E

MARINE ENVIRONMENT PROTECTION MEPC 79/INF.31

COMMITTEE 7 October 2022
79th session ENGLISH ONLY
Agenda item 7 Pre-session public release: ☒

REDUCTION OF GHG EMISSION FROM SHIPS

Literature review and analysis of LCA studies on marine fuels
Submitted by the Republic of Korea

SUMMARY

Executive summary: This document presents a literature review and analysis of LCA
studies on marine fuels aiming at facilitating the development of
lifecycle GHG/carbon intensity guidelines for marine fuels.

Strategic direction, if 3
applicable:

Output: 3.2

Action to be taken: Paragraph 4

Related documents: ISWG-GHG 11/2/3; ISWG-GHG 11/WP.1; MEPC 77/WP.6;

ISWG-GHG 9/2; ISWG-GHG 9/2/3; ISWG-GHG 7/3/1;
ISWG-GHG 7/5/2 and MEPC 79/7/12

Introduction
1 The Intersessional Working Group on Reduction of GHG Emissions from Ships, at its 11th session
(ISWG-GHG 11), continued the development of draft lifecycle GHG and carbon intensity guidelines for
marine fuels. The working group has made significant progress in the development of draft LCA guidelines,
in particular, noting the need for further intersessional work on the various key issues with a view to
continuing the further development of the LCA guidelines.
2 MEPC 78 noted the discussion in ISWG-GHG 11 on the progress made in the development of draft
guidelines on lifecycle GHG/carbon intensity for marine fuels and established a correspondence group to
further evolve the work. The correspondence group has submitted an interim report as document
MEPC 79/7/12 (China et al.), and the final draft guidelines are expected to be adopted by MEPC 80.
3 In light of this, the Republic of Korea has further carried out a literature review and analysis
of LCA studies on marine fuels, as set out in the annex, with an aim to facilitate the development of
lifecycle GHG/carbon intensity guidelines for marine fuels, while seeking a better way to guide future
LCA policy development as well as decision-making.

Action requested of the Committee

4 The Committee is invited to note the information provided in this document

***

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ANNEX

A LITERATURE REVIEW AND ANALYSIS OF LCA STUDIES ON MARINE FUELS

1. Introduction

1.1. Background

The CO2 emissions from shipping sector account for approximately 3% of total annual
anthropogenic greenhouse gases (GHG) emissions and are comparable to Germany, the
world's 7th largest emitter (Global Carbon Project, 2020). In business-as-usual scenarios of
doubling global trade, these emissions are projected to increase up to 250 percent by 2050,
but meeting a 1.5–2 °C climate target requires net-zero GHG emissions from all economic
sectors, including shipping (Smith, Jalkanen et al. 2015). Therefore, the International Maritime
Organization (IMO) has established an initial GHG strategy to reduce the CO2 intensity from
the maritime sector by 40% in 2030 and abate total GHGs emissions by at least 50% by 2050
compared to 2008 (IMO 2018). To achieve the levels of ambition in the Initial IMO GHG
Strategy, it was projected that more than 60% of CO2 reduction efforts by 2050 will be
accomplished via alternative zero-carbon and low-carbon fuels (IMO 2020). Following the 26th
session of the Conference of the Parties (COP 26) Climate Summit in Glasgow, there is
growing industry and political pressure to raise the 50% to 100% reduction in total GHGs
emissions goal to ensure that IMO emission measures are fully aligned with the 1.5 °C Paris
Agreement goal (Bullock, Mason et al. 2022).

In an effort to improve ship’s energy efficiency and reduce CO2 emission, IMO has adopted
the mandatory instruments under MARPOL Annex VI with indicators, i.e., Energy Efficiency
Design Index (EEDI), Energy Efficiency Existing Ship Index (EEXI), Carbon Intensity Indicator
(CII), Annual Efficiency Ratio (AER) and Energy Efficiency Operational Indicator (EEOI) (IMO
2009, IMO 2021). However, these are of limited scope because it only considers emissions
from on-board combustion, ignoring upstream emissions associated with from fuel production
and distribution. Furthermore, it only addresses CO2, in place of all the GHGs defined by the
Intergovernmental Panel for Climate Change (IPCC), which might trigger a divergent
perspective on the effectiveness of environmental regulation for emission reduction. These
indicators containing the conversion factor (Cf) pose the risk that IMO can inadvertently
encourage shipowners to use the alternative low-carbon and zero-carbon fuels—e.g.,
hydrogen with conversion factor "0"—that may deliver more GHG emissions than conventional
fossil fuels over their lifecycle.

In this context, in 2018 IMO adopted the common framework for the lifecycle assessment as
one of the candidates' short term measures in the IMO Initial GHG Strategy; "robust lifecycle
GHG/carbon intensity guidelines for marine fuels" addressing both the upstream and the
downstream emission parts (IMO 2018). As shown in Figure 1, the LCA for marine fuels refers
to the GHG emissions from the fuel production to the ship (Well-to-Wake); Well-to-Tank and
Tank-to-Wake.

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Figure 1 Generic Well-to-Wake supply chain

While IMO initiated the work on the development of LCA Guidelines in 2019 and identified the
work scope, i.e., develop not only WtW default emission values for marine fuel, but also
verification and certification procedure for their actual emission values, the challenges remain
in the development of the robust default emission values due to lack of unified LCA
methodologies for marine fuels. Other elements to be unified by IMO pertain to, inter alia,
global warming potential time horizon, GHG emissions scope and accounting principles. It also
covers the identification of sustainability criteria and relevant certification schemes of fuels
which perform better than the default values (IMO 2021).

LCA is a well-established methodology which allows users to quantify the emission levels of
relevant pollutants throughout the life cycle of a product or system from raw material extraction
to final disposal (ISO 2006). The LCA framework is a systematic approach and comprises four
phases (see Figure ): the goal and scope definition, the inventory analysis, the impact
assessment, and the interpretation. Additionally, each of these phases, along with their
associated databases and models, has significantly associated uncertainties (Baker and
Lepech 2009).

Figure 2 Main stages of lifecycle assessment framework

The LCA methodologies with significant uncertainties not only create greater challenges on
how to determine default emission values, but they also lead to uncertainty on LCA regulatory
framework for marine fuels to be included in possible mid- and long-term measures for GHG
reduction with respect to effective uptake of low- and zero-carbon fuels into shipping sector. In
this regard, LCA guidelines should be developed in a consistent manner.

