Skuld: Check NOx Regs Compliance Before Using Biofuels and Blends

Ships at anchor. File Image. Image Credit: Ship & Bunker.

Before using biofuel bunkers, Skuld has recommended its members check for compliance with NOx regulations with their Classification Society or Flag State.

MARPOL regulation 18.3.2.2 states that: a 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 3,4,5.11 and 7.4 of regulation 13.

Helpfully, evidence from tests to date indicate biofuels and blends thereof do not cause excess emissions of NOx. In fact, the International Bunker Industry Association (IBIA) has noted that tests submitted to IMO indicate NOx is typically comparable or less than traditional oil-based fuel.

Still, operators are still required to perform the appropriate testing to show a biofuel is complaint, and IBIA has noted that this can be challenging.

In June life was made a little easier for the growing number of companies looking to test biofuels, with IMO introducing new rules that considered blends of 30% biofuel (B30) or less be treated in the same way as regular oil-based bunkers.

For those looking to use higher blend ratios, there are other exceptions that can be made.

For one, MARPOL Annex VI provides exceptions for 'Trials for Ship Emission Reduction and Control Technology Research', although IMO has previously noted that ships taking this route may face restrictions from certain ports due to national or local regulations.

"We are receiving an increased number of technical inquiries both on P&I and Hull related to the use of marine biofuel grades available in the market, either as an alternative fuel or for main engine testing for future use," says Skuld.

"Skuld recommends its members and clients who are now using, or intending to use, biofuels to always obtain confirmation from their Classification Society or Flag State for an exemption to use such fuels and also to ask the Flag State for a determination of the NOx emissions in accordance with the relevant provisions of the NOx Technical Code 2008.

"Also, if the vessel has an existing Flag State approval for the use of restricted biofuel blends, to obtain confirmation that higher ratio of biofuels may be used without the need for further NOx emission trials."