The EC recently released a report on calculation methodologies under FuelEU Maritime, which serves as official guidance.
On May 22, the European Commission (EC) updated a report on the calculation method of FuelEU Maritime (see top right), prepared by experts from the European Sustainable Shipping Forum (ESSF), specifically the sub-group on Sustainable Alternative Power for Shipping (SAPS). The report is not legally binding but aims to interpret legislative requirements and provide technical expertise relevant to the implementation of FuelEU Maritime.
As we also provided our own interpretation of the FuelEU regulation in our latest study, we compared our conclusions with those in the report. Here are some main takeaways:
- The Carbon Intensity (CI) of each fuel is calculated by summing the Well-to-Tank (WtT) and Tank-to-Wake (TtW) greenhouse gas (GHG) emissions. Our CI values for the main fossil fuels match those in the report, which confirms the validity of the methodology we applied in our study.
- Our CI values for biofuels may differ slightly from those in the report. This is because we applied the feedstock’s typical emission intensity (E*) value rather than the default E value used in the report, as referred to in Annex III of the Renewable Energy Directive (RED).
- The report clearly states that for actual WtT emission calculations of the various biofuel pathways, the respective actual E value from the Proof of Sustainability (PoS) or Proof of Compliance (PoC) of the certified biofuel should be used, which may differ from the default value in the RED.
- The report also clarifies the FuelEU and Emissions Trading System (ETS) scope for different cases of international voyages. Details are provided in the table below.
- As discussed previously, the methodology for fuel allocation under FuelEU was not yet clearly defined. The report also outlines that FuelEU does not prescribe a specific methodology for allocating fuels to fulfill the energy scope.
- In the absence of a defined methodology in the legislative text, and based on the interpretation in the EC’s Q&A on the FuelEU webpage, it is understood that fuels used on different types of voyages or port calls can be freely allocated to meet the total energy scope within one calendar year, provided they have been reported under the MRV Regulation.
- Fuels used during out-of-scope voyages cannot be allocated to the FuelEU scope; however, fuels used during voyages exempted under Article 2 (3), (4), (5), and (6) can be allocated to the FuelEU scope.
As a next step, an official guidance document is being prepared and is expected to be published in the second half of 2025. Additionally, the FuelEU Q&A page is scheduled to be updated by this summer. We will closely monitor any updates.
*E value means the total GHG emission intensity (gCO2/MJ) from the supply and use of the fuel.
