IMSML Website Article 08/2025: Resolution MEPC.376(80) - Guidelines on Lifecycle GHG Intensity of Marine Fuels (LCA Guidelines), Part 1 of 5, PART I - GENERAL

This is Part 1 of a series of articles on the LCA Guidelines.

The LCA Guidelines (see Annex 14, p 1 - p 60) were adopted by the Marine Environment Protection Committee via Resolution MEPC.376(80) at its 80th Session. It is the applicable nationally via Malaysia Shipping Notice (MSN) 14/2023, as the 8th subject-matter in Annex 1.

OUTLINE OF THE GUIDELINES

There are 5 Parts, 13 Sections and 4 Appendices to the LCA Guidelines.

The 5 parts are as follows:

[1] Part I - General;

[2] Part II - Methodology;

[3] Part III - Default Emission Factors and Actual Values;

[4] Part IV - Verification and Certification;

[5] Part V - Review.

The 4 appendices deal with the following subject-matters:

[1] Appendix 1 - Fuel List with Fuel Pathway Code;

[2] Appendix 2 - Default Emission Factors per Fuel Pathway Code;

[3] Appendix 3 - Abbreviations and Glossary;

[4] Appendix 4 - Template for Well-To-Tank Default Emission Factor Submission

PART I - GENERAL

SECTION 1 - INTRODUCTION

What do these guidelines provide? Guidance on the life cycle of GHG intensity assessment for all fuels and other energy carriers (eg electricity) used on board a ship, see Paragraph 1.1.

What are the aims of the Guidelines? Paragraph 1.1 identifies - Covering the whole fuel lifecycle with specific boundaries from:

[1] Feedstock extraction / cultivation / recovery;

[2] Feedstock conversion to a fuel product;

[3] Transportation;

[4] Distribution / bunkering;

[5] Fuel utilisation on board a ship.

What 'sustainability' themes are covered by these guidelines? Paragraph 1.1 lists down the following:

[1] Fuel type, feedstock type, nature and carbon source;

[2] Conversion / production processes (ie process type and energy used in the process);

[3] GHG emission factors;

[4] Information on fuel blends;

[5] Sustainability themes.

Is there verification / certification of elements of the Full Lifecyle Label (FLL)? Yes, the Guidelines specify the elements of FLL and also includes a general procedure on how the certification scheme / standards could be identified, see Paragraph 1.1.

SECTION 2 - SCOPE

What do the scope of these Guidelines address? Paragraph 2.1 lists down this scope:

[1] Greenhouse gases (GHG) intensity for the following:

[a] Well-to-tank (WtT);

[b] Tank-to-wake (TtW);

[c] Well-to-wake (WtW).

[2] Sustainability themes /aspects related to marine fuels / energy carriers (eg electricity for shore power) used for:

[a] Ship propulsion;

[b] Power generation on board.

What are the relevant GHGs? Paragraph 2.1 specifies three gases:

[1] Carbon dioxide (CO2);

[2] Methane (CH4);

[3] Nitrous Oxide (N2O).

What do the Guidelines do not cover? Paragraph 2.1 clarifies that

[1] It is not intended to provide guidance for a complete IMO GHG inventory for international shipping;

[2] Not included are emissions from cargo, eg volatile organic compounds (VOC);

[3] Other short-lived climate forces and precursors, eg non-methane volatile organic compounds (NMVOC), sulphur oxides (SOX), carbon monoxide (CO), particulate matter (PM), and Black Carbon.

What falls within the Attributional Life Cycle Assessment (LCA)? According to Finnveden G, Hauschild MZ, Ekvall T, Guinea J, Heijungs R, Hellweg S, eg al. ‘Recent Developments in life cycle assessment’, Journal of Environmental Management, 2009, 91(1): 1-21, the Guidelines span the lifecycle of fuels, based on an attributional approach, from (see Paragraph 2.2):

[1] Sourcing;

[2] Production;

[3] Conversion;

[4] Transport;

[5] Distribution;

[6] Eventual usage on board ships.

Could there be possibility to expand the system boundaries for specific pathways in which the feedstock is displaced from present use(s)? Yes, it will be assessed on a case by case basis, eg captured CO2 transportation and storage, see Paragraph 2.2 and fn 2.

What part of the life cycle chain, will feedstock emissions be accounted for? Paragraph 2.2 identifies the following part of the life cycle chain for accounting:

[1] feedstock extraction /cultivation / acquisition /recovery, see Paragraph 2.2.1;

[2] feedstock (early) processing / transformation at source, see Paragraph 2.2.2;

[3] feedstock transport to conversion site, see Paragraph 2.2.3;

[4] feedstock conversion to product fuel, see Paragraph 2.2.4;

[5] product fuel transport /storage / delivery /retail storage / bunkering, see Paragraph 2.2.5; and …

[6] fuel utilization on board a ship, see Paragraph 2.2.6.

What are the basis of the WtT emissions calculations in addition to the ‘attributional approach’, using best available scientific evidence? Paragraph 2.3 lays down the following approaches:

[1] Assessments are assessed regardless of the final use of fuels / energy carriers;

[2] TtW emissions (ie related to fuel use) are quantified regardless of the sourcing. / production / conversion / transport and delivery steps of the fuel / energy carrier;

[3] WtW emissions are given by the sum of two parts, providing the full emission performance associated with:

[a] Fuel production;

[b] Use of certain fuel / energy in a specific converter onboard.

How are GHG emissions calculated? According to Paragraph 2.4, the emissions are calculated to CO2-equivalent, using:

[1] Global Warming Potential;

[2] This was to be done over a 100 year time horizon (GWP100);

[3] Conversion of emission of gases other than CO2 such as CH4 and N20 (as given in the 5th IPCC Assessment Report, which form the foundation of these Guidelines);

[4] GWP100 values should be used for the purposes of quantifying ‘GHG Intensity’;

[5] Global Warming Potential values can also be computed over a 20 year horizon (GWP20).

Do the Guidelines include an initial non-exhaustive list of fuels? Yes, in Appendix 1, depicting the main current and expected future marine fuels, see Paragraph 2.8.

Thank you for reading IMSML Website Article 08/2024

Stay tuned for the next IMSML Website Article 09/2025: Resolution MEPC.376(80) - Guidelines on Lifecycle GHG Intensity of Marine Fuels (LCA Guidelines), Part 2 of 5, PART II - METHODOLOGY

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,  25 February 2025

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