Regulatory requirements for biofuels

Decarbonization Alternative Fuels
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Hello!
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?

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Hello Satyajit,

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

  1. Regulation 18.3.1.1 - 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)

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