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DNV on Fuel EU Maritime: How to prepare for compliance

After the release of the FuelEU Maritime Monitoring Plan online form in mid-May, DNV recommends that shipowners begin preparing their plans as the deadline of 31 August is approaching fast.

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DNV on Fuel EU Maritime: How to prepare for compliance

Classification society DNV on Monday (6 May) published a technical and regulatory news to provide more details on FuelEU Maritime and how ship owners and managers can prepare for it:

FuelEU Maritime sets requirements on the well-to-wake GHG intensity of energy used for ships trading in the EU/EEA from 1 January 2025. The first step is to prepare and submit a monitoring plan to an accredited verifier by 31 August 2024. This statutory news provides you with more details on what you need to prepare.

Summary of the FuelEU Maritime GHG intensity requirements

From 1 January 2025, for ships trading in or to/from the EU/ EEA irrespective of flag, the annual average GHG intensity of energy used on board needs to be below a defined level. The GHG intensity is measured as GHG emissions per energy unit (gCO2e/MJ) and includes carbon dioxide (CO2), methane (CH4) and nitrous oxide (N2O).

In addition to emissions from energy use on board the ship, GHG emissions are calculated in a well-to-wake perspective, including emissions related to the extraction, cultivation, production and transport of fuel. The regulation includes provisions for crediting ships using wind-assisted propulsion.

The GHG intensity requirements are set as a percentage reduction relative to a 2020 reference value of 91.16 gCO2e/MJ. The percentage reduction requirement increases gradually every five years to 2050 – meaning, for example, that it stays at 2% from 2025 to end-2029:

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Voyages, scope

The FuelEU Maritime GHG intensity requirements apply to 100% of energy used on voyages and port calls within the EU/ EEA, and 50% of energy used on voyages into or out of the EU/EEA. To avoid evasive behaviour, container ships stopping in transshipment ports outside the EU/EEA, but less than 300 nautical miles from an EU/EEA port, need to include 50% of the energy for the voyage to that port as well, rather than only the short leg from the transshipment port. 

The GHG intensity requirements apply to ships above 5,000 GT transporting cargo or passengers for commercial purposes. It does not apply to offshore ships. The scope could change as part of the scheduled review by the end of 2027.

FuelEU Maritime also sets requirements on the use of shore power for container and passenger ships from 2030. More details on this part of the regulation can be found in the References.

Compliance process

Responsible shipping company

The requirements apply to the shipping company, which is the shipowner or any other organization or person, such as the manager or the bareboat charterer, who has assumed responsibility for the operation of the ship, including duties and responsibilities imposed by the ISM Code.

As opposed to EU ETS, the responsible company under FuelEU Maritime must be the ISM company and cannot be retained by the registered owner unless the owner is also the ISM company. This implies that the responsible company for a ship may not be the same for EU ETS and FuelEU Maritime. Each responsible company will need to be registered with an administering state, which is the same as the Administering Authority for EU ETS compliance.

In the event of a change of company, the shipping company has the responsibility – on 31 December in any given year – for compliance for the whole calendar year. However, previous companies are required to report and verify energy use and emissions as soon as possible after the changeover.

Pooling of compliance

FuelEU Maritime includes the option to attain compliance across a fleet of ships, even if they belong to different companies. This means that each individual ship does not need to achieve the required GHG intensity but can rely on other ships to achieve a combined level of GHG intensity below the requirement.

Banking and borrowing of compliance surplus

If a ship has an average GHG intensity below the requirement, the surplus emission amount (compliance surplus) can be banked for use in the subsequent compliance period. Similarly, a ship can borrow advance compliance surplus from a subsequent period, limited to 2% and only for two consecutive periods, and with a 10% penalty on the borrowed compliance surplus for the subsequent period.

Penalties

Ships that have a higher GHG intensity than the requirement must pay a penalty corresponding to its compliance deficit, measured as the difference between the required and actual GHG intensity, multiplied by the energy use. The penalty is progressively increased if the ship has a compliance deficit for two or more consecutive reporting periods. The compliance deficit is calculated into energy based on the actual GHG intensity of the ship, applying a penalty of €2,400 per tonne VLFSO energy equivalent, or about €58.50 per GJ of non-compliant energy use. Hence, the penalties can be significant.

Reporting and verification

The energy use and emissions will be reported and verified through a scheme which is separate from the existing EU Monitoring, Reporting and Verification (MRV) system. However, elements from the MRV regulation can be reused for the purpose of the FuelEU Maritime regulation.

By 31 August 2024, the FuelEU Maritime Monitoring Plan needs to be submitted to a verifier (such as DNV), describing the method for monitoring and reporting of the data required under this regulation. This plan comes in addition to the current MRV Monitoring Plan, but part of this can be reused.

