Ref. Ares(2022)7851869 - 14/11/2022
NOTE TO THE FILE
ECSA Board Meeting
30 June 2022
Participants COM : R. Lesovici (CAB VAlean),
(DG MOVE)
Context : we were invited to present the Fitfor55 package to the ECSA Board meeting.
Main points discussed in the meeting:
• Shared responsibility with fuel suppliers in FuelEU: Commission took the opportunity to
highlight the relevant elements that would deem impracticable a proposal for shared
responsibility with Fuel Suppliers. RED was highlighted as the key instrument that should
contain al relevant requirements on Fuel Producers/ Suppliers. Topic was more marked by
Union of Greek Shipowners. Responsibility of fuel suppliers to be defined in a context of fuel
supply contracts between operators.
• Fuel Non-Availability Report (FONAR): Highlighted by ECSA as a cornerstone of the
shipowners proposal – FONAR was reiterated by ECSA as an essential possibility for
operators to justify non-availability of compliant fuel. The demonstration of compliance with
FuelEU is however based on the average GHG intensity of the energy used onboard, not
al owing to determine what would be “non-compliant” fuel.
• Fuel Availability: ECSA expressed concerns. Commission used the opportunity to underline
the relevance of the work just started by the Renewable and Low-Carbon Fuels Alliance.
• Fuel Certification: Some shipowners raised concerns regarding the quality of fuels, especially
if/when purchased outside the EU. Further questions raised regarding the reassurance of
quality of blended fuel products.
• Scope of Emissions for FuelEU vis-à-vis ETS: discussed the scope of emissions both in FuelEU
maritime and ETS, with shipowners raising concerns regarding the Well-to-Wake VS Direct
Stack Emissions, respectively, of both approaches. Commission highlighted the development
of Delegated Acts in ETS which will consider differentiation based on biogenic/renewable
synthetic origin of carbon-based fuels.
Roxana Lesovici