Understanding the challenge of reporting biofuels under EU maritime regulations

The global shipping industry uses more than 300 million tons of fossil fuels every year, accounting for around 5% of global oil production. Meanwhile, the offshore sector accounts for approximately 7 million tonnes of fossil fuels, according to Spinergie’s Emissions Model (2023 calculation). To help alleviate this, the number of vessel managers using biofuels in maritime operations is gradually increasing. 

It should be noted that ‘biofuel’ is a wide term encompassing a number of fuel types derived from biomass—and not all are equal when it comes to CO₂ emissions. The latest generation of biofuels are sourced from algae or other advanced processes, while earlier generations derived from food crops, agricultural or forestry residue, organic waste, and non-food crops.

On the positive side, biofuels offer the opportunity to reduce the overall carbon content of operations while also benefitting from clear sourcing—an aspect that is especially important in light of increased regulatory requirements globally and in the European Union (EU).

Yet despite their advantages, biofuels come with sustainability challenges including competition with the food chain and pressure on land and forestry. Furthermore, in some cases, the production, transport, and fertilizers required to create biofuels can cancel out the benefits while certain crops can be a significant drain on the water supply. 

For these reasons, and the delicate balancing required to ensure their sustainability, regulatory bodies are cautious of biofuel use. Without strict processes, the benefits of using them can be negated compared to standard Marine Diesel Oil (MDO). This is why, when it comes to reporting, the process is more complicated than with fossil fuels.

‍EU maritime regulation consumption reporting requirements

There are three EU carbon-emission directives that require accurate fuel consumption reporting. 

‍EU MRV

EU Monitoring, Reporting and Verification (EU MRV) is the basis of carbon tax determination and involves emissions collection and reporting to assess the environmental impact of maritime transport. When first introduced, the regulation covered ships over 5,000 GT, however, since January 1, 2025, it now also includes general cargo ships between 400 and 5,000 GT and offshore vessels of 400 GT and above.  

‍EU ETS

The EU Carbon Trading System (EU ETS) requires ship owners to pay for their emissions by purchasing and surrendering EU emission allowances (EUA) for each tonne of reported CO2 emissions in the regulatory scope. Since its introduction in 2024, cargo and passenger ships over 5,000 GT have been included. From 2027, offshore vessels over 5,000 GT will be incorporated. This will coincide with a review period where offshore vessels and general cargo ships between 400 and 5,000 GT will be considered for inclusion. 

‍Read More: Keeping pace with the EU’s emission reduction regulations? Spinergie’s Smart Fleet Management solution holds the answers

‍FuelEU Maritime

Part of the EU’s “Fit for 55” package, the FuelEU Maritime regulation aims to gradually reduce GHG emissions of ships calling at EU and European Economic Area (EEA) ports (from 2% in 2025 to 80% by 2050). FuelEU Maritime also covers ships-at-berth to mitigate in-port emissions by mandating the use of an on-shore power supply or alternative zero-emission technologies. Currently applied to commercial ships over 5,000 GT, FuelEU Maritime specifically promotes the use of renewable, low-carbon fuels with incentives available for using cleaner fuels.

‍Read More: Spinergie’s key to FuelEU Maritime compliance? Streamlined reporting and efficient data management

Reporting requirements for these regulations include several data points to be collected and reported for each period such as: 

• Port Detail: time and date of arrival or departure at each port and time spent at berth.
• Fuel consumption: at berth and at sea. 
• Emissions: the well-to-wake (WtW) emissions of each fuel type consumed at berth and at sea. 
• Onshore Power Supply (OPS) - for FuelEU Maritime: for applicable vessels this must include details of the connection and use of OPS and the amount of electricity delivered to the vessel while using OPS. 

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The challenges of using biofuels when regulatory reporting 

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Reporting of fuel consumption and emissions is relatively straightforward when using traditional fossil fuels such as MDO. However, the use of biofuels, such as Hydrotreated Vegetable Oil (HVO) makes the process more complex, in part due to the different approaches taken within the regulatory framework itself. 