Vessels trading in the EU/EEA countries shall have the approved FuelEU Maritime Monitoring Plan on board before 1 January 2025.

How to start FuelEU Maritime preparations

The deadline of 31 August is approaching fast, and early preparation is strongly recommended!

Step 1: Prepare your FuelEU Maritime Monitoring Plan, with complementing documentation.

DNV will make the FuelEU Maritime Monitoring Plan online form available to our customers in mid-May 2024 (DNV customers will be notified by email). DNV’s existing EU MRV customers will be able to base this plan on their verified MRV plans.

Step 2: Copy the plan of other vessels in your fleet.

You will also be able to copy all the sections of the FuelEU Maritime Monitoring Plan between the vessels in your fleet, like the MRV Monitoring Plan online form but in an extended way.

Step 3: Submit the plans to DNV for verification after EU documents are published.

Submitting the Monitoring Plans to DNV for verification will not be possible before the official EU documents have been published, scheduled for the end of Q2 2024. This would leave July and August for submission of the Monitoring Plans to the verifier. DNV will notify its customers when the submission can be performed.

Other useful information about the preparation of FuelEU Maritime:

Requirements for providing new documents relating to the FuelEU Monitoring Plan verification highly depends on the ship type:

  • For passenger/container vessels, some documentation related to onshore power supply equipment will be required.
  • If your vessels do have any other equipment like fuel cells, zero-emissions technology or wind-assisted propulsion installed on board, documentation to confirm that would also be required before plan verification.

The companies shall also specify the established total electrical power demand of the ship at berth. By default, this would be based on the main engine (ME) power, but it can also be taken from the ship’s electrical load balance/study. These documents would also have to be provided by non-DNVclassed vessels if the non-default option is chosen.

The Continuous Synopsis Record and Safety Management Certificate of the vessel might also be required to confirm the company in charge of the vessel.

Companies must also complement the control system and data gap procedures to include the additional data to be monitored and reported for the purpose of the FuelEU Maritime regulation. The FuelEU Monitoring Plan online form will therefore also contain the outline of the overall control system creator. This new requirement, coming from both the FuelEU Maritime regulation and the revised MRV regulation, states that companies need to describe their data flow processes from the emissions measurement to data compilation. Furthermore, they need to describe the potential impact and probability of incidents which may happen at each step and define the control activities mitigating the risk such incidents might have.

DNV requests that the above information be provided in a practical, digital format to support MRV Emission Report verification and FuelEU Maritime report verification. Implementing regulations covering the FuelEU Monitoring Plan verification activities strictly requires this information to be provided before the start of the assessment of the plan.

Recommendations

  • After the release of the FuelEU Maritime Monitoring Plan online form in mid-May, DNV recommends that shipowners begin preparing their plans. This draft plan can then be copied for other vessels in their fleet. Submitting these plans to DNV for verification can only be performed after the official EU documents have been published, scheduled for the end of Q2 2024.
  • We encourage our customers to attend our “Ask the Expert” webinar taking place on 14 May 2024 (invitation will be sent via email). There we will discuss FuelEU Maritime and show how to comply with regulations using DNV's digital tools.
  • Review commercial contracts to define how compliance is managed and compensated in the maritime value chain.

 

Photo credit: DNV
Published: 7 May 2024

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Bunker Fuel

Cost-efficient strategies can significantly cut price of FuelEU Maritime compliance, says DNV

Adoption of the most cost-effective strategy can result in savings of up to 16% or USD 21 million over a vessel’s lifetime compared to using Bio-MGO as a compliance option, according to new DNV white paper.

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Classification society DNV on Thursday (5 December) said compliance with FuelEU Maritime requirements will be expensive but applying certain strategies can significantly reduce the cost.

This was one of the main highlights of its latest white paper outlining FuelEU Maritime requirements and compliance strategies for shipowners. 

Effective from 1 January 2025, the rules mandate stringent greenhouse gas (GHG) emission intensity requirements for ships over 5,000 gross tonnage (GT) transporting cargo or passengers for commercial purposes in the EU/ EEA. GHG emissions are calculated from a well-to-wake perspective. In addition to emissions from onboard combustion, this calculation also includes emissions related to the extraction, cultivation, production, and transport of the fuel. 

The regulation includes provisions for crediting ships using wind-assisted propulsion.

The DNV paper provides shipowners with insights to reduce compliance expenses and avoid major penalties. It contains a comprehensive overview of the regulation, including a case study which highlights a range of different compliance strategies. 

