The study was commissioned by Pacific Environment. IMage Credit: Pacific Environment / NTU

• Study commissioned by campaign group Pacific Environment, carried out by NTU Singapore's MESD centre
• Reviews ISCC, RSB, RenovaBio, California's LCFS, and the US RFS as models for the IMO's certification rules
• Recommends chemical testing of fuels and a central database against double-counting
• Urges IMO to cap or phase out high-ILUC crop feedstocks; report says MPA reviewed it

The most recent cases of feedstock fraud in biofuel certification involved virgin crop oils being passed off as waste used cooking oil (UCO) and palm oil mill effluent (POME), and were only uncovered when the volumes declared became implausible, according to a study published on Tuesday that argues paper-based checks will not be enough as the IMO writes its own fuel certification rules.

The study was commissioned by Pacific Environment, a US-based climate campaign group, and carried out by the Maritime Energy and Sustainable Development (MESD) centre of excellence at Nanyang Technological University in Singapore, with the port authority MPA reviewing the report before publication, according to its acknowledgements.

It reviews the voluntary ISCC and RSB schemes used under the EU's Renewable Energy Directive and CORSIA, alongside Brazil's RenovaBio, California's Low Carbon Fuel Standard, and the US Renewable Fuel Standard, as blueprints for the sustainable fuel certification schemes (SFCS) the IMO is developing for its Net-Zero Framework.

ISCC may dominate the market, the authors find, with more than 90% of biofuels in the UK ISCC-certified and 7,546 ISCC certificates issued in 2024 against 72 for RSB.

Fingerprinting

To counter feedstock fraud the study recommends chemical testing, or "fingerprinting", to verify what a fuel was made from independently of its paperwork, though it says this is "subject to further methodology development and a cost-benefit analysis", and notes Singapore has already developed such a method using methanol as a case study.

It also calls for a central database logging every transaction so that the same batch of fuel cannot be claimed as green more than once, pointing to the EU's Union Database as the model.

"As shipping scales up the use of these fuels, we need certification systems that are robust enough to guard against fraud and unsustainable production, while also being practical and workable across complex international supply chains," said Pacific Environment's Singapore climate specialist Lim Jie Ying in an emailed press release.

Land Use

The study finds the biggest gap between the schemes is the treatment of indirect land-use change (ILUC), the emissions caused when fuel crops displace food production and drive deforestation elsewhere, which CORSIA and the two US schemes count but the EU schemes do not.

The study's authors recommend a hybrid approach, using quantitative ILUC values to penalise the carbon intensity of crop-based biofuels while still allowing their use, with usage caps or an eventual phase-out for high-risk feedstocks.

That is one side of a live debate at the IMO, where the US has proposed regional ILUC risk rules in submission ISWG-GHG 21/3/21.

"Strengthening the traceability of sustainable fuels through continued research and innovation will be critical in supporting the maritime energy transition," said the study's lead researcher, Dr Yeoh Keat Ping, research lead at MESD.

For Singapore, the report recommends expanding the pool of trained sustainability auditors as well as adopting fingerprinting, which the campaign group says would strengthen the country's position as a trusted green maritime hub.

The framework the certification rules are meant to serve has yet to be adopted: the Net-Zero Framework failed to pass at last October's extraordinary session and is due back before the Marine Environment Protection Committee (MEPC) on November 30, with a resumed adoption session pencilled in for December 4.

The full study can be downloaded here.