via the link here.

 

Photo credit: Maritime and Port Authority of Singapore
Published: 15 July 2025

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Alternative Fuels

ITOCHU orders world’s first ammonia bunkering vessel for Singapore demonstration project

Company contracted Sasaki Shipbuilding to build the 5,000 m3 vessel and Izumi Steel Works to construct an ammonia tank plant that will be loaded onto the vessel, which is expected to be delivered in 2027.

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ITOCHU orders world’s first ammonia bunkering vessel for Singapore demonstration project

ITOCHU Corporation (ITOCHU) on Monday (14 July) announced that it recently signed a shipbuilding contract for the construction of a 5,000 m3 ammonia bunkering vessel with Sasaki Shipbuilding. 

The company also announced an agreement regarding the construction of an ammonia tank plant that will be loaded onto the vessel with Izumi Steel Works. 

These agreements were signed by Clean Ammonia Bunkering Shipping Pte Ltd (CABS), a wholly owned Singapore-based specific purpose company of ITOCHU. 

In relation to this, CABS has concluded a financing agreement with The Hiroshima Bank for financing a part of purchase price of the vessel.

The agreements were concluded to pursue the Demonstration Project for Bunkering Ammonia as Marine Fuel in Singapore adopted by the Ministry of Economy, Trade and Industry in Japan as part of the Global South Future-oriented Co-Creation Project (large-scale demonstration in ASEAN member states). 

Going forward, with an eye toward the demonstration of ammonia bunkering in Singapore after building the world’s first newbuilding ammonia bunkering vessel, ITOCHU said efforts will be made to facilitate concrete discussions with the maritime stakeholders, including the port authority in Singapore, the Maritime & Port Authority of Singapore (MPA), and the fuel producers, while obtaining support from the Japanese Government.

The vessel is to be flagged under the Singapore Registry and is expected to be delivered in September 2027.

ITOCHU will establish a safe offshore bunkering operation of ammonia as marine fuel by way of ship-to-ship transfer through the development and construction of the vessel and demonstration. 

Then, by utilising the vessel, ITOCHU will establish connection between the first movers in clean ammonia production and the first movers in the ammonia-fueled vessels and secure initial demand for ammonia as marine fuel, aiming at the commercialisation of ammonia bunkering business in Singapore and expansion of similar business model to major maritime transportation points around the world, including Spain (Strait of Gibraltar), Egypt (Suez Canal) and Japan.

 

Photo credit: ITOCHU Corporation
Published: 15 July 2025

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Business

S@S Week 2025: Singapore conducts chemical spill exercise to gear up for methanol bunkering

Exercise simulated a methanol spill from a collision involving a methanol-carrying tanker off Singapore’s southern coast, triggering a multi-agency response which included spill containment.

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RESIZED bunker tanker singapore

The Maritime and Port Authority of Singapore (MPA) on Tuesday (15 July) conducted a multi-agency chemical spill exercise to strengthen Singapore’s operational readiness, as part of the International Safety@Sea (S@S) Week. 

MPA is organising the 12th edition of the S@S Week, with this year’s event being the international edition, taking place from 15 to 18 July 2025. 

Conducted off Singapore’s southern coast, the exercise involved 11 vessels and over 150 personnel from more than 10 government agencies and industry partners. Mr Murali, Mr Dominguez and Secretary-General, International Organization for Marine Aids to Navigation, Mr Francis Zachariae, observed the exercise.

The exercise simulated a methanol spill from a collision involving a methanol-carrying tanker, triggering a multi-agency response. This included coordinated efforts for spill containment and the evacuation of injured crew. A range of drone-enabled technologies was trialled during the exercise, including 3D imaging to assess vessel damage and a water curtain misting system to limit the spread of chemical plumes. An Uncrewed Surface Vehicle was also deployed to monitor air quality, reducing the need for responders to enter hazardous zones to perform such monitoring. The Maritime Digital Twin and chemical plume modelling tools were used to enhance situational awareness and support decision-making throughout the exercise.

The exercise is part of MPA’s broader preparations for methanol bunkering and provided a valuable opportunity for agencies and industry partners to better understand the safety and operational challenges, and potential solutions, in handling alternative fuels. Following an open call in March 2025, MPA has received 13 applications for methanol bunker supplier licenses, reflecting strong industry interest in supplying methanol on a commercial scale in Singapore. MPA is evaluating the applications and targets to issue the licenses in Q4 2025, which will cover the period from 1 January 2026 to 31 December 2030. 

Themed ‘The Future of Maritime Safety: Navigating the Next Frontier’, the annual event brings together local and international maritime experts, and the maritime community to promote awareness and facilitate discussions on maritime safety. 

Speaking at the opening today, Mr Murali Pillai, Senior Minister of State, Ministry of Law and Ministry of Transport, said that the maritime sector is facing increasingly complex global challenges, including heightened geopolitical tensions, climate change, and rapid transformation in digitalisation and decarbonisation. He highlighted that we can tackle these challenges by (i) equipping our workforce for future challenges, (ii) harnessing collective expertise through close collaborations and partnerships, and (iii) drawing upon technology and innovation to augment our capabilities. 

In his keynote address, Mr Arsenio Dominguez, Secretary-General of the International Maritime Organization (IMO), underscored the need for robust safety frameworks and regulations as the maritime landscape evolves. He cited Maritime Autonomous Surface Ships and new ship designs and systems using sustainable marine fuels as examples of how the maritime sector is transforming and outlined IMO’s priorities in those areas. Mr Dominguez also highlighted the importance of government-industry collaboration and initiatives like the Safety@Sea Singapore Campaign to foster a safety-first culture at sea.  

This year’s conference features 19 speakers across three plenaries. Discussions will focus on issues shaping the future of maritime safety, including lessons learned from past incidents, and the human element in ensuring safety as the industry transforms. A new Safety@Sea Community Conversations event will also bring together representatives from shipping companies, regional ferry operators, harbour craft operators and terminal operators to share their experiences and efforts in fostering a safety culture in their organisations. 

Over 1,800 participants from more than 40 countries are expected to participate in the week’s sessions. Other highlights include the Responders Plus Programme (RPP) Maritime Workshop jointly organised by MPA and the Singapore Civil Defence Force, and two safety forums organised by the MPA-Harbour Craft and MPA-Pleasure Craft Safety Work Groups to promote safety awareness and best practices within the local maritime community. 

MPA is also enhancing safety across other areas of port operations. In collaboration with Skyports Drone Services, TFG Marine and CBS Ventures, MPA and the partners will complete Singapore’s first shore-to-ship drone trials for delivery and retrieval operations from bunker tankers later this week. 

The use of drones reduces reliance on harbour craft for such operations, improving efficiency while reducing pollution and congestion. 

It also minimises safety risks by removing the need for crew to handle and transfer heavy items between the ship and shore using harbour craft. Safety considerations, including the management of electrostatic discharge risks during the drone operations, are carefully reviewed in preparation for the trials. 

Findings from these trials will inform the development of safety protocols and an operational framework to support the phased implementation of this new maritime service.

 

Photo credit: Manifold Times
Published: 15 July 2025

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