Technical Information: Approved Sustainability Certification Scheme

Subject
Handling of IMO Interim Guidance on the Use of Biofuels

under IMO-DCS and CII regulation
Technical
Information
No. TEC-1307
Date 13 September 2023
To whom it may concern
At the 80th Marine Environment Protection Committee (MEPC 80), the Interim Guidance on the use of
biofuels under regulations 26, 27, and 28 of MARPOL Annex VI (IMO-DCS and CII regulations)
(MEPC.1/Circ.905) was approved. As a result, it is possible to calculate the CO2 emission factor (Cf)
for biofuels that meet the conditions, and to use it under the IMO-DCS and CII regulations.
The following summary is the IMO Interim Guidance on the Use of Biofuels.
1. Summary of the Interim Guidance about using Biofuels
In the 2022 Guidelines on Operational Carbon Intensity Indicators and Calculation Methods
(RESOLUTION MEPC.352(78) 2022 GUIDELINES ON OPERATIONAL CARBON INTENSITY
INDICATORS AND THE CALCULATION METHODS (CII GUIDELINES, G1)), it is stipulated that
if the type of fuel oil is not included in the relevant guidelines, the fuel supplier is required to provide
the CO2 emission factor (Cf) for that type of oil, along with documentary evidence.
On the other hand, at the IMO, guidelines on Life Cycle Assessment (LCA) of greenhouse gas (GHG)
emissions from the production to consumption of marine fuels (Well-to-Wake) are continually being
discussed. Until the LCA guidelines are developed, it has become possible to use the interim guidance
on the use of biofuels to calculate the CO2 emission factor (Cf) for biofuels that meet the following
conditions, for use in IMO-DCS and CII regulations.
Conditions for biofuels that can be used in IMO-DCS and CII regulations:
(1) Certified to meet sustainability criteria through an international certification system (such as
ISCC, RSB, etc.)1, and
(2) the Well-to-Wake GHG intensity of the fuel is 33gCO2e/MJ or less.
Formula for calculating the CO2 emission factor (Cf) for biofuels:
Cf [gCO2eq/g] = GHG Intensity [gCO2eq/MJ] × Lower Calorific Value (LCV) [MJ/g]
1
Refer to ICAO's Approved Sustainability Certification Scheme and the CORSIA Sustainability
Criteria (Chapter 2) for CORSIA Eligible Fuels.
(To be continued)
NOTES:
 ClassNK Technical Information is provided only for the purpose of supplying current information to its readers.
 ClassNK, its officers, employees and agents or sub-contractors do not warrant the accuracy of the information contained
herein and are not liable for any loss, damage or expense sustained whatsoever by any person caused by use of or reliance
on this information.
 Back numbers are available on ClassNK Internet Homepage (URL: www.classnk.or.jp).
ClassNK Technical Information No. TEC-1307
Note that in any case, the Cf value of biofuels cannot be less than zero. For blended (mixed) fuels, the
Cf is calculated based on the weighted average of the Cf for the respective amount of fuels by energy.
Additionally, biofuels that are not certified by an international certification system as "sustainable", or
that do not meet the above GHG intensity criteria (33gCO2eq/MJ or less), will be assigned a Cf equal
to the Cf of the equivalent fossil fuel type.
This guidance is temporary and will be discontinued once a more comprehensive Well-to-Wake GHG
emission calculation method, based on the IMO LCA guidelines, has been developed.
2. Procedures for the Use of Biofuels in ClassNK Verification of IMO-DCS and CII Regulations
In verification for IMO-DCS and CII regulations, in order to use the above CO2 emission factor (Cf)
for biofuels, re-approval of SEEMP Part II is required. Please add the biofuels into the section about
fuels type used on the SEEMP Part II and submit it to us through the ClassNK MRV Portal. Also, at that
time, please submit the documents specified in 1. above (Proof of Sustainability certificate or similar
documents), along with a copy of the Bunker Delivery Note.
Regarding how to input fuel oil consumption into the MRV Portal, we will separately inform MRV
Portal users through revised MRV Portal user manual accordingly.
For any questions about the above, please contact:
NIPPON KAIJI KYOKAI (ClassNK)

Marine GHG Certification Department, Administration Center, Head Office
Address: 4-7 Kioi-cho, Chiyoda-ku, Tokyo 102-8567, Japan
Tel.: +81-3-5226-3025
Fax: +81-3-5226-3026
E-mail: [email protected]
Attachment:
1. MEPC.1/Circ.905; Interim guidance on the use of biofuels under regulations 26, 27, and 28 of
MARPOL Annex VI (DCS and CII)
2. Sample of Proof of Sustainability and example calculations for the CO2 Conversion Factor (Cf)
2
Attachment 1. to
4 ALBERT EMBANKMENT
LONDON SE1 7SR
Telephone: +44 (0)20 7735 7611 Fax: +44 (0)20 7587 3210
MEPC.1/Circ.905
24 July 2023
INTERIM GUIDANCE ON THE USE OF BIOFUELS UNDER REGULATIONS 26, 27

AND 28 OF MARPOL ANNEX VI (DCS AND CII)
1 The Marine Environment Protection Committee, at its eightieth session (3 to 7 July 2023),
approved the Interim guidance on the use of biofuels under regulations 26, 27 and 28 of MARPOL
Annex VI (DCS and CII), as set out in the annex.
2 Member Governments are invited to bring the annexed Interim Guidance to the
attention of their Administrations, shipowners, ship operators, fuel oil suppliers and any other
interested relevant stakeholders concerned for application as of 1 October 2023.
***
I:\CIRC\MEPC\1\MEPC.1-Circ.905.docx
MEPC.1/Circ.905
Annex, page 1
ANNEX
INTERIM GUIDANCE ON THE USE OF BIOFUELS UNDER REGULATIONS 26, 27

