IMO Updates Guidance on Carriage of Biofuels by Conventional Bunker Ships

The International Maritime Organisation (IMO) has approved its Interim Guidance on the Carriage of Blends of Biofuels and MARPOL Annex I Cargoes by Conventional Bunker Ships.

Although the new guidelines (MEPC.1/Circ.917) are not mandatory, they are likely to be considered by flag Administrators and their Recognised Organisations in the acceptance of carriage of biofuel blends. 

So, what does the guidance cover? To put it in the simplest possible terms, the IMO has stated that ‘the maximum blend ratio (by volume) of biofuel and MARPOL Annex I cargoes (e.g. petroleum derived oils) permitted to be carried by a “bunker ship” has increased from 25% to 30% biofuels’. 

However, this is dependent on: 

• The “bunker ship” being an oil tanker, as defined in Regulation 1.5 of MARPOL Annex I, that is certified under MARPOL Annex I to carry, transport and deliver fuel oil for use by ships.
• All residues or tank washings have been discharged ashore, unless the oil discharge monitoring equipment is approved for the biofuel blend(s) being shipped. 

The IMO stipulates that should a bunker ship meets these criteria, it does not need to modify its International Oil Pollution Prevention Certificate.

Guidance has also been set out for ships carrying more than 30% biofuels. In which instance, the provisions of MARPOL Annex II (Regulations Controlling Carriage of Noxious Liquid Substances in Bulk) and Chapter 17 of the International Code for Construction and Equipment of Ships Carrying Dangerous Chemicals in Bulk (IBC Code) apply.

Guidance for biofuel-carrying ships other than bunker ships

With an increasing number of ships other than bunker ships carrying biofuels, the IMO has set out non-bunker ship guidance. This is as follows: 

• 25% or less: biofuel blends and MARPOL Annex I cargoes with 25% (by volume) or less biofuel are to be considered MARPOL Annex I cargo and are required to comply with MARPOL Annex I.
• More than 25%: biofuel blends and MARPOL Annex I cargoes with more than 25% (by volume) biofuel are to be regarded as MARPOL Annex II products and must comply with the requirements set out in Chapter 17 of the IBC Code. 

The biofuels that are covered by the Interim Guidance (in the context of MARPOL Annex II and as indicated in the MEPC.2/Circular, Annex 11) are: 

• tert-Amyl ethyl ether.
• Ethyl alcohol.
• Fatty acid methyl esters (FAME). 
• Vegetable fatty acid distillates.

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