Zero-rating of CO2 emissions from sustainable biomass in marine bunker fuels
Shipping companies, if they meet the necessary monitoring and reporting requirements, can claim a zero-rating of CO2 emissions from sustainable biomass under the EU ETS for the biofuels they have used. To qualify for this zero emission claim, shipping companies must demonstrate that the biofuel complies with the monitoring and reporting procedures set out in Regulation 2015/757 (the Monitoring, Reporting and Verification Regulation, or MRV) and the RED-II. This compliance is basically demonstrated through a PoS.
The Netherlands has implemented the Renewable Energy Directive (RED-II) using the opt-in for fuel deliveries in the maritime sector. When fuel suppliers supply sustainable fuels, they can generate renewable energy units (HBEs) if they submit a proof of sustainability (PoS) to the Dutch Emissions Authority (NEa).
To zero-rate the CO2 emissions from sustainable biomass in marine bunker fuels, shipping companies must make the PoS available to the verifier and (if requested) to the NEa. In practice, the PoS is issued to the NEa by the fuel supplier to obtain its HBEs under the RED-II opt-in for maritime in the Netherlands. A PoS can only be issued once for a batch of fuels, which is why it is no longer available to a shipping company for its EU ETS reporting.
The European Commission is developing the Union Database (UDB), which should enable the use of the PoS by both the fuel supplier and the end user of the fuel, in this case the shipping company. The UDB should become a reliable system that supports parallel claims of renewable energy while preventing companies from double claiming in multiple greenhouse gas schemes. However, this system will not be fully operational during the reporting year 2024.
Currently, the European Commission is working on an interim solution while the UDB is not yet operational. For this we refer to the European Commission's Maritime Authority (EMSA), they can be reached at fitfor55@emsa.europa.eu. It is then up to the Ministries of Infrastructure and Water Management and Climate Policy and Green Growth to implement the interim solution nationally. The NEa will follow these developments closely and as soon as there is more clarity, the NEa will publish information on its website.