FuelEU Maritime public consultation

FuelEU Maritime legislation should pursue a dual goal: 1) create predictable demand for green hydrogen(-based) fuels or direct use of electricity, 2) incentivise ships to increase their energy efficiency (i.e. reduce energy consumption per transport work) and also tap into other sustainable alternative power sources that are not defined as “fuel”, especially wind-assist technologies. In combination, these would help the industry to better absorb the extra costs of using expensive sustainable alternative marine fuels, incentivise innovation, reward early movers and deliver deep and steep GHG cuts.

To achieve this, we recommend a hybrid approach that combines low-carbon energy standard (LCES) and vessel energy intensity standard per transport work – dubbed in this briefing as Carbon and Energy Intensity Standard (CEIS). Such a standard can be designed in a way to give the regulator the possibility to directly and separately target the necessary improvements on fuel carbon intensity, as well as vessel energy intensity.

We also recommend FuelEU Maritime legislation to adopt a full life-cycle approach, incorporating all GHG, including CO 2 , CH 4 and N 2 O and apply REDII sustainability criterion of 70% reduction threshold for qualifying sustainable advanced fuels. Alternative fuels that do not meet this threshold should not be allowed for regulatory compliance. In addition, we recommend all food/feed-based biofuels to be automatically excluded from the list of compliant fuels and cap the contribution of advanced (i.e. agricultural residue-based) biofuels at 1% of the onboard energy use by mass.

Lastly, we recommend implementing a robust enforcement regime, including fuel certification based on the sustainability criterion of REDII and dissuasive penalties.