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1.2. Previous LCA studies on marine fuels

It is found that alternative marine fuels have been extensively investigated in previous studies
using a variety of methods, particularly LCA. Various preceding LCA studies on marine fuels
were identified as listed in Table 1, whose focus is mainly to compare and contrast alternative
fuels with conventional fossil fuels.

However, many elements influence the broad range of outcomes in the LCA studies of marine
fuels. Moreover, variability occurs due to differences between the methodological criteria
applied, such as differences in elements regarding GHG emission scope, global warming
potential, sustainability criteria, functional unit, and inventory database. Notable points from
them will be further elaborated on in the section 2.

1.3. LCA application for policy including other transport sectors

This study also scrutinized LCA policies applied in other transport sectors to bridge the gap
between the literature and the existing practice of policies applied. LCA based approaches are
able to support policy-making and its implementation, and can be applied in performing the
policy evaluation (Lindstad and Rialland 2020). A number of policies in other transport sectors
to which LCA was applied have been identified as listed in Table 2. Notable points from them
are succinctly described as follows:

- Some examples of regulations relating to fuels come from some regional or international
sectors: there are regulations such as the California Low Carbon Fuel Standard, the UK
Renewables Transport Fuels Obligation, the US Renewable Fuel Standard, the
Washington Clean Fuel Standard, Renewable Energy Directive II (RED II), and the Carbon
Offsetting and Reduction Scheme for International Aviation (CORSIA) (Andreea Miu 2021).

- Recognising the large amounts of biomass used to produce biofuels for replacing fossil
fuels could lead to the increase of significant GHG emissions in WtT part as natural lands
are converted to croplands (Searchinger, Heimlich et al. 2008), RED II adopted an LCA
approach to avoid fuel production from biomass obtained from land with high carbon stock
(Brandão, Azzi et al. 2021). It provides the calculation method for attained GHG emission
reduction from biofuels fuels and include default values for a range of pathways.

- The International Civil Aviation Organization (ICAO) established CORSIA to help reducing
aviation GHG emissions (ICAO 2016). Under CORSIA, emissions reductions from the use
of sustainable aviation fuels are calculated using an LCA approach, agreed upon at ICAO
in 2018. The following four items are key elements amongst the agreed LCA method for
CORSIA (ICAO 2019): firstly, introduction of accounting for GHG well-to-wake emissions,
secondly, consideration of emission from induced land use change (ILUC), thirdly,
safeguards against deforestation, and finally, introduction of practices1 for low land use
change (LUC). These elements encouraged the stakeholders to choose different option
for SAFs to reduce life-cycle CO2 emissions, while avoiding the risks of unforeseen
consequences (Prussi, Lee et al. 2021).

1 Using certain types of land, land management practices (LMP), and the incorporation of innovative
agricultural practices could all be considered as contributing to low risk for land use change and therefore
receive a value of zero for ILUC

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Table 1 List of LCA studies on marine fuels

Author(s) and GHG emission Global warming Sustainability Criteria life cycle inventory
Type of Fuels Functional Unit
publication date Scope potential except for GHG database/tool
Methanol, Bio-
(Strazza, Del Borghi methanol, LNG,
kg CO2eq per kWh
et al. 2010) Hydrogen in Solid CO2, CH4, N2O GWP 100 ODP, POCP, AP, EP SimaPro
(electricity)
Oxide Fuel Cells
(SOFC)
(Bengtsson, t CO2eq per 1 t cargo
HFO, MGO, LNG, CO2, CH4, and
Andersson et al. GWP 100 AP, EP transported 1 km with a ro–ro ELCD, JEC
GTL(gas-to-liquid) N2O
2011) vessel
HFO, MGO, g CO2eq /MJ fuel: emission
Rapeseed methyl factors for the engines on the
(Bengtsson, Fridell et AP, EP, Agricultural land
ester (RME), CO2, CH4, and ro-pax ferries based on the
al. 2012) GWP100 use, Primary energy use, ELCD, JEC
Synthetic bio-diesel N2O yearly fuel consumption
and PM
(BTL), LNG, Bio- corresponding to energy
LNG content
HFO, LNG, 1 t cargo transported 1 km
(Brynolf, Fridell et CO2, CH4, and
Methanol, bio-LNG, GWP100 PM, POCP, AP, EP with a ro-ro vessel (g CO2eq/t ELCD, JEC
al. 2014) N2O
Bio-methanol km)
emission per tonne-kilometre
(Bicer and Dincer HFO, Hydrogen, ADP, AP, ODP cruise travel where the
CO2, CH4, N2O GWP 500 GREET
2018) Ammonia Ecotoxicity Potentials functional unit is 1 tonne-
kilometre.
HFO, MDO, LNG,
(Gilbert, Walsh et al. Hydrogen, CO2, CH4, and Air quality (NOx, SOx, grams emission/kWh
GWP 100 Ecoinvent, ELCD
2018) Methanol, Bio- N2O PM) delivered to the shaft
LNG, Bio-diesel
g CO2eq per 1 kWh of Oil Production Greenhouse
(El‐Houjeiri, Monfort CO2, CH4, and (GWP only)
HFO, MGO, LNG GWP100 & GWP 20 energy transferred to the ship Gas Emissions Estimator
et al. 2019) N2O
propeller (OPGEE), GREET

emission per the supply and

(Hwang, Jeong et al. CO2, CH4, and
HFO, MGO, LNG GWP100 AP, PM, POCP, EP consumption of LHV(MJ) of Gabi
2019) N2O
fuel

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Author(s) and GHG emission Global warming Sustainability Criteria life cycle inventory
Type of Fuels Functional Unit
publication date Scope potential except for GHG database/tool
emission per 1 kWh brake
HFO, LSFO, MGO, CO2, CH4, and Air quality (NOx, SOx,
(Life Cycle 2019) GWP20 & GWP 100 power specific unit (g CO2- GREET
LNG N2O PM)
eq/kWh)