For EU MRV, only Tank-to-Wake (TtW) emissions are considered. These emissions are from the GHG released from a fuel during combustion. This is calculated using two parameters: 

• The Lower Calorific Value (LCV) of the fuel: how much energy is created by burning 1g of fuel. 
• GHG Intensity TtW: how much CO2 equivalent is created by combusting 1MJ of energy from the fuel. 

The FuelEU Maritime regulation also requires Well-to-Wake (WtW) data which means that operators must account for emissions for the entire lifecycle of the fuel used. This means everything from feedstock cultivation, through to production, and final combustion on the vessel, must be included. This is significantly more complicated than the TtW measurement and requires a new parameter: 

• GHG Intensity WtT: how much CO2 equivalent is emitted by creating the fuel in the factory and transporting the fuel to the ship. 

Out of the three parameters outlined above, LCV and GHG Intensity WtT show major differences between fossil fuels and biofuels. These parameters are standardized for fossil fuels. This means that any MDO bunkered at any time, by any ship, can be converted to CO2eq using the same factors. However, there is no such standardization for biofuels. This means that every batch of bunkered biofuel will have a different set of parameters. 

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What does this mean for reporting biofuel consumption compared to fossil fuels?

There are two changes to be made when it comes to reporting biofuel consumption compared to fossil fuels.  

1. When biofuel is used, the emissions factors must be obtained by the fuel provider and shared with the verification agency in order for the CO2eq to be computed. 
2. Any biofuel burnt by the ship must be precisely linked to the corresponding bunkered batch. 

The difference in reporting can be explained in two distinct case studies: reporting using only fossil fuel and reporting using biofuel. 

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Case Study 1: Emissions reporting using Marine Gasoil (MGO) 

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Emissions factors are standardized for fossil fuels like MGO, this means that only the fuel type is needed for accurate consumption reporting. In this case, the crew can report bunkerings and consumption independently and the only link between the two is via the fuel type. 

With this in mind, a reporting structure may look like: 

• Jan 1st: 100 mT of MGO bunkered (Bunker A) 
• Jan 2nd: 30 mT of MGO consumed
• Jan 3rd: 30 mT of MGO consumed
• Jan 4th: 30 mT of MGO consumed
• Jan 5th: 100 mT of MGO bunkered (Bunker B); 30 mT of MGO consumed.‍

Here the amount of MGO consumed is enough information to be able to compute the day’s CO₂ emissions. It does not even matter which bunker the MGO was taken from: 20mT from Bunker A and 10 mT from Bunker B would still result in the same 30 mT to be reported that day. 

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Case Study 2: Emissions reporting using Hydrotreated Vegetable Oil (HVO) 

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The process of reporting is more complicated when a biofuel like HVO is used. This is because any bunkered batch is, by definition, different from another batch—even if the biofuel type is the same. 

In this case, a reporting structure may look like: 

• Jan 1st: 100 mT of HVO bunkered (Bunker A—note, this batch, we can call Batch A has specific LCV and GHG factors) 
• Jan 2nd: 30 mT of HVO consumed from Batch A
• Jan 3rd: 30 mT of HVO consumed from Batch A
• Jan 4th: 30 mT of HVO consumed from Batch A
• Jan 5th: 100 mT of HVO bunkered (Bunker B—note, this batch, Batch B, also has specific LCV and GHG factors that differ from Batch A).
• Jan 5th: 30mT of HVO consumed. It is necessary to report how much of that 30mT came from Batch A and from Batch B as they both have non-standardized, differing emission factors. 

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The crew must be precise in their reporting of how much fuel came from which batch, which is complicated in practice. They must: 

• Keep track of all specific batches.
• Ensure consumption reporting includes links to the correct batch.

Then, QHSE teams must transfer this information to the verification service in a specific format, which is more complicated than the format required for fossil fuel reporting. 

Spinergie’s Smart Fleet Management (SFM) solution is designed to help you manage your biofuels and blends including accurately reporting their usage to your verification service. Our system makes sure crews report their bunkers and consumption as usual, with no extra work. Then, we’ll automatically format your data to verifier requirements. 

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Want to find out more about how we can make biofuel reporting easier? Contact us for a free demo and we’ll chat about your specific requirements. 

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