The Global Centre for Maritime Decarbonisation (GCMD) has released a report titled 'Quantity assurance in marine biofuel supply chains,' which identifies a significant risk: marine biofuel blends might contain less renewable content than what buyers pay for, despite supplier declarations on bunker delivery notes. This finding suggests that existing documentation practices are insufficient to guarantee the actual biofuel percentage, which is crucial for compliance with environmental regulations.
This issue is particularly pertinent for regulatory frameworks such as the EU Emissions Trading System (ETS) and FuelEU Maritime. The renewable component, typically fatty acid methyl esters (FAME) or hydrotreated vegetable oil (HVO), directly influences a blend's eligibility for these schemes. If the actual renewable content is lower than declared, vessels and their operators could face compliance penalties or fail to meet their decarbonisation targets.
For freight forwarders and shippers, this means increased scrutiny is required when procuring marine biofuels. Relying solely on a bunker delivery note might expose them to compliance risks and potential financial liabilities if the fuel's actual composition does not match its certification. It underscores the need for more robust verification processes beyond standard documentation to ensure the integrity of the biofuel supply chain. This could involve independent testing or more stringent contractual clauses with fuel suppliers to mitigate the risk of under-blending and ensure that sustainability investments yield genuine environmental benefits.