(Sharafian, Blomerus CO2, CH4, and emissions per kWh engine

HFO, LNG GWP 100 Air quality (NOx, SOx) GREET
et al. 2019) N2O output

mass per energy units (e.g.,

(Winebrake, Corbett MDO, Methanol, CO2, CH4, and Air quality (NOx, SOx,
GWP 20 & GWP 100 grams per mega-Joule, or GREET /TEAMS
et al. 2019) LNG N2O PM)
g/MJ) with engine efficiency
(Lindstad and HFO, LSFO, MGO, CO2, CH4, and CO2eq emissions per kWh as
GWP 20 & GWP 100 (GWP only) Gabi, GREET, JRC
Rialland 2020) LNG N2O a function of fuel and engine
Methanol, Dimethyl
ether, LNG,
(Perčić, Vladimir et CO2, CH4, and
Hydrogen, GWP 100 (GWP only) tons of CO2-eq. GREET
al. 2020) N2O
Biodiesel,
Electricity
(Spoof-Tuomi and MDO, LNG, Bio- CO2, CH4, and AP, EP, PM, human g/MJ fuel with engine
GWP 100 Literature review
Niemi 2020) LNG N2O health efficiency
emission per “1 t of cargo
(Seithe, Bonou et al. CO2, CH4, and transported for 1 km (1 tkm)”
HFO, LNG GWP 100 (GWP only) ELCD, Ecoinvent
2020) N2O and “1 passenger transported
for 1 km (1 pkm)”
emission per shaft work
(Pavlenko, Comer et HFO, LSFO, MGO, CO2, CH4, and
GWP 20 & GWP 100 (GWP only) produced by the engine GREET
al. 2020) LNG N2O
(g/kWh)
(Manouchehrinia, CO2, CH4, and
LNG GWP 100 (GWP only) - GREET, GHGenius
Dong et al. 2020) N2O
(Jang, Jeong et al. CO2, CH4, and emission per unit of fuel
HFO, LNG GWP 100 AP, EP Literature review
2021) N2O energy (g/MJ fuel)
emission per the mass of fuel
(Comer and Osipova HFO, LSFO, MGO, CO2, CH4, N2O the ship consumed and a well-
GWP 20 & GWP 100 (GWP only) GREET
2021) LNG and Black carbon to-wake carbon dioxide
equivalent factor for that fuel

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Author(s) and GHG emission Global warming Sustainability Criteria life cycle inventory
Type of Fuels Functional Unit
publication date Scope potential except for GHG database/tool
Biogas, Dimethyl
ether, Ethanol,
human health, ecosystem,
LNG, LPG, GWP 20, GWP 100, emission per 1 ton or the
(Bilgili 2021) CO2, CH4, N2O resource utilization, SimaPro
Methanol, GWP 1000 equivalent volume of fuel
emission inventory
Ammonia, Bio-
diesel
Bio-methanol, Fossil
(Malmgren, Brynolf methanol, Electro- AP, EP, POCP, PM, emission per a voyage with a
CO2, CH4, N2O GWP 20, GWP 100 ELCD
et al. 2021) methanol (eMeOH), terrestrial eutrophication RoPax vessel travelling
MGO
HTP,POCP,AP,ADP,OD emission per 1 kWh of energy
(Fernández-Ríos,
Hydrogen CO2, CH4, N2O GWP 100 P ,EP, Ecotoxicity obtained from the PEMFC Gabi
Santos et al. 2022)
Potentials and the ICEs systems

Note: Ozone layer depletion Potential (ODP), Photochemical Ozone Creation Potential (POCP), Acidification Potential (AP), Eutrophication Potential (EP),
Abiotic depletion Potential (ADP), Human Toxicity Potential(HTP)

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Scheme Description Fuels Region Scope

British Columbia Requirements on annual goals for fuel British
Low Carbon suppliers to reduce the average carbon Fossil fuels Columbia, WtW
Fuel Standard intensity of fossil fuels Canada
Standard designed to reduce the carbon
California Low- Low-carbon and
intensity of California's transportation fuel
Carbon Fuel renewable US WtW
pool and promote the use of an variety of
Standard alternatives fuel
low-carbon and renewable alternatives fuel
Standard for fuel suppliers (producers and
Clean Fuel
importers) to reduce the lifecycle carbon Fossil fuels Canada WtW
Standard
intensity of fuels
Renewable Setting a common target for the promotion
Bio fuels and
Energy Directive and use of energy from renewable sources EU WtW
bioliquids
II (RED II) within the EU
Standard for fuel refiners or importers to
Renewable Fuel achieve compliance by blending renewable Renewable fuels
US WtW
Standard fuels into transportation fuel(or by obtaining including biofuels
credits)
Renewable
Detailed regulation for biofuels used for
Transport Fuel Biofuel UK WtT
transport and non-road mobile machinery
Obligation
Fossil fuels
International
ICAO CORSIA Requirements on a CORSIA eligible fuel andrenewable or WtW
aviation
waste-derived fuels

Table 2 List of policies with LCA approach in other transport sectors

These examples of policies investigated above should not be seen as flawless, but are a
starting point upon which the shipping sector can further harmonise with. With regards to
certification schemes on not only GHG emissions but also other sustainability issues, these
can differ by fuel type with several certification schemes already existing for biofuels while
some are being developed for emerging fuels such as ammonia and hydrogen.

1.4. Research aim

While the global shipping industry has started its journey to adopt a growing number of
alternative fuels to accelerate the energy transition, the scarcity of relevant studies with unified
LCA methodologies often misguides stakeholders by disregarding or underestimating their
comprehensive impacts on GHG emissions including sustainability aspects for eligible marine
fuels. This study was motivated to tackle these issues, with aiming at facilitating the
development of IMO LCA guidelines for marine fuels, while seeking a better way to guide future
LCA policy development and decision-making.

This literature review can be placed on the fact that it is a proactive response to the concerns
from industries and regulators on how accurately to appraise all GHG emissions and
sustainability aspects of alternative fuels from a lifecycle IMO policy perspective, as a
prerequisite to facilitate informed decision-making. Therefore, it is believed to present a
pragmatic insight to develop robust lifecycle GHG/carbon intensity guidelines for marine fuels
for the effective transition of sustainable low-carbon and zero-carbon fuels and to meet the
2050 ambitions in the Initial IMO Strategy.
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2. Further consideration of LCA framework in IMO instruments

2.1. What do we need to consider in the IMO lifecycle GHG/carbon intensity guideline?

2.1.1. GHG emissions scope

The six greenhouse gases covered under the UNFCCC are carbon dioxide (CO2), methane
(CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs) and sulphur
hexafluoride (SF6) (IMO 2020). Although black carbon (BC) may have potential impacts on the
climate, the current scientific uncertainty related to its evaluation for both the WtT and TtW
exists. With regard to the GWPs of BC which produced by incomplete combustion of MGO and
HFO in ship’s engines, some studies estimated the values for 20- and 100-year horizons with
approximately 3200 (270–6200) and 900 (100–1700) respectively (Bond et al., 2013). BC
would contribute to an additional 5–8% and 16–23% respectively to the global CO2 equivalent
emissions from shipping, when applying for the GWPs of 900 (GWP over 100 years ) and 3200
(GWP over 20 years ) (Comer et al., 2017)(Sharafian, Blomerus et al. 2019). It may still cause
a high uncertainty in these values.

