London shipbroker Alibra Shipping has a warning for owners hoping to pool ships to meet the requirements of Europe’s FuelEU Maritime Initiative.
The decarbonisation scheme enters into force in 2025, but there is work for companies to do now ahead of that date, the tanker shop told TradeWinds.
The first step for shipowners will be to submit an emissions monitoring plan by 31 August 2024.
They will be required to monitor both the type and amount of energy used, in port and at sea. This includes well-to-wake emission factors for all fuels.
Emissions data must be submitted to the verifier by 31 January each year.
Three months after that, shipowners will receive a report from the verifier and have to pay any applicable penalties, before receiving the year’s FuelEU certificate at the end of June, Alibra explained.
Class society DNV has said the initiative will increase the share of renewable and low-carbon fuels in the fuel mix.
A key measure is the voluntary pooling mechanism, under which owners with only a few ships will be allowed to pool their compliance balance.
But there are conditions.
The brokerage said the total pooled compliance must be positive.
It added that this means ships cannot have a greater deficit after pooling emissions.
Take the example of two ships controlled by the same company.
By pooling one ship at 120% compliance and another at 80%, Alibra said the balance is 100% compliance.
However, pooling two ships at 80% results in the same compliance deficit and is therefore not permitted.
To use the mechanism, vessels must have also been compliant the previous year and each ship can only be included in one pool per reporting period.
“In theory, you could have one ship that has very low carbon emissions pooling with [four] ships that do nothing to lower emissions and the average figure for these five ships would pass,” the London shop said.
All greenhouse gas emissions have to be independently audited by an approved company.
“It’s going to be interesting to see how this is going to work when smaller shipowners, in terms of number of ships, pool with other companies,” Alibra said.
How contracts are put together is crucial.
“Difficulties may arise when deciding who pays the fines and who is responsible for ratifying the whole issue,” the broker said.
For ships trading in the European Union or European Economic Area, the yearly average greenhouse gas intensity of energy used on board, measured as greenhouse gas emissions per energy unit, needs to be below the required level.
To avoid evasive behaviour, container ships stopping in transshipment ports outside the EU or EEA, but less than 300 nautical miles (555 km) from an EU or EEA port, need to include 50% of the energy for the voyage to that port as well, rather than only the short leg from the transshipment port.