IMSML Website Article 11/2025: Resolution MEPC.376(80) - Guidelines on Lifecycle GHG Intensity of Marine Fuels (LCA Guidelines), PART 4 of 5, PART IV - VERIFICATION AND CERTIFICATION, and PART V - REVIEW

There are two sections to PART IV, and one section to PART V. These are the two sections for PART IV:

[1] Section 11 - Elements Subject to Verification / Certification;

[2] Section 12 - Identification of Certification Schemes / Standards.

The single section in PART V is: Section 13 - Continuous Review Process.

PART IV - VERIFICATION AND CERTIFICATION

SECTION 11 - ELEMENTS SUBJECT TO VERIFICATION / CERTIFICATION

When does FLL need to be verified and certified by a third party? When used as evidence for performance. It needs to take into account further guidance to be developed by IMO, see Paragraph 11.1.

Can verification be carried out separately by different verification bodies? Yes, but it is important to note that verification and certification of Part D, is based on the verified Part A, Part B and Part C, see Paragraph 11.2.

How does one deal with fuel types that have a specific pathway code and which will be consumed in a specified energy converter? The default emission factors for Part A-5, Part C-1, Part C-2 and Part D of the FLL are set out in Appendix 2. As long as the Part A-1 to Part A-4, and Part C-3 of the FLL have been duly verified, the default emission factors contained in these guidelines can be applied without further verification, see Paragraph 11.3.

What if lower emission factors are claimed compared to the default emission factors for Part A-5, Part C-1, Part C-2 and/or Part D? The actual emission factors can be used only after verification and certification by a third party, taking into account further guidance referred to in Paragraph 11.1, see Paragraph 11.4.

SECTION 12 - IDENTIFICATION OF CERTIFICATION SCHEMES / STANDARDS

It is known that different parts of the FLL may be verified using different certification schemes / standards, but could a specific part of the FLL be addressed by multiple certification schemes / standards? Yes, if similar in scope, see Paragraph 12.1.

Should the certification schemes / standards in use be recognised by IMO? Yes, it should take into account even guidance to be developed by IMO. The list of recognised certification schemes / standards should be publicly available and kept under review, see Paragraph 12.2.

What is to be done with proposals for recognition of international certification schemes / standards? To be submitted to IMO for consideration, including an assessment of a set of predetermined criteria which will be further developed for this purpose, see Paragraph 12.3.

How should the framework, criteria and procedures leading to recognition of certification schemes be implemented? Uniformly to guarantee the quality, reliability and robustness of the IMO framework as a whole, and to ensure a level playing field among the certification schemes, see Paragraph 12.4.

PART V - REVIEW

SECTION 13 - CONTINUOUS REVIEW PROCESS

Why should the Guidelines be kept under continuous technical review? To ensure that new technological advances and scientific knowledge are taken into account, see Paragraph 13.1.

What elements should be kept under review? Section 13.2 identifies the following:

[1] WtT, TtW and WtW default emission factors specified in Appendix 2, see Paragraph 13.2.1; AND …

[2] New proposed fuel pathways and the corresponding default emission factors in addition to those specified in Appendix 1, see Paragraph 13.2.2.

Thank you for reading IMSML Website Article 11/2024

Stay tuned for the next IMSML Website Article 12/2025: Resolution MEPC.376(80) - 2023 IMO Strategy on Reduction of GHG Emissions from Ships (2023 GHG Strategy), Part 5 of 5, THE APPENDICES - APPENDIX 1-4

Signing-off for today,

Dr Irwin Ooi Ui Joo, LL.B(Hons.)(Glamorgan); LL.M (Cardiff); Ph.D (Cardiff); CMILT

Professor of Maritime and Transport Law

Head of the Centre for Advocacy and Dispute Resolution

Faculty of Law

Universiti Teknologi MARA Shah Alam

Selangor, Malaysia

Tuesday,  18 March 2025

Note that I am the corresponding author for the IMSML Website Articles. My official email address is: uijoo310@uitm.edu.my