While IMO adopted a resolution on voluntary use of environmental fuels in the Arctic to reduce
black carbon emissions, there is currently no concrete regulation regarding the measurement of
BC in IMO or what its GWP should be. It should be noted that the Fourth IMO GHG Study also
included the inventory of BC emissions from ships, but IPCC does not report a GWP of BC.

The inclusion of black carbon would introduce substantial complexity to the LCA framework,
which in turn could make it difficult to implement. Thus, it could be more appropriate to address
black carbon in other types of regulation at this stage. For the purpose of lifecycle GHG
emissions in the IMO LCA framework, the GHGs should include CO2, CH4, and N2O since
these represent the majority of GHGs emitted in transportation sectors.

2.1.2. Global warming potential

Global Warming Potential ("GWP") is a measure of each GHG's ability to trap heat in the
atmosphere over a given time period, compared to each ton of carbon dioxide (CO2) emissions.
Many other legislative acts for the transport sector such as EU Renewable Energy Directive
(RED II) and Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA)
etc., addressed the GWP over 100 years.

The importance of considering GWP over 20 years was highlighted in the context of IMO
policymaking because preventing or reducing GHG emissions with high 20 years GWP, such
as methane and BC, can help avoid additional near-term warming, which is critically important
as we strive to keep global warming below 1.5 °C set by the Paris Agreement(Comer and
Osipova 2021).

The default GWP with the 100-year time frame used in investigated studies was found as
common practice, but some studies presented results for the 20-year time for sensitivity
analysis purposes. While these IPCC reports publish GWPs over 20, 100, and 500 years of
time horizon, regulations referenced in this white paper have adopted GWP100 values.

When the carbon dioxide equivalent emissions, so-called CO2eq, are established with a sum
of the three GHGs mentioned above, many of the investigated studies are performed by the
IPCC GWP100 AR5 multipliers as per the table below. However, the most updated GWP 100
values from AR6 for CH4 and N2O should be used in order to generate a robust estimate of
CO2eq emissions considering the fact that the IPCC compiles and revises the estimates of
GWPs periodically.

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GHGs GWP 100 (IPCC AR5) GWP 100 (IPCC AR6)

CO2 1 1
CH4 28 29.8
N2O 265 273

Accordingly, GWP over 100 years should be considered in order for IMO policies to stay in line
with the UNFCCC and other widely accepted international reporting standards for GHG
emissions with a view to facilitating comparative assessment with other sectors.

In these sections from 2.1.3 to 2.1.7, the methodological aspects are analyzed among the
investigated LCA studies. The most significant differences were found to be due to how the
studies dealt with functional unit, sustainability criteria, co-product allocation, LUC, LCA
database, and choice for attributional (A-LCA) or consequential (C-LCA) modelling.

2.1.3. Functional unit

Life cycle assessment evaluates the environmental impacts of a product or process system
with regard to its function, such as GWP or acidification impacts per kg of product (ISO 2006).
The functional unit, as a reference, plays a crucial role in comparing LCA results and
quantifying performances of a product. In comparing many LCA studies of products in terms
of their environmental performances or impacts, the functional unit makes sure the comparison
of the evaluated fuels and their technologies.

However, the application of different functional units for identical fuels and technologies may
entangle comparisons between results or makes them incomparable (Artz et al.,2018). For this
reason, defining an acceptable functional unit should be prioritized to improve comparability
among studies. It is worth to note that, at the very first phase in any LCA, the functional unit is
defined in parallel with defining the goal and scope of the assessment. It is to be in line with
the goal of IMO Lifecycle GHG and Carbon Intensity Guidelines.

For the WtT part, the global warming impact for the fuels can be fairly compared based on per
megajoule (MJ) of delivered energy. On the other hand, in considering TtW part, an appropriate
functional unit should carefully be chosen. The past LCA research on marine fuel shown in
Table 3 indicate that the options as LCA functional unit are categorised as follows:

Option Functional Unit Purpose

This unit can rank order or prioritise
gCO2e/MJ shaft work or gCO2e/kWh engine
1 specific propulsion systems with specific
output.
fuel
This unit with transport work (tonne-nm)
can rank order or evaluate the
2 t CO2e/tonne-nm
performance of specific vessels or
operators
This unit is multiplied by fuel quantities
3 tCO2e/tfuel or gCO2e/ MJLHV,fuel
to evaluate total lifecycle emissions
Table 3 Possible functional units for IMO LCA Frameworks

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For gCO2e/MJ shaft work, it excludes the specific characteristics to a vessel, its operational factors,
but includes the engine’s efficiency and its emission. It has become established to report WTW
and TTW GHG emissions per shaft work (gCO2e/MJ shaft work or gCO2e/kWh engine output) based
on the engine efficiency. However, they do not represent actual WtW emissions since they
cover the performance at the propeller shaft.

On the other hand, GHG/carbon intensity of ships or the shipping sector refers to CO2 emissions
per transport work, for example, tonne-nautical mile, and therefore links CO2 emissions to the
amount of cargo transported and the distance sailed for a specific ship, as highlighted in the
document ISWG-GHG 11/2/4 (Angola et al). Transport work in the functional unit can be
considered as a unified unit in policies evaluating the performance of individual vessels. This would
allow the vessel to improve its performance and reduce the emission by adapting goal-based
approach using all available technologies, such as renewable energy (wind assist/solar), improved
design and operational measures as well as using fuel with lower lifecycle GHG emissions.
Although this unit postulates methods to evaluate the GHG/carbon intensity of ships/international
shipping from a lifecycle perspective, it cannot achieve the goal of the LCA Guidelines to provide
methods to calculate the GHG/carbon intensity of marine fuels. GHG emissions results on the
basis of a gCO2e/tonne-nm enable sound comparison, but necessitate knowledge of the
corresponding vessels being compared and differ significantly depending on the operational factor
(Laugen 2013, Sharafian, Blomerus, et al. 2019, Ashrafi, Lister et al. 2022)

One of the goals of the IMO LCA guideline is to account for GHG/carbon emissions from
ships/international shipping and all regulatory regimes which are based on the accounting of the
emissions from international shipping should strictly follow the principles set out in the 2006 IPCC
Guidelines for National Greenhouse Gas Inventories. In this aspect, the functional unit with
gCO2e/gfuel total is multiplied by fuel quantities consumed, thereby accounting for lifecycle
emissions through data from the IMO DCS. IMO DCS reporting of fuel consumption is based on
tons of fuel consumed and this can be also converted to MJ using the standard lower heating value
for the specific fuel.

