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GARD: The EU Emission Trading System – are you ready?

Since the EU ETS has been agreed, vessel owners and charterers that may trade within the EU should ensure they are prepared to comply with its requirements in 2024.




GARD The EU Emission Trading System

Maritime protection and indemnity (P&I) club Gard on Wednesday (7 December) published an article discussing on the EU Emission Trading Scheme. The following is an excerpt of the article:

There has been increasing interest in expanding existing domestic emission trading schemes to also cover international shipping. There is now agreement in the EU on how the EU’s emission trading system will be applied to shipping from 2024. Owners and charterers should start to think about how they are going to deal with its requirements.

On a nation state level, governments can impose taxes on the sources of pollution at the point of production or sale. An example is petrol, with the aim that the taxes generated will cover the cost of dealing with the resulting pollution and incentivise reduced consumption. The difficulty in international shipping is that if just a few governments took this approach for bunker fuel, the buyers would likely adjust their arrangements so that they avoided bunkering at the taxed ports. Therefore, for a sales tax on bunker fuel to be effective, governments of all the major bunkering ports around the world would need to coordinate and agree to tax bunker fuel in the same way. With such cooperation looking very unlikely in the near term, and IMO discussion of a carbon tax still in its early stages, governments are now looking at imposing costs on emissions, rather than on fuel at the point of sale.

An emission trading scheme (ETS) is a tool that governments and regulators are expected to use increasingly often in the fight to reduce the pollution created by international shipping. The central idea behind an ETS is to have a market mechanism to ensure that “the polluter pays” – the payment being for the environmental and social cost of pollution, its clean-up cost and potentially also research into technology that will reduce or remove it. Of course, increasing the cost of pollution also creates an incentive to generate less of it.

For this reason, there has been growing interest in expanding existing emission trading schemes to include international shipping, including in the EU, China and Japan. The basic idea of an ETS is that a capped number of emission permits are bought and sold on the market, with emitters having to purchase and surrender enough allowances to cover their emissions. The price of the allowances will change over time to reflect the balance of supply and demand, and emitters then are incentivised to find the cheapest (ie. most efficient) ways to reduce emissions.

The EU Emission Trading Scheme 

Launched in 2005, the EU’s Emission Trading System works as a “cap and trade” scheme where emitters of CO2 in certain sectors have to purchase allowances to cover their carbon emissions during the relevant trading period. The number of allowances at any one time are fixed, but they generally reduce each year, so that emissions within the EU also fall.

How the scheme will be applied to shipping has beenunder discussion for some time, but there now seems to be agreement between the European Parliament, the Council of Ministers and the European Commission thatthe key features will be:

  • Application to all vessels over 5,000 GT trading within EU waters, irrespective of flag
  • Start date of 1 January 2024 (pushed back from 1 January 2023)
  • A phased-in implementation, with 40% of emissions covered by the system during 2024, 70% for 2025 and 100% for 2026.
  • All intra-EU voyage emissions to be covered by the scheme
  • 50% of EU in-bound/out-bound voyage emissions will be covered
  • The ‘shipping company’ (defined as owner, manager or bareboat charterer) will be responsible for surrendering the allowances
  • The system will cover carbon dioxide, methane and nitrous oxide
  • 30 April deadline for surrender of allowances for the previous calendar year -for example, 30 April 2025 deadline for 2024 emissions
  • Non-compliance can lead to penalties and expulsion orders

Several parts of the scheme are still unclear, and questions have been raised about two particular areas relating to shipping. First, in the Special Rapporteur’s report of 24 January 2022, it says that where a ship is on charter and the owner is not responsible for purchasing fuel or making decisions about the vessel’s speed, cargo or route, then:

“… a binding clause should be included in such arrangements for the purpose of passing on the costs so that the entity that is ultimately responsible for the decisions affecting the CO2 emissions of the ship is held accountable for covering the compliance costs paid by the shipping company under this Directive.”

Whilst many vessel owners would support the motivation behind this provision, it is far from clear how EU law would impose such a clause in private contractual arrangements between parties that may not be based in EU states. What happens if the charterparty contains no such clause? Could the owners rely on EU law to seek recovery from the charterers in the EU even if there was no such clause in the charterparty? Might it result in some voyage-charterers being forced to pay for EU ETS allowances even though they did not supply the fuel?

A second area of discussion is how emissions on voyages into or out of the EU are to be determined, and if operators may seek to evade the full application of the EU ETS. For example, if a vessel calls at an intermediate port just outside of the EU shortly after leaving EU waters, that may result in the out-bound voyage being assessed as much shorter than one from/to the actual next load port. The change of routing may cause the operator extra costs, but the benefit of the avoided allowances could be greater, depending on the assumptions made. We would expect this issue to be covered by the scheme once implemented, but at the moment it is an area that needs more thought.

Note: The complete article of ‘The EU Emission Trading System - are you ready?’ by Gard can be found here


Photo credit: Gard
Published: 8 December, 2022

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GCMD concludes its final biofuel blend supply chain trial with Hapag-Lloyd

bp provided the B30 biofuel blend to the “TIHAMA”, a 19,870 TEU container vessel operated by Hapag-Lloyd in final trial; marks the end of a series of trials initiated in July 2022.





GCMD concludes its final biofuel blend supply chain trial with Hapag-Lloyd

The Global Centre for Maritime Decarbonisation (GCMD) on Thursday (18 July) said it has successfully completed its final supply chain trial for biofuel blended with very low sulphur fuel oil (VLSFO). 

This marks the end of a series of trials initiated in July 2022 as part of a larger pilot to develop a framework to provide quality, quantity and GHG abatement assurances for drop-in fuels.

