Tank-based reporting: simplifying biofuel tracking and compliance

ZeroNorth Editorial
Tuesday, January 21, 2025

Introduction to tanker fuel management challenges

Managing fuel storage and segregation is a delicate dance on tanker vessels. The typical fuel grades carried include Very Low Sulfur Fuel Oil (VLSFO), Marine Gas Oil (MGO), and increasingly, biofuel blends like B30 (30% biofuel, 70% conventional fuel). However, the physical limitations of tank layouts and sizes pose significant challenges in accommodating multiple fuel grades simultaneously.

Tank configurations vary across vessel types, often with a limited number of sizable tanks suitable for primary fuel storage. Accommodating too many fuel grades risks comingling and contamination, which can compromise fuel quality and compliance. As such, tanker operators must carefully juggle their fuel inventory, strategically planning bunkering operations and voyage routing to minimise the need for carrying excessive fuel grades concurrently.

Avoiding comingling is a top priority, as it can lead to off-spec fuels and potential engine damage. Stringent procedures are in place to ensure tanks are emptied before loading a new fuel grade, adding another layer of complexity to fuel management. With the introduction of biofuel blends, the challenges intensify, as these new fuel types must be meticulously segregated and tracked to maintain compliance and sustainability claims.

The rise of biofuel mandates

The shipping industry is facing increasing pressure to reduce its environmental impact, leading to the introduction of biofuel mandates such as FuelEU. This regulation aims to promote the use of sustainable biofuels in maritime transportation, with the goal of reducing greenhouse gas emissions.

Under FuelEU, vessels operating in the European Union will be required to incorporate a specific percentage of biofuels into their fuel mix. Initially, the mandate will require a 2% biofuel blend for the first five years, gradually increasing to 6% in subsequent years. However, it is important to note that biofuels are not expected to completely replace traditional bunker fuels like VLSFO and MGO. Rather, they will be used as a supplementary fuel source to help meet decarbonisation targets.

The introduction of biofuel mandates presents new challenges for tanker operators. While biofuels offer a more sustainable alternative, they also introduce complexities in terms of tracking, compliance, and fuel management. Ensuring compliance with regulations like FuelEU will require robust systems and processes to monitor and report on biofuel usage accurately.

Complexities of biofuel tracking and compliance

As the shipping industry transitions towards using more biofuels to meet environmental regulations, vessel operators face new challenges in tracking and proving compliance. Unlike traditional fossil fuels, biofuels often come in batches with varying levels of bio-components and sustainability certifications. 

Proper tracking of these batches is crucial to demonstrate that the correct biofuel grade was consumed during specific voyages. However, maintaining a clear chain of custody can become complicated, especially when multiple biofuel batches are loaded onto a single vessel. Mistakes in batch tracking could lead to discrepancies between the reported fuel consumption and the actual biofuel used.

Moreover, verifying the sustainability credentials of biofuel batches is a critical aspect of compliance. Certain biofuels may not meet the required standards for greenhouse gas emissions reductions or sustainable sourcing practices. Without proper documentation and proof of sustainability, these biofuel batches could be deemed non-compliant, potentially resulting in penalties or fines.

To avoid such risks, vessel operators must be diligent in their biofuel tracking and reporting from day one of new regulations taking effect. Establishing robust processes and systems to accurately monitor biofuel batches, their associated sustainability certifications, and their consumption patterns is paramount. Failure to do so could jeopardize compliance efforts and undermine the environmental benefits of using biofuels in the first place.

Traditional batch-based reporting approach

The traditional approach to fuel reporting on ships has been based on the concept of batches and Bunker Delivery Notes (BDNs). Each time a vessel takes on fuel, a BDN is issued, detailing the quantity and grade of the fuel supplied. The common practice is to follow a "first-in, first-out" (FIFO) logic, where the fuel batches are consumed in the order they were loaded onto the ship.

From the perspective of verifiers, such as classification societies, the BDN serves as the primary proof of the fuel quantities and grades received by the vessel. In the context of emissions reporting and compliance, verifiers have typically relied on spot-checking BDNs against the reported fuel consumption data. The underlying assumption is that vessels are consuming fuel batches in the FIFO order, as indicated by the chronological sequence of BDNs.

This batch-based reporting approach has been seen as relatively straightforward and aligned with the operational practices of most vessels. By adhering to the FIFO logic and cross-checking with BDNs, verifiers can gain reasonable assurance that the reported fuel consumption figures are accurate and consistent with the fuel supplied to the vessel.