A functional unit of gCO2e/gfuel and gCO2e/MJLHV, fuel may not be sufficient so that it can
directly compare the lifecycle emissions of new fuels or energy carriers, such as hydrogen,
ammonia, or electric batteries on the basis of fuel energy content because the efficiency of the
selected propulsion systems varies. However, the propulsion system efficiency, vessel
efficiency, and the impact of operational factors, are well captured in the fuel consumption
reported to the IMO DCS. For the EU and IMO policies, gCO2e/gfuel and gCO2e/MJLHV, fuel
will be a more appropriate unit to introduce an effective way for calculation well to wake
emissions based on fuel consumption.

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2.1.4. Attributional (A-LCA) and consequential (C-LCA) modelling

Amongst the several choices that need to be made for the LCA methodology, the one between
the attributional (A-LCA) and consequential (C-LCA) modelling (or also so-called marginal) is
very critical(Thomassen, Dalgaard et al. 2008). The use of modelling is fundamental, and is
selected at the phase of the goal and scope definition. The two LCA modelling terms are
defined as below (Sonnemann and Vigon 2011):

– Attributional approach: “System modelling approach in which inputs and outputs are
attributed to the functional unit of a product system by linking and/or partitioning the
unit processes of the system according to a normative rule.”

– Consequential approach: “System modelling approach in which activities in a product

system are linked so that activities are included in the product system to the extent that
they are expected to change as a consequence of a change in demand for the
functional unit.”

According to the European Council for Automotive R&D (EUCAR), the main differences
between the two approaches were indentified as shown in Table 4.

Attributional approach Consequential approach

Analysis of an average operation Analysis of changes in operation
Goal
(e.g., on an annual basis) (e.g., changes in demand)
For example, what are the potential
For example, what are the potential
environmental impacts of a
environmental impacts of the
Guiding decrease in fossil fuel demand due
average production of 1 ton of fuel
question to the increase in the use of
(under different technical
alternative fuels in the transport
conditions)?
sector?
Assigns elementary flows and
potential environmental impacts to Studies of the environmental
a specific product system typically consequences of possible (future)
Approach
as an account of the history of the changes within one or between
product. Can use scenario analysis multiple product systems
to project future technical situations
Table 4 Main differences between attributional and consequential modelling principles
(adapted from EUCAR)

Some studies argued that A-LCA is not suitable to support decision or policy making, e.g.,
climate policy, since A-LCA does not consider its consequences to use or avoid a product,
while C-LCA is well-established to this purpose (Brandão et al., 2014; Plevin et al., 2014).
However, other research adovocated that A-LCA is more appropriate for national emission
accounting and environmental taxation (Prapaspongsa and Gheewala, 2017).

For the CORSIA calculations, an A-LCA approach is basically adopted by accounting for
phisical flow, e.g., mass and energy, along the entire upstream process (ICAO 2019), while
ILUC GHG emissions are calculated through a C-LCA approach with economic models which
consider the estimated crop displacement land use change. To estimate ILUC emissions for
aviation biofuels, two economic models, GTAP-BIO and GLOBIOM, were used to minimise
significant uncertainty in ILUC emission results.

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A-LCA is used in regulatory frameworks in different world regions. For the purpose of setting
the target and defining the default value for WtW emissions for marine fuels in IMO, A-LCA
should be prioritised since it tends to reduce uncertainties, especially when allocation is
required. However, flexibility with extensions for marginal consideration or consequential
approach might be needed to capture the complexity of several feedstock-to-fuel pathways,
for example, biofuel emissions associated with induced land use change (ILUC).

2.1.5. Allocation method for coproduct

For a fuel production process that often produces multiple products, the environmental impacts
corresponding to products should be defined and assigned. Two allocation methods are most
widely applied to LCA studies. One is an allocation method, which divides inputs and impacts
between products according to a proportion of physical relationship (e.g., mass and energy
content) or other characteristics (e.g., market value). The other is called system expansion,
which expands system boundaries to take account of the impact of displaced products. System
expansion is the preferred LCA approach and it is often adopted in “consequential” LCAs.
According to ISO recommendations, allocation method should be based on physical
parameters, e.g., mass or energy content, if system expansion is not allowed (ISO 2006)

Although ISO standard suggests the abovementioned principles, the following regulations
define their own co-product handling methodologies. The European RED and CORSIA use
energy-based allocation methods and US Renewable Fuel Standard uses system expansion.
The other regulations, in particular biofuel policies, handle each co-product with different
allocation approaches (see Table 5) that the relevant legislation finds most fitting.

Legislation Region covered Allocation method

Renewable Transport Fuel
Obligation
Renewable Energy Directive
Low Carbon Fuel Standard
Renewable Fuel Standard
Table 5 Allocation choices in fuel policies(adopted from Wardenaar, Van Ruijven et al. 2012)
System expansion (or substitution)
UK approach whenever possible, if not
allocation based on economic value
Allocation based on energy content,
except for electricity co-production for
EU
which it is a system expansion (or
substitution)
System expansion (or substitution)
California approach whenever possible, if not
allocation based on energy content
System expansion (or substitution)
US
approach

As shown in Table 5, different allocation methods have been adopted depending on regions.
Various studies have shown that the amount of emissions generated to produce a product
varies depending on the allocation method (Kyttä et al., 2022). This circumstance not only lays
the uncertainty for marine fuel producers and shipping industries, but also result in different
regulations due to different interpretations for regulators.

While system expansion allocation method is highly complicated, physical allocation is

relatively easy to apply and its outcome is stable over time since the data is relatively
unambiguous. It should be noted that CORSIA and RED II, as international regulatory
measures, apply for energy based allocation. For most marine fuels and their co-products, the
allocation method based on energy content could be the most suitable when the co-products
are involved in energy based products. Although this situation will not be able to avoid all
uncertainty such as data issues, the method’s conciseness will improve the policy’s robustness.

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2.1.6. Indirect emissions

While many LCA studies on biofuels evaluates the direct emissions from cultivating feedstocks
and producing biofuels, some studies suggest that biofuel production may give rise to a number
of undesirable effects because the expansion for cropland due to overall demand for biofuel
production may generate indirect GHG emissions including indirect land-use change (ILUC).

In the case of some biofuels, there is a clear scientific consensus that ILUC can have a
significant impact on lifecycle GHG emissions (Woltjer et al., 2017). Policies should not ignore
indirect emissions related to production of alternative fuels. It is believed that a robust LCA
methodology may need to account for the "consequential" GHG emissions associated with
land use change (LUC).