This shows how the adoption of the most cost-effective strategy can result in savings of up to 16% or USD 21 million over a vessel’s lifetime compared to using Bio-MGO as a compliance option.

Knut Ørbeck-Nilssen, DNV Maritime CEO, said: “It is essential that shipowners understand the requirements and compliance options related to the FuelEU Maritime regulation to make informed business decisions. Adopting a cost-efficient strategy with the right combination of measures can help shipowners reach compliance at reduced costs.

“Just paying the penalty could prove a more costly option. All parties must understand their potential obligations and privileges, and how these might affect their commercial and compliance agreements. Crucial to this is verified emissions data, which can maintain operational and commercial integrity across the maritime value chain.”

The report provides recommendations for shipowners including securing long-term fuel agreements and implementing energy efficiency measures. It also recommends considering pooling as a mechanism for sharing and optimizing costs. This is underpinned by a call to begin preparations immediately. The report also highlights how, by leveraging digital tools, maritime stakeholders can access verified emissions data, a key factor in compliance and maintaining both operational and commercial integrity throughout the value chain.

A key point emphasized in the report is that the International Maritime Organization is also set to introduce similar regulations in the near future, with a net-zero framework expected to be adopted in the fall of 2025 and come into force around mid-2027.

It is absolutely essential that shipowners understand the requirements and compliance options related to the FuelEU Maritime regulation so that they are equipped to make informed business decisions. Adopting a cost-efficient strategy with the right combination of measures can help shipowners reach compliance and significantly reduce costs.

“Doing nothing and paying the penalty could prove to be a costly option. All parties must understand their potential obligations and privileges, and how these might affect their commercial and compliance agreements. Crucial to this is verified emissions data, which can maintain operational and commercial integrity across the maritime value chain.”

The report provides recommendations for shipowners including securing long-term fuel agreements and implementing energy efficiency measures. It also recommends considering pooling as a mechanism for sharing and optimizing costs. This is underpinned by a call to begin preparations immediately. The report also highlights how, by leveraging digital tools, maritime stakeholders can access verified emissions data, a key factor in compliance and maintaining both operational and commercial integrity throughout the value chain.

A key point emphasized in the report is that the International Maritime Organization is also set to introduce similar regulations in the near future, with a net-zero framework expected to be adopted in the second half of 2025 and come into force around mid-2027.

Note: The full whitepaper titled ‘FuelEU Maritime: Requirements, compliance strategies, and commercial impacts’ by DNV can be downloaded here.

 

Photo credit: DNV
Published: 6 December, 2024

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Alternative Fuels

DNV: Nordic shipping roadmap urges for government action to close fuel transition cost gap

Nordic Roadmap project has unveiledFuel Transition Roadmap for Nordic Shipping, which identified three main barriers to uptake of zero-emission bunker fuels in the region.

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DNV: Nordic shipping roadmap urges for government action to close fuel transition cost gap

The DNV-led Nordic Roadmap project has unveiled the Fuel Transition Roadmap for Nordic Shipping, a comprehensive document outlining a decarbonization strategy for the region.

According to the classification society, the report urged Nordic ministers to take immediate action to support the industry in achieving its goals by closing the cost gap associated with the fuel transition. 

Its findings and recommendations were officially presented to Nordic ministers today at a High-Level Conference on Green Shipping in the Nordic Region, held in Copenhagen.

Alongside their commitment to global maritime emission reduction targets set by the IMO, the Nordic countries have also pledged to meet ambitious regional climate targets for shipping. 

These include early commitments to net-zero emissions by 2050, advancing a sustainable ocean economy and green transition, cooperation on transport, infrastructure and energy supply, and the establishment of green shipping corridors.

To decarbonize, shipping will need to switch to zero-emission fuels and the Roadmap strategy identified three main barriers to their uptake in the region:

  • Demand and costs – linked to the lack of demand for zero-emission shipping and cost-competitiveness of zero-emission fuels. 
  • Fuel availability – referring to the lack of onshore development of the supply chain, including fuel production and sourcing of raw materials, distribution, and bunkering infrastructure. 
  • Technology and safety – referring to the low maturity level of fuel technologies and safety regulations, both onshore and onboard vessels.

The report goes on to outline seven building blocks, broken down further into 20 specific actions to be taken towards 2030, to overcome the interlinked barriers. These represent specific work packages that governments and industry stakeholders must collaborate and work on in parallel to upscale the use of zero-emission fuels. 

The key recommendations of the Roadmap highlight the urgent need for government action to bridge the cost gap for zero-emission fuels and to accelerate the implementation of competitive tenders for green shipping corridors. The strategy envisions the first corridor becoming operational by 2025, followed by three more by 2026, and an additional six by the end of 2028. An immediate priority is to develop a plan for the regional integration of fuel production and infrastructure. 

