13 Application of regulation 18.3 for biofuels
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Statutory Documents - IMO Publications and Documents - Circulars - Marine Environment Protection Committee - MEPC.1/Circular.795 Rev.6 – Unified Interpretations to MARPOL Annex VI – (10 June 2022) - Annex – Unified Interpretations to MARPOL Annex VI - 13 Application of regulation 18.3 for biofuels

13 Application of regulation 18.3 for biofuels

Regulation 18

Fuel oil availability and quality

Regulation 18.3 reads as follows:

  • "Fuel oil for combustion purposes delivered to and used on board ships to which this Annex applies shall meet the following requirements."

Interpretation:

13.1 A fuel oil which is a blend of not more than 30% by volume of biofuel should meet the requirements of regulation 18.3.1 of MARPOL Annex VI. A fuel oil which is a blend of more than 30% by volume of biofuel should meet the requirements of regulation 18.3.2 of MARPOL Annex VI. For the purposes of this interpretation, a biofuel is a fuel oil which is derived from biomass and hence includes, but is not limited to, processed used cooking oils, fatty-acid-methyl-esters (FAME) or fatty-acid-ethyl-esters (FAEE), straight vegetable oils (SVO), hydrotreated vegetable oils (HVO), glycerol or other biomass to liquid (BTL) type products. The Product Name, as entered onto the bunker delivery note, should be of sufficient detail to identify whether, and to what extent, a biofuel is blended into the product as supplied.

Regulation 18.3.2.2 reads as follows:

  • "fuel oil for combustion purposes derived by methods other than petroleum refining shall not cause an engine to exceed the applicable NOX emission limit set forth in paragraphs 3, 4, 5.1.1 and 7.4 of regulation 13."

Interpretation:

13.2 A marine diesel engine certified in accordance with the requirements of regulation 13 of MARPOL Annex VI, which can operate on a biofuel or a biofuel blend without changes to its NOx critical components or settings/operating values outside those as given by that engineʹs approved Technical File, should be permitted to use such a fuel oil without having to undertake the assessment as given by regulation 18.3.2.2 of MARPOL Annex VI. For the purposes of this interpretation, parent engine emissions tests undertaken on DM or RM grade fuels to the ISO 8217:2005 standard, as required by paragraph 5.3.2 of the NOx Technical Code, should be valid for all DM or RM grade fuels used in operation, or that the engine may be designed for, or capable of operation on, including those meeting the ISO 8217 standards superseding ISO 8217:2005.

13.3 Where fuel oils are derived from methods other than petroleum refining, or fuel oil which is a blend of more than 30% by volume of biofuel and does not fall under 13.2 of this unified interpretation, or other fuels required to undertake the assessment as given by regulation 18.3.2.2 of MARPOL Annex VI and for which have not been specifically certified in accordance with the regulation 13 limits at test bed for that specific fuel and Engine Group/Family, the following is interpreted as an acceptable route to demonstrate compliance with regulation 18.3.2.2:

  • .1 the ship's IAPP Certificate may continue to be issued where the overall NOx emissions performance has been verified to not cause the specified engine to exceed the applicable NOx emissions limit when burning said fuels using the onboard simplified measurement method in accordance with 6.3 of the NOX Technical Code 2008, or the direct measurement and monitoring method in accordance with 6.4 of the NOX Technical Code 2008, or by reference to relevant test-bed testing. For the purposes of this interpretation and demonstration of compliance with regulation 18.3.2.2 of MARPOL Annex VI, and as applicable to possible deviations when undertaking measurements on board, an allowance of 10% of the applicable limit may be accepted.

Parent topic: Annex – Unified Interpretations to MARPOL Annex VI
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