IPCC land usage covers the following categories: forestland, grassland, wetlands, settlements,
or other lands. Cropland or perennial cropland included in those categories should be used as
a basis to define feedstock production for which a direct land-use change occurred. When food
and feed crops are used to produce biofuels, for use in maritime transport, their use should be
limited to defined sustainability criteria. In this regard, specific sustainability criteria have to be
adopted, such as criteria for land with high carbon stock, high biodiversity value and indirect
land-use change (ILUC).

2.1.7. LCA Database/ Modeling Tool

The different LCA databases/tools were identified among the analysed studies focusing on
marine fuels, as shown in Table 1. In particular, the Ecoinvent, the European Reference Life
Cycle Database (ELCD), GREET, Gabi and SimaPro were mainlytaken into account.

The Ecoinvent is one of the most comprehensive LCI database and reliant on industry-vetted
averages. The Joint Research Centre of the European Commission formulated the ELCD
under the framework of the European Platform on Life Cycle Assessment. GREET was found
to be well established to evaluate emission impacts of transportation fuels including the
analysis of alternative marine fuels although it has limitation to cover only a North American.
GaBi is also one of the largest consistent LCA software and databases developed by PE
international GmbH, Germany. SimaPro is developed by PRé Sustainability, Netherlands.

In this paper, the coverage differences were found through comparisons between databases,
existing main standards and regulations related to LCA, as indicated in Table 7.

One of the reasons causing the significant differences among the result from LCA studies was
orginated from the LCA database they adopted. In this regard, in selecting the relevant
emission data, the undestanding of transparent database and reference is critical for
quantifying uncertainty as well as improving uncertainties.

2.1.8. Sustainability criteria and certification scheme

In order to draw a clear picture of the sustainability of marine fuels, environmental, social and
economic matters should be addressed over the lifecycle of the fuel (Ashrafi, Lister et al. 2022).

Ashrafi, Lister et al. identified and classified 18 sustainability criteria, as shown in Table 6
through the extensive academic literature, and a multi-stakeholder participatory approach was
applied for a systematic and consistent assessment of marine fuels (Ashrafi, Lister et al. 2022).

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Marine fuel used onboard ships should be sustainable in terms of environment, society and
economy, and underpinned by the continuous enhancement of its sustainability aspects.
Sustainability issues from a lifecycle perspective should be well-understood to further allow for
informed policy decision-making and help final decision for investment (Andreea Miu 2021).

The term“GHGs and carbon intensity” included in the title of IMO LCA guidelines does not
cover a fraction of the sustainability issues. Howerver, considering existing sustainability
approaches, e.g., Roundtable on Sustainable Biomaterials (RSB) and International
Sustainability & Carbon Certification (ISCC), the guidelines should expand the scope into not
only WtW GHG emissions but also sustainability criteria related to all fuels for propulsion and
operation on board a ship (IMO 2022).

Environmental Economic Social

• Life cycle GHG • Capital expenditures • Regulatory

compliance
• Air pollutions • Operational
expenditures • Social acceptability
• Ocean acidification
• Fuel cost • Ethics and social
• Ecosystem
responsibility
degradation • Opportunity cost
• Public health impact
• Depletion of natural • Safety-related risk
resources costs • Occupational health
and safety
• Land use change • Possible regulatory
penalty • Socio-economic
development
Table 6 Economic, environmental, and social criteria for evaluating alternative marine fuels
(adapted from Ashrafi, Lister et al.)

From a regulatory perspective, there are several existing regulations that also actively use
sustainability criteria as a way to evaluate the sustainability of fuels for transport, such as
ICAO’s CORSIA and the EU RED II. Especially, ICAO, which is a UN’s specialized agency like
IMO, developed a framework to not only define which fuels are eligible but also include
sustainability criteria. CORSIA eligible fuel (CEF) consists of two types: lower carbon aviation
fuels (LCAF) and sustainable aviation fuels (SAF).

While LCAF are fossil-based aviation fuel with lower life-cycle emissions than coventional fuels,
SAF should be produced from renewable or waste-derived sources. In order to meet CEF
criteria, it should be at least 10% lower life-cycle GHG emissions than conventional fossil
based fuels, and not be produced from biomass obtained from land with high carbon stock
(ICAO 2019). The Committee on Aviation Environmental Protection (CAEP) developed a
sustainability certification processes and elements based on existing sustainability approaches,
e.g., RSB and ISCC, to make sure that the process is feasible.

The CEF should be supplied from fuel producers that are certified by an approved sustainable
certification scheme. This scheme is an example of how IMO regulation and guidelines can
incorporate certification schemes. Figure 3 shows the processes and elements of sustainability
certification between CORSIA and the International Carbon and Sustainability Certification
(ISCC).

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Figure 3 The processes and elements of CORSIA and ISCC (adapted from ISCC)

With regard to certification schemes for GHG emissions, IMO LCA guidelines considered to include
the criteria and procedure for recognising certification schemes, which enable the use of certified
actual emission values with better performance than the default value. The reliable certification
schemes are needed to provide assurance if chemically-identical fuels come from renewable
sources or produced from fossil fuels.

The sustainability criteria as developed by ICAO to support CORSIA may be useful for IMO
discussions. Considering the urgent need for the development of LCA guidelines for marine fuels,
IMO may consider a phased approach: phase 1 for life cycle emissions reductions and for
feedstock not to be obtained from land with a high carbon stock and phase 2 for additional criteria
to address other aspects of sustainability (e.g., impacts to water, soil, and air).

Sima-
CORSIA Ecoinvent GREET Gabi JEC2 RED II
Pro
Type Regulation Y N N N N Y N
Certification scheme Y N N N N N N
Default value Y Y Y Y Y Y Y
WtT Life cycle GHG Y Y (CO2 only) Y Y Y Y Y
Air pollutions N N Y Y N N Y
Sustainability

Acidification N N Y Y N N Y
criteria

Depletion of
natural N N Y Y N N Y
resources
Land use
Y N Y Y N N Y
change
Carbon capture N Y Y N Y Y N
Carbon storage N Y Y N Y N N
TtW Coverage for the marine
N Y Y Y N Y N
sector
Table 7 Comparision between existing main standards, regulations and databases related to LCA

2 It was co-developed by the JRC, EUCAR and Concawe to assess the sustainability of the European vehicle
and oil industry.

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2.2. How do we develop GHG emissions factors for accounting the emissions from
international shipping sector?

