6.4.2022
EN
Official Journal of the European Union
C 152/147
the maritime value chain, especially fuel production and energy providers, engine manufacturers, but also ports, charterers and the workers’ representatives in all involved sectors.
Well targeted, clear, cyclical and transparent communication is essential for gaining the involvement and supportive contribution of society.
3.2.
The impact of the FuelEU Maritime Regulation proposal on shipping is uneven compared to other industries: short-term measures into 2030 are adequately described, but long-term changes that will deliver the bulk of the reduction in greenhouse gases in 2030-2050 are still largely target-shooting, comprising technologies that have not yet been developed, let alone matured.
In other words, the shipping sector’s pathway to climate neutrality by 2050 is still uncertain, involving a wide range of technological options.
In addition, there are major open questions about the supply, safety, distribution and costs of these alternatives.
Hence, a certain degree of flexibility should be built into the regulatory parts of this proposal in order for the industry to be able to adapt to it.
Moreover, an urgent time pressure stems from the long lead time and the heavy upfront investment cycle of the wider sector covering all stakeholders.
3.3.
On the one hand, the trajectory of emissions towards full decarbonisation hinges on the introduction and market uptake of economically viable and safe zero emission fuels and technologies.
On the other hand, new means of propulsion, new low carbon or carbon-free fuels available worldwide and a joint collaborative effort with stakeholders in the supply chain are necessary to ultimately reach full decarbonisation.
3.4.
Under the scope of the ‘Fit for 55’ legislative package, the FuelEU initiative needs to provide synergies, coherence and consistency between supply, distribution and demand.
This should be achieved by effectively complementing the Renewable Energy Directive (RED) (5) targeting the supply of energy from renewable sources in particular and the Alternative Fuel Infrastructure Regulation targeting distribution infrastructure in EU ports (6).
3.5.
To this end, providing the right incentives between supply and demand is also essential.
However, the draft FuelEU Regulation, at the moment, prescribes particular low carbon fuels, as all alternative fuels should be allowed, with no prior assessment of their global availability and cost.
This may eventually lead to distortion of competition, while their availability presently and for the near future is negligible.
The responsibility for the development and availability of renewable alternative fuels lies with the fuel suppliers and the uptake of cleaner fuels should be encouraged.
For this to happen, the price gap between fossil and alternative fuels needs to be bridged and the cleaner fuels need to become more affordable and widely available.
Efforts are required, involving the active contribution of all actors in the maritime value chain, especially fuel production and energy providers, engine manufacturers, but also ports, charterers and the workers’ representatives in all involved sectors.
This could potentially result in an increase of the demand for alternative fuels as envisaged by the FuelEU Regulation.
3.6.
In mandating the uptake of cleaner fuels and biofuels in particular, the proposal seems to be ignoring the fact that such fuels may in reality never be available in sufficient quantities for international shipping and may not really be a viable alternative to fossil fuels.
Imposing administrative fines in a situation where viable alternatives do not exist is punitive and a revenue-generating rather than an emissions-abatement measure.
3.7.
The zero/low-carbon fuels required for shipping to decarbonise are currently unavailable, especially for deep-sea shipping, and will remain so in the near future.
Huge investments are required for the production and worldwide availability of these fuels, which will have to be developed by out-of-sector stakeholders, namely, oil companies and energy suppliers more generally.
In addition, alternative fuels, such as ammonia, methanol or hydrogen need a new generation of internal combustion engines and advancements in ship design and propulsion technologies, which come under the purview of engine manufacturers and shipyards, most of which are located in the Far East.
3.8.
Pending the development of these alternative fuels, the long-term goals of the agreed IMO Initial Strategy for decarbonisation and the ambitious objectives of the European ‘Green Deal’ and ‘Fit for 55 Package’ cannot be achieved.
More science-based profound knowledge is needed sooner in order to reduce decision-making risks and to be orientated towards the right investments.
This is why the industry, along with several Member States with substantial maritime interests, made the proposal at the IMO to set up an R & D Board and Fund (the IMRB and IMRF proposal) to be funded
(5) (6)
COM(2021) 557 final.
COM(2021) 559 final.