Ms. Ida Heimann Larsen, Deputy Secretary General of the Nordic Council of Ministers, said: “The Nordic Council of Ministers is proud to have helped bring about this comprehensive and ambitious public-private cooperation.”

“And we will continue to support the advancement of the 7 key building blocks of the Road Map as part of a wider, cross-sectoral focus on the green transition of our blue economy. These are important stepping stones on our path towards making the Nordic region the most sustainable in the world.”

Knut Ørbeck-Nilssen, CEO Maritime, DNV, said: “We call on Nordic governments to act swiftly on the urgent measures identified in the Fuel Transition Roadmap for Nordic Shipping. Doing so will give the industry confidence to invest in ships capable of running on zero-emission fuels, and the fuel infrastructure needed to support them.”

“Cross border and value chain collaboration will be crucial in enabling the industry to overcome key barriers and to meet the ambitious decarbonization targets. By leading the way, the Nordics can not only drive value creation and boost exports but can also play a key role in the global fuel transition.”

Bjarne Foldager, Senior Vice President and Head of Two-Stroke Business, Denmark, MAN Energy Solutions, said: “This Roadmap is a worthy initiative and, in tandem with other global decarbonisation efforts, represents a concrete way for Nordic shipping to collaborate and push decarbonisation through – among other parameters – the adoption of zero-emission fuels and green corridors.”

“At MAN Energy Solutions, we welcome the opportunity to work with like-minded partners and are more than happy to bring our expertise within marine propulsion and alternative fuels to the table in the pursuit of net zero.”

The Roadmap is developed by the project team led by DNV with members from MAN Energy Solutions, IVL Swedish Environmental Research Institute, Chalmers University of Technology, Menon Economics, and Litehauz, and in collaboration with more than 60 industry partners.

The Nordic Roadmap project started in 2022 and is funded by the Nordic Council of Ministers. It aims to reduce key barriers to the uptake of zero-emission fuels and develop a common roadmap for the whole Nordic region towards zero-emission shipping.

Note: The full strategy can be read here.

 

Photo credit: DNV
Published: 5 December, 2024

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LNG Bunkering

Bureau Veritas classifies three LNG bunkering vessels

The first is an 18,600 m3 vessel for Ibaizabal Group at Hudong Zhonghua, and the second and third are 18,000 m3 vessels for Hercules Shipping, shipping arm of Peninsula, at Hyundai Mipo Dockyard.

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Bureau Veritas classifies three LNG bunkering vessels

Bureau Veritas Marine & Offshore (BV) on Tuesday (3 December) announced the classification of three new LNG bunker vessels, including one 18,600 cubic metre (m3) vessel for Ibaizabal at Hudong Zhonghua and two 18,000 m3 vessels for Hercules Shipping, shipping arm of Peninsula at Hyundai Mipo Dockyard, which will be delivered from 2026. 

“The vessels further BV’s collaboration with world-leading shipbuilders, charterers and yards on major LNG projects, supporting the maritime industry as it transitions to the use of more sustainable fuels,” it said on its website. 

Bureau Veritas classifies three LNG bunkering vessels

The new vessels join a list of 18 BV-classed LNG bunkering vessels in service, with four more scheduled for delivery in 2025 and 2026. They add to the important supply of LNG as fuel and help ensure shipbuilders and operators remain compliant and on course to meet global emissions targets. 

BV has now classified around 35% of the world’s bunkering ships in service and approximately 50% of the order book to date.

Bureau Veritas classifies three LNG bunkering vessels

While LNG remains an essential part of the current maritime energy landscape, methanol and ammonia are increasingly viewed as a fuel that could accelerate decarbonisation efforts. BV is already leveraging its expertise in LNG to facilitate the industry's shift to other clean fuels, exploring how lessons from LNG can be applied to methanol and ammonia’s production, transport, and eventual use as a maritime fuel. 

Bureau Veritas has supported developments that will pave the way for the broader uptake of ammonia as a fuel on land and at sea. It recently granted an Approval in Principle (AiP) to Dalian Shipbuilding for its liquid ammonia bunkering vessel design and partnered with Hanwha Ocean and Naftomar on a joint development project to develop large ammonia carriers with an ammonia fuel-prepared design. 

On methanol projects, BV is also actively involved in a selected class of several bunkering tankers in Europe and Singapore and numerous methanol fuel projects, mainly in chemical tankers and container ships.

 

Photo credit: Peninsula and Ibaizabal
Published: 5 December, 2024

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