2.2.1. Proposals in IMO /FuelEU Maritime

GHG emission factor (CO2 equivalent factor) should enable the evaluation of fuels on Global
Warming Potential (GWP) and can be used for accounting all relevant GHG emissions. One
of main aims of IMO LCA guidelines is to develop the WtT and TtW emission factors for all
marine fuels. The WtW GHG emission factor (GHGWtW, g CO2eq/MJ fuel, or g CO2eq/MJ for
electricity) can be calculated as the sum of the WtT and TtW emission factors, labelled GHGWtT
and GHGTtW respectively as follows:

𝐺𝐻𝐺WtW = 𝐺𝐻𝐺WtT + 𝐺𝐻𝐺TtW

This section mainly addresses the TtW emission factor rather than WtT emission factor, while
section 2.1 elucidates methodological differences which give a relatively significant impact on
WtT emission factor. The role of TtW emission factor is to be able to accurately calculate the
GHG emissions of international shipping. It is important to develop a reliable TtW emission
factor for the possible application of regulations such as CII.

Most previous LCA studies on marine fuels, listed in Table 1, used the following equation to
evaluate TtW emission factors (𝐺𝐻𝐺WtT) when the GWP emissions from ships are expressed
as the combination of CO2, CH4 and N2O impacts:

GHGTtW = CfCO2 + CfCH4 х GWPCH4 + CfN2O х GWPN2O

During discussion on LCA guidelines for marine fuels at IMO, several equations for GHGTtW
were proposed, which are numerical methods slightly different from the equation above applied
in the vast majority of previous LCA studies. In this regard, this paper compared the several
options for calculation method for GHGTtW and their GHG impact.

Proposed detailed calculations on TtW emission factors are shown in Table 8. Two main
differences of the proposed methods were identified in terms of calculation 1) on method on
reflecting methane emissions into total GHG emissions and 2) introduction of carbon source
factor. FuelEU Maritime proposal provided indicative default emission values depending on
LNG engine types; LNG Otto cycle engine with dual fuel medium speed (4 stroke), LNG Otto
cycle engine with dual fuel slow speed (2 stroke) and LNG Diesel cycle engine with dual fuels,
as indicated in Table 9.

Based on these proposed formulas (Table 8) and default emission values (Table 9), this paper
analysed the results on calculating GHG emission factor including methane slip depending on
calculation method and introduction of carbon source factor.

Source Proposed formula(s)

EU proposal (IMO
1 𝐺𝐻𝐺TtW = (1 – 𝐶slip ) · 𝐶𝑂2eq TtW + 𝐶slip · 𝐺𝑊𝑃CH4
2021), FuelEU Maritime 𝐶𝑂2eq TtW = 𝐶f CO2 + 𝐶f CH4 ∗· 𝐺𝑊𝑃CH4 + 𝐶f N2O · 𝐺𝑊𝑃N2O
Norway-led proposal
2 𝐺𝐻𝐺TtW = 𝑆f ∙ 𝐶f CO2 + 𝐶f CH4 · 𝐺𝑊𝑃CH4 + 𝐶f N2O · 𝐺𝑊𝑃N2O
(IMO 2021)
EU-Norway led proposal 𝐺𝐻𝐺TtW = [(1 – 𝐶slip )
3 · (𝑆f ∙ 𝐶f CO2 + 𝐶f CH4 · 𝐺𝑊𝑃CH4 + 𝐶f N2O · 𝐺𝑊𝑃N2O)
(IMO 2022)
+ (𝐶slip · 𝐺𝑊𝑃CH4) − 𝑒occs ]
Table 8 Detailed equations on TtW emission factors (𝐺𝐻𝐺TtW)

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Note: 𝑆f : Carbon source factor, 𝐶slip : Coefficient accounting for fuel (methane) slip (share of the total fuel in use),
𝐶f CO2 : CO2 emission conversion factor (g CO2/g fuel), 𝐶f CH4 : CH4 emission conversion factor (g CH4/g fuel),
𝐶f N2O : N2O emission conversion factor (g N2O/ g fuel), GWP : Global Warming Potential corresponding to GHG,
𝑒occs : emission savings from on-board CO2 capture and geological storage, CO2eq , TtW, i : combustion emissions
factors and it is not related to slip

Figure 2 Schematic diagram for GHG emission and methane slip emitted in the combustion
chamber of engines (Left) and for a case that carbon source factor is considered as zero for
accounting purpose (Right)

2.2.2. Methane emission factor

Figure 2 shows an example of conceptual schematic of GHG emission by combustion process

and unburned methane, i.e. methane slip emitted in the combustion chamber of engines from
ship. Methane slip is considered as most relevant fugitive emissions at the current technology
state, in particular for 4-stroke dual fuel engines (IMO 2020). However, according to the studies
investigated in Table 1, different methane emission factors have been applied due to the
different definition/scope of the methane slip. The amounts of methane slip varies pursuant to
differences in engine use, operating conditions, makers, and technology.

In this regard, an appropriate definition should be developed to capture the methane emissions
from the ship’s operation and then the procedures or methodology for measuring methane
emission or calculating its emission factor should be defined. It would be effective way to follow
the current procedures for NOx emission measurements specified in the NOx Technical Code
2008, which is a well-established practice, to ensure the consistent implementation within IMO
instruments(as proposed in the document MEPC 78/7/13).

With regard to the emission factors, while Norway led proposal (IMO 2021) includes not only
combusted emissions but also the amount of methane slips in the term “Cf CH4 ·GWPCH4”, EU
proposal (IMO 2021) deals with combusted emissions in the term “Cf CH4 ·GWPCH4” of CO2eq
TtW and considers the methane slip seperately in “Cslip· GWPCH4 ” term (See Table 8). The
calculation results of TtW emission factor (gCO2eq/g) depending on methane slip % can be
summarized in Figure 3. In general, the emission factors calculated by EU proposal was found
to have the higher GHG emission factor.

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It clearly indicates that a different amount of GHG emissions generated by ship can be
estimated depending on proposed method. The maximum difference gap of emission factor
was found in dual fuel engine with 3.1% of methane slip. It shows that the greater methane
slip is, the larger the emission factor’s gap between two proposal.

