Regulatory requirements for biofuels

What are the regulatory requirements with respect to the use of biofuels?
Are extra NOx measurements required?
Do Flag and Class have to be notified by the operator?

1 Like

Hello Satyajit,

MARPOL Annex VI Regulation 18 classifies fuel oils into two categories:

  1. Regulation - blends of hydrocarbons from petroleum refining
  2. Regulation 18.3.2 - fuel oil derived by methods other than petroleum refining

Biofuels can be classified under either category because they can be a mixture of bioderived products with conventional petroleum-derived sources or solely bioderived.

The Unified Interpretation (UI) on the application of biofuels to marine engines (MEPC.1/Circ.795) interprets regulation 18.3 of MARPOL Annex VI as:

  1. Blend less than 30% biofuel, which should meet the requirements of regulation 18.3.1
  2. Blend of more than 30% biofuel, should meet the requirements of regulation 18.3.2

Generally, for blends between 7-30% biofuel, NOx re-measurements are not required. However, a confirmation from the OEM on the capability of the engines to burn the proposed biofuels and a no-objection confirmation letter is required. For blends with more than 30% of biofuel, NOx re-measurement might be necessary depending on whether the biofuel can be burnt without changes to the NOx critical components or settings.

For more than 30% biofuel, the Flag Administration should be contacted to check the application under the regulations of MARPOL Annex VI and ask for further guidance.

Also, for the class, a risk assessment should be conducted showing that risk control measures are in place in case of engine failure or fuel-related issues.

In any case, an implementation plan for the use of biofuels and change-over requirements in their Safety Management System and crew familiarization is required.

mepc1circ795rev7.pdf (208.0 KB)