Skuld tells clients to always obtain exemptions for use and NOx emissions rulings from class or flag state authorities on biofuels
The Norwegian marine insurer said it is receiving an influx of technical enquiries both on P&I and Hull insurance, related to the use of marine biofuel across the different grades available in the market.
The questions regard using biofuels either as an alternative fuel or in testing fuels for future use in main engines, according to the club.
"The major issue we want to highlight is the requirement under Marpol regulation 18.3.2.2 which states: a fuel oil for combustion purposes derived by methods other than petroleum refining shall not cause an engine to exceed the applicable NOx emissions limit set forth in paragraphs 3,4,5.11 and 7.4 of regulation 13," Skuld said.
Skuld told 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" for the use of biofuels as well as a formal ruling from the flag state on the fuels’ NOx emissions under the NOx Technical Code 2008 regulations.
"Also, if the vessel has an existing flag state approval for the use of restricted biofuel blends, to obtain confirmation that a higher ratio of biofuels may be used without the need for further NOx emissions trials," the P&I club cautioned.
In June 2022, MEPC 78 approved a Unified Interpretation on the use of biofuels in IMO’s Marpol ANNEX VI. Skuld said it is important to note that biofuel blends of 30% by volume or less should simply be considered as conventional petroleum derivative fuels.
"For non-petroleum derived fuels other than biofuels, the provisions of this regulation apply as per regulation 18.3.2.2. For biofuels and biofuel blends of more than 30% by volume, if NOx-critical components and operational values are required by the engine’s technical file, then NOx emissions trials should not be required," Skuld said.
"In view of the above, Skuld would like to advise its members to always contact their respective classification society or their flag state for clarification and guidance.
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