Figure 3 The calculation result of TtW emission factor (gCO2eq/g) depending on methane slip %

WtT TtW
CO2eq
Energy CfCO2 CfCH4 CfN2O
Pathway LCV WtT Cslip
Reference Converter [gCO2/ [gCH4/g [gN2O/
name [MJ/g] [gCO2 [%]
Class gFuel] Fuel] gFuel]
eq/MJ]
LNG 17.7 - LNG Otto
SINTEF 2020,
0.0491 18.5 (dual fuel
Sphera 3.1
medium
Bio-LNG speed)
Main LNG Otto
products / (dual fuel
wastes / 1.7
slow
Feedstock 0.05 -38.9 RED II
speed) 2.755 0 0.00011
mix LNG Diesel 0.2
(dual fuels)
LBSI N/A
RED WFLG2
e-LNG/EU
(from biomass
electricity 0.0491 -26.6
gasification)
mix

Table 9 Default WtT and TtW values and slip factors for LNG fuel (partially adopted from
ISWG-GHG 11/2/3)

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2.2.3. Introduction of carbon source factor

The concept of the carbon source factor (Sf) was introduced to address the need for correctly
accounting for CO2 emissions from international shipping sector according to IPCC guidelines
(IMO 2021). For example, the IPCC guidelines stipulate that CO2 emissions from biomass-
based products or biomass combustion for energy should not be captured and reported in
sectors of national GHG inventories where the biomass was combusted but should be reported
as an information item for cross-checking purposes. The CO2 emissions from biomass
combustion are estimated and accounted for in the Agriculture, Forestry and Other Land Use
(AFOLU) sector as net changes in the carbon stocks (Sf = 0). This means that the TtW CO2
emission for bio-fuel should be reported as zero (Figure 2). The actual emissions are also
recommended to be reported to avoid double-counting. A biofuel can have zero reported CO2
emissions in the TtW phase, while still have GHG emissions in the WtT phase.

When calculating the TtW GHG emissions according to the IPCC accounting principles a
carbon source factor (Sf) should be applied. The factor determines if the TtW CO2 emissions
should be accounted for in the IMO GHG inventory for international shipping (Sf = 1) or not (Sf
= 0) and should be multiplied with the CO2 emission factor for the specific fuel (Cf). In other
words, for marine fuel production pathway, different forms of energy, such as electricity, steam,
fuel gas, etc., may be used. If the carbon source of energy used in the fuel production process
is fossil-based (Sf = 1), GHG emissions created by using the energy source need to be
accounted for in the LCA, and the emissions from ship using fossil-based fuel should be
considered as foot print of shipping sector. However, if the source of energy used during a
process is biogenic, renewable fuels, or recycled carbon (Sf = 0), the combustion CO2
emissions released as a result of using these energy sources are circular and should not be
accounted in emissions from international shipping because the net CO2 avoidance will be re-
adsorbed by plants or captured and reused.

Figures 5 to 10 show examples of calculation results for LNG TtW emission factors according
to proposed equations on TtW emission factors (𝐺𝐻𝐺TtW) (see Table 8), using default WtT and
TtW values and slip factors in Table 9.

When calculating WtW emission factors for Bio LNG and e-LNG where Sf is zero, calculation
results via Norway-led proposal (IMO 2021) may result in distorted values(See Figures 6, 8
and10). For this reason, as per EU-Norway led proposal (IMO 2022), the carbon source factor
(Sf) should always be 1 for the purpose of calculating GHGTtW in the equation of WtW
emission factors.

Figure 4 TtW emission factors (𝐺𝐻𝐺TtW) for fossil-based LNG, Bio LNG and e-LNG (LNG
Otto 4 stroke)

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Figure 5 WtW emission factors (𝐺𝐻𝐺WtW) for fossil-based LNG, Bio LNG and e-LNG (LNG
Otto 4 stroke)

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Figure 6 TtW emission factors (𝐺𝐻𝐺TtW) for fossil-based LNG, Bio LNG and e-LNG (LNG Otto
2 stroke)

Figure 7 WtW emission factors (𝐺𝐻𝐺WtW) for fossil-based LNG, Bio LNG and e-LNG (LNG
Otto 2 stroke)

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Figure 8 TtW emission factors (𝐺𝐻𝐺TtW) for fossil-based LNG, Bio LNG and e-LNG (LNG
Diesel cycle)

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Figure 9 WtW emission factors (𝐺𝐻𝐺WtW) for fossil-based LNG, Bio LNG and e-LNG (LNG
Diesel cycle)

3. Conclusion

The global shipping industry has indeed observed increasing commitments, popularity and
interests of low- and zero-carbon fuels to achieve decarbonisation of the sector in time in spite
of the scarcity of relevant studies with uniformed LCA methodologies for informed decision-
making on eligible alternative marine fuels. In this study, various preceding LCA studies and
currently available regional policies as well as the aviation sector’s approach have been closely
examined with a view to facilitating the development of IMO LCA guidelines for marine fuels
and looking to a better way to guide future LCA policy development and decision-making.

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Assuredly, the current IMO instruments have room for improvement in terms of supporting the
uptake of these fuels. A well-developed IMO LCA framework on marine fuel, in this context,
should be introduced to not only assess their environmental performance and sustainability
but also minimize the unintended consequences. It could be effective in not only ensuring a
level playing field but also gradually building up the fuel production and the bunkering
infrastructure. In light of the foregoing, the development of robust LCA guidelines is essential
before implementation of regulation such as Low GHG Fuel Standard (LGFS) concept to
regulate an annual average WtW emission below a required level. In consequence, this study
has encapsulated the following technical aspects from the literature review for the IMO’s
consideration in the development of IMO LCA framework for marine fuels:

- The GHGs should include CO2, CH4, and N2O since these represent the majority of
GHGs emitted in shipping sectors

- GWP over 100 years should be considered in order for IMO policies to stay in line with
the UNFCCC and other widely accepted international reporting standards for GHG
emissions with a view to facilitating comparative assessment with other sectors

- For the EU and IMO policies, gCO2e/gfuel and gCO2e/MJLHV, fuel will be a more
appropriate unit to introduce an effective way for calculation well to wake emissions
based on fuel consumption

- For the purpose of setting the target and defining the default value for WtW emissions
for marine fuels in IMO, A-LCA should be prioritised since it tends to reduce
uncertainties

- The allocation method based on energy content could be the most suitable when the
co-products are involved in energy based products

- A robust LCA methodology may need to account for the "consequential" GHG
emissions associated with land use change (LUC) which can be addressed within one
of the specific sustainability criteria.

- IMO may consider a phased approach on sustainability criteria: phase 1 for life cycle
emissions reductions and for feedstock not to be obtained from land with a high carbon
stock and phase 2 for additional criteria to address other aspects of sustainability (e.g.,
impacts to water, soil, and air)

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