In this final trial, bp provided the B30 biofuel blend to the TIHAMA, a 19,870 twenty-foot equivalent unit (TEU) container vessel operated by Hapag-Lloyd.

The biofuel component used is certified to the International Sustainability & Carbon Certification (ISCC) standard – a multistakeholder certification scheme for biobased materials. The biofuel component comprised neat Fatty Acid Methyl Ester (FAME) produced from food waste.

Authentix, a tracer solutions provider, supplied and dosed the FAME with an organic-based tracer at the storage terminal outside the Netherlands. The dosed FAME was then transported to the Port of Rotterdam for blending with VLSFO to achieve a B30 blend, before the blend was bunkered onboard the TIHAMA.

Similar to previous trials, GCMD engaged fuel testing company Veritas Petroleum Services (VPS) to witness the operations at all stages – from biofuel cargo transfer to bunkering. VPS also collected and conducted extensive laboratory tests on samples of the biofuel and biofuel blend collected at pre-determined points along the supply chain to assess quality per Standards EN 14214 and ISO 8217.

With well-to-wake emissions of 13.74 gCO2e/MJ, the neat FAME presented a 85.4% emissions reduction compared to the emissions of the fossil marine fuel. The reduced emissions complies with the MEPC 80, which requires a minimum emissions reduction of 65% in order for biofuels to be classified as sustainable.

GCMD and Hapag-Lloyd determined that consumption of the 4,500 MT B30 blend of FAME and VLSFO resulted in 27.9% emissions reduction compared to sailing on VLSFO.

A newly developed tracer deployed with this supply chain

GCMD collaborated with Authentix to develop and deploy a new organic-based tracer to authenticate the origin and verify the amount of FAME present in the blend. The proprietary tracer blended homogeneously with FAME and was detected at expected concentrations at all sampling points along the supply chain.

This trial marks the first deployment of this tracer in a marine fuel supply chain. Previously, similar tracers were used to authenticate and quantify biofuels in road transport and LPG supply chains.

Development of a comprehensive biofuels assurance framework underway

With the completion of this trial, GCMD has deployed a diverse range of tracer technologies, including synthetic DNA and element-based tracers, in addition to the organic-based tracer used in this trial. The trials have also included the development of a chemical fingerprinting methodology and the evaluation of lock-and-seal and automatic identification systems (AIS) as additional solutions to ensure the integrity of the biofuels supply chain.

Learnings on tracer limitations and benefits will be incorporated into a framework that recommends appropriate use to ensure consistent and robust performance. This effort will complement existing ISCC by providing additional supply chain assurance through physical traceability.

The insights from these trials will be shared in a series of reports covering issues, such as traceability, biofuel degradation, supply chain optimisation and abatement costs. These findings will culminate in a comprehensive assurance framework to provide guidance on biofuels use, slated for release in the fourth quarter of 2024.


Photo credit: Global Centre for Maritime Decarbonisation
Published: 19 July 2024

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MPA, ITOCHU and partners sign MoU on ammonia-fuelled bulk carriers study

As a government agency, MPA,will review and provide their views to the designs of the ammonia-fuelled ships to ensure their safe operations, says ClassNK.





RESIZED venti views

Classification society ClassNK on Thursday (18 July) said it signed a Memorandum of Understanding (MoU) with ITOCHU Corporation, Nihon Shipyard Co., Ltd., and Maritime and Port Authority of Singapore (MPA) regarding a joint study for the design and safety specifications of ammonia-fuelled ships which are under development by ITOCHU and partners.

“The discussion for a specification of ammonia-fuelled ships with a governmental body related to their operation is essential for a social implementation of ammonia-fuelled ships,” ClassNK said. 

“As one of parties of the MoU, MPA, a government agency overseeing the world’s busiest bunkering hub, will review and provide their views to the designs of the ammonia-fuelled ships to ensure their safe operations.”

The MoU is based on the premise that 200,000 deadweight ton class bulk carriers will be built by Nihon Shipyard with an ammonia dual-fuelled engine.

“The necessary clarifications of the specification for the ammonia-fueled ship to carry out ammonia bunkering in Singapore will be conducted among parties of this MoU, for the commercialisation of ammonia-fuelled ships,” ClassNK added.


Photo credit: Venti Views on Unsplash
Published: 19 July 2024

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“K” Line to use biofuel on three Gram Car Carriers-chartered vessels in Singapore

Biofuel will be supplied to the sister vessels “Viking Ocean”, “Viking Diamond” and “Viking Coral” while bunkering in Singapore, says Gram Car Carriers.





“K” Line to use biofuel on three Gram Car Carriers-chartered vessels in Singapore

Norwegian transportation firm Gram Car Carriers (GCC) on Thursday (18 July) said Kawasaki Kisen Kaisha (“K” LINE) will use biofuel on three vessels chartered from GCC from July onwards. 

“The biofuel will be supplied to the sister vessels Viking Ocean, Viking Diamond and Viking Coral while bunkering in Singapore, an Asian hub for marine biofuels,” GCC said on its social media. 

“The use of biofuel is a key environmental initiative to reduce emissions across the entire value chain (well-to-exhaust) and an effective way of transitioning to low-carbon marine fuels amid globally tightening environmental regulations.”

“We support the green mobility shift. This means that GCC commit to supporting the transition of both vehicles and their logistic chain towards a zero-emission future in close cooperation with leading customers such as K-Line,” said Georg A. Whist, CEO of GCC.


Photo credit: Gram Car Carriers
Published: 19 July 2024

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