AND 28 OF MARPOL ANNEX VI (DCS AND CII)
1 The 2022 Guidelines on operational carbon intensity indicators and the calculation
methods (resolution MEPC.352(78) CII Guidelines, G1) provide the possibility for the CO2
Emission Conversion Factor (Cf) to be obtained from the fuel oil supplier, supported by
documentary evidence, in case the type of the fuel oil is not covered by the relevant guidelines.
2 Pending the development of the comprehensive method to account for well-to-wake

GHG emissions and removals based on the Guidelines on life cycle GHG intensity of marine
fuels (LCA Guidelines) (resolution MEPC 376(80)), biofuels that have been certified by an
international certification scheme,* meeting its sustainability criteria, and that provide a
well-to-wake GHG emissions reduction of at least 65% compared to the well-to-wake
emissions of fossil MGO of 94 gCO2e/MJ (i.e. achieving an emissions intensity not
exceeding 33 gCO2e/MJ) according to that certification, may be assigned a Cf equal to the
value of the well-to-wake GHG emissions of the fuel according to the certificate (expressed in
gCO2eq/MJ) multiplied by its lower calorific value (LCV, expressed in MJ/g) for the purpose of
regulations 26, 27 and 28 of MARPOL Annex VI for the corresponding amount of fuels
consumed by the ship. In any case, the Cf value of a biofuel cannot be less than 0. For blends,
the Cf should be based on the weighted average of the Cf for the respective amount of fuels
by energy.
3 A Proof of Sustainability or similar documentation from a recognized scheme should

be provided along with the Bunker Delivery Note, to facilitate the verification of the reported
biofuel consumption.
4 Biofuels not certified as ʺsustainableʺ or not fulfilling the well-to-wake emission factor
criterion above should be assigned a Cf equal to the Cf of the equivalent fossil fuel type.
5 This guidance should be considered as an interim simplified method until a more

comprehensive method is developed to calculate a fuel's Emission Conversion Factor
reflecting its well-to-wake GHG emissions and removals based on the LCA Guidelines.
This guidance does not intend to prejudge or delay the process of developing such a
comprehensive method.
6 This Interim Guidance will be rescinded immediately upon operationalization of a

well-to-wake GHG methodology through the LCA Guidelines.
7 Administrations are invited to inform the Committee on which international certification

schemes have been used when applying this guidance.
___________

Refer to ICAO's Approved Sustainability Certification Schemes and the CORSIA Sustainability Criteria
(chapter 2) for CORSIA Eligible Fuels
I:\CIRC\MEPC\1\MEPC.1-Circ.905.docx
Attachment 2. to
Sample of Proof of Sustainability and Example Calculations for the CO2 Emission Factor (Cf)
■ Example Calculation 1:
For an unblended biofuel certified by the above PoS sample:
・Lower Calorific Value (LCV) [MJ/g] = 809,930 [MJ] / 21.890 × 106 [g] = 0.037 [MJ/g]
・GHG Intensity [gCO2eq/MJ] = 14.9 [gCO2eq/MJ] (< 33 [gCO2eq/MJ])
・Cf [gCO2eq/g] = 14.9 × 0.037 = 0.551 [gCO2eq/g]
■ Example Calculation 2:
For 75MT of blended biofuel (a blend of 21.890MT of the biofuel from Example 1 and 53.110MT of
VLSFO):
・Energy of biofuel [MJ] = 0.037 [MJ/gFuel] × 21.890 × 10⁶ [g] = 809,930 [MJ]
・Energy of VLSFO [MJ] = 0.041 [MJ/gFuel] × 53.110 × 10⁶ [g] = 2,177,510 [MJ]
(In the case that LCV and Cf of LFO are used for VLSFO.)
・Ratio of energy between biofuel and VLSFO = 809,930 / (809,930 + 2,177,510) : 2,177,510 /
(809,930 + 2,177,510) = 0.271 : 0.729
・Blend Cf [gCO2eq/g] = 0.271 × 0.551 + 0.729 × 3.151 = 2.446 [gCO2eq/g]
Lower Fuel Energy Ratio of Cf Blend Cf

Calorific Weight Amount Energy [gCO2eq/g] (Weighted Average
Value [g] [MJ] based on Energy)
[MJ/g] [gCO2eq/g]
FAME 0.037 21.890×10⁶ 809,930 0.271 0.551 0.149
VLSFO 0.041 53.110×10⁶ 2,177,510 0.729 3.151 2.297
Total 75.000×10⁶ 2,987,440 1.000 2.446

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Subject

Handling of IMO Interim Guidance on the Use of Biofuels

1. Summary of the Interim Guidance about using Biofuels

For any questions about the above, please contact:

NIPPON KAIJI KYOKAI (ClassNK)

INTERIM GUIDANCE ON THE USE OF BIOFUELS UNDER REGULATIONS 26, 27

INTERIM GUIDANCE ON THE USE OF BIOFUELS UNDER REGULATIONS 26, 27

2 Pending the development of the comprehensive method to account for well-to-wake

3 A Proof of Sustainability or similar documentation from a recognized scheme should

5 This guidance should be considered as an interim simplified method until a more

6 This Interim Guidance will be rescinded immediately upon operationalization of a

7 Administrations are invited to inform the Committee on which international certification

・Cf [gCO2eq/g] = 14.9 × 0.037 = 0.551 [gCO2eq/g]

・Blend Cf [gCO2eq/g] = 0.271 × 0.551 + 0.729 × 3.151 = 2.446 [gCO2eq/g]

Lower Fuel Energy Ratio of Cf Blend Cf

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