However, as biofuel mandates and sustainability requirements become more stringent, the traditional batch-based reporting approach may face challenges in providing the level of granularity and traceability required for demonstrating compliance with evolving regulations.

Tank-based reporting for stricter compliance

As biofuel mandates like FuelEU come into effect, there is a growing concern among shipping companies about ensuring strict compliance from day one. While verifiers have indicated that a batch-based "first-in, first-out" approach aligned with Bunker Delivery Notes (BDNs) may suffice, some experts argue for a more conservative risk minimisation strategy.

The tank-based reporting approach involves tracking exactly which fuel batches are loaded into which tanks on a vessel. This level of granularity allows for precise monitoring of biofuel consumption, ensuring that the right batches are being used at the right times, and enabling full traceability back to the BDNs and proof of sustainability documentation.

ZeroNorth's eBDN platform emerges as a flexible and powerful enabler of both batch-based and tank-based reporting approaches. By seamlessly associating BDNs with specific tanks, eBDN ensures detailed traceability of fuel batches and supports compliance with biofuel sustainability requirements. This adaptability allows operators to transition between reporting methods effortlessly, aligning with operational priorities or regulatory needs as they evolve.

By knowing the specific contents of each tank, shipping companies can avoid potential issues that may arise from a first-in, first-out logic. For instance, if multiple biofuel batches are on board and one lacks proper sustainability certification, the vessel may choose to consume the certified batch first, even if it is newer, violating the first-in, first-out assumption. With eBDN's ability to track and document such decisions, operators can ensure compliance while optimising their fuel strategies.

While tank-based reporting adds complexity, it provides a safeguard against potential compliance risks and fines. As regulations continue to evolve and become stricter, having a robust system like eBDN in place that can adapt to changing requirements becomes increasingly valuable. By erring on the side of caution and implementing a more comprehensive fuel tracking solution from the outset, shipping companies can future-proof their operations and minimise the risk of non-compliance penalties.

Digital solutions for fuel management

To effectively navigate the complexities of managing multiple fuel grades, biofuel batches, and compliance reporting, digital fuel management solutions have emerged as powerful enablers. By leveraging data and automation, these tools can streamline the tracking of batches, BDNs (Bunker Delivery Notes), and tank levels across the fleet.

One of the key advantages of digital fuel management platforms is their ability to automate the association between fuel batches, BDNs, and the specific tanks they are loaded into. This traceability is crucial for maintaining an audit trail and ensuring compliance with regulations that mandate proof of sustainability for biofuels.

Moreover, these solutions often incorporate contextual reporting capabilities. This means that the level of reporting granularity can be adjusted based on whether biofuels are present on a particular vessel. If a ship is not carrying any biofuel, the system can automatically switch to a simpler grade-based reporting approach, reducing administrative overhead. However, when biofuels are loaded, the system can seamlessly transition to a more comprehensive tank-based reporting mode, ensuring meticulous tracking of batch consumption.

The true power of digital fuel management tools lies in their ability to enable quick adjustments to reporting strategies. As regulations evolve and compliance requirements shift, these platforms can adapt swiftly. If a decision is made to switch from a batch-based approach to a tank-based approach mid-voyage or mid-year, the system can accommodate this change without disrupting operations.

By consolidating data from various sources, such as procurement systems and bunker supply events, these solutions can maintain an up-to-date record of the remaining on-board (ROB) quantities for each batch and tank. This information can then be leveraged for data-driven decision-making, optimising tank usage and minimising the risk of contamination or comingling.

Conclusion: mastering the tanker fuel tetris

The shipping industry faces a complex juggling act in managing multiple fuel grades, especially with increasing biofuel mandates disrupting traditional bunkering and storage approaches. Physical tank layout limitations, avoiding comingling, tracking batch sustainability, and ensuring compliance from day one pose significant challenges. 

While batch-based reporting aligns with some verifier guidance, many experts recommend the more granular tank-based approach to minimise compliance risks as regulations evolve. Digital fuel management solutions enable automated tracking of batches, BDNs, tank levels, and contextual reporting based on biofuel use. 

Data-driven decision-making optimises tank usage across a diverse fleet. Crucially, these tools provide the flexibility to adapt reporting approaches if requirements change under stricter future decarbonisation rules beyond biofuels.

As the industry transitions towards greater renewable fuel adoption, full transparency, traceability, and the ability to manage complex fuel tetris games will be critical. Implementing flexible digital fuel management solutions today paves the way for sustainable compliance in an increasingly decarbonised future.