Sustainable maritime fuels (FuelEU Maritime Initiative)

Iogen Corporation supports “Fit for 55”, the transformational changes that are required to achieve the EU’s 2030 decarbonisation goals and climate-neutrality by 2050. Indeed, we as a company are fully dedicated to using our world-leading advanced biofuels technologies to develop deep carbon-negative fuels based on green biohydrogen, a process we have successfully commercialised.

FuelEU Maritime - Holocenic reply Holocenic is a Swedish management consulting company working in the energy and transportation sectors towards a green transition. Our mission is to reduce global warming. Holocenic welcomes the proposal “Regulation on the use of renewable and low-carbon fuels in maritime transport” as it has the potential to decarbonize shipping in Europe while showing the way for the global…

Novozymes welcomes the Commission’s proposal to implement dedicated legislations for the decarbonization of maritime through sustainable renewable fuels but strongly objects to the ill-founded decision to exclude or penalize biofuels produced from food and feed crops.

Comments to the whereas, in numeral 12: It is important to note that in Colombia, the oil palm that has been generically classified as causing ILUC, has not produced deforestation, nor does it indirectly produce the use of land with high carbon stocks. In Colombia, several studies have shown that oil palm development has not been a major driver for deforestation.

EDF welcomes the European Commission’s FuelEU Maritime initiative aiming to reduce GHG emissions in the maritime sector. Today maritime transport is a growing source of GHG emissions and the EU needs to tackle this issue to be fully in line with the Green Deal and the carbon neutrality target by 2050.

While the Baltic Ports Organization (BPO) welcomes "Fit for 55" package the EC, there are a number of points that need to be addressed in order to make the "Fit for 55" package fit for purpose and assure the continuous competitiveness of the European port sector.

Comments to the whereas, in numeral 12: It is important to note that in Colombia, the oil palm that has been generically classified as causing ILUC, has not produced deforestation, nor does it indirectly produce the use of land with high carbon stocks.

The Dutch Platform Renewable Fuels much appreciates the ‘Fit for 55’ proposals on the effects these will have on reducing the climate impact of the energy use in the international maritime sector. The Platform considers the focus of the proposed FuelEU Maritime Regulation rightly placed on reducing the climate impact, with a much-valued long-term horizon.

To stay ahead in the global race for the best climate and energy technology solutions, companies need a clear and reliable fit-for-55 implementation plan providing a clear commitment to Europe as an attractive business, investment and innovation location.

The Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. VDMA represents around 3300 German and European companies in the mechanical engineering industry. The industry represents innovation, export orientation, medium-sized companies and employs around four million people in Europe, more than one million of them in Germany.

ECODES (Foundation for Ecology and Development) thanked the European Commission for the opportunity to comment on the European Commission’s FuelEU Maritime proposal. ECODES is an independent non-profit organisation seeking to accelerate the transition to a green, inclusive and responsible economy, framed by new governance, through innovation and building bridges and alliances.

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Carbon Recycling International is the globally recognised leader in CO2-to-methanol technology, which has been operating e-fuel (RFNBO) plants at industrial scale and selling certified e-fuel to obligated parties in the EU since 2012.

Gas Infrastructure Europe (GIE), representing almost 70 European companies operating storage facilities, transmission pipelines and LNG terminals, welcomes the European Commission’s initiative to encourage the use of low-carbon fuels in the maritime sector. In the context of the FuelEU Maritime Regulation, please find GIE's feedback and considerations attached.

CO2 Value Europe is the European association dedicated to Carbon Capture and Utilisation (CCU) and represents over 70 members along the CCU value chain, primarily industrial actors from different sectors. As CO2 Value Europe, we welcome the European Commission’s FuelEU Maritime initiative to boost the uptake of sustainable fuels in shipping and ports in order to reduce emissions from the sector.

ECSA supports the objective of the FuelEU Maritime proposal to foster the uptake of cleaner fuels in shipping. However, the proposal may become a missed opportunity. Using documents provided by non-EU fuel suppliers to calculate carbon savings contributing to the EU’s climate targets may create substantial enforcement loopholes.

•The European Oleochemicals & Allied Products Group (APAG) welcomes the Commission’s proposal for the FuelEU Maritime Regulation. As we fully support the European Union’s intention to reduce emissions from shipping and would support a more ambitious approach on biofuels, modeled after the Renewable Energy Directive, including: 1.

The "FuelEU Maritime" initiative is an excellent opportunity to promote the use of alternative fuels, thus allowing to help the decarbonization of maritime transport in line with the objectives of IMO (International Maritime Organization) and the EU.

Maritime CleanTech and Energy Norway would like to present our views on the European Commission's regulatory proposal for promoting alternative fuels in the maritime sector (FuelEUMaritime). We are representing over 450 companies involved in activities related to developing and using new energy carriers in shipping.

EUROMOT welcomes the FuelEU Maritime proposal from the European Commission as a tool to overcome the barriers for the uptake of low and zero carbon fuels in shipping. EUROMOT members are committed to advancing the development of engine technology and propulsion systems capable of operating on such fuels.

- A successful EU decarbonisation transport policy should build on the achievements of the RED II and other EU policies, not reverse them. - European sustainable biofuels today account for over 89% of renewables in the European transport. They are the most widely available alternative to fossil fuels and deliver significant GHG emissions savings, and should continue to decarbonise all transport modes.

NABU recognizes the European Commission’s initiative for further action on the decarbonisation of shipping in the FuelEU Maritime proposal ‘CO2 emissions from shipping – encouraging the use of low-carbon fuels’. Being responsible for over 2 percent of the global greenhouse gas emissions each year, the international shipping sector offers immense potential for emissions reductions.

Hydrogen Europe recommends the following points regarding the recent proposal of the FuelEU Maritime Regulation: 1. Revise the loophole for electricity calculation in Annex I to account average grid intensity of the grid at port of call. 2.

The European Sea Ports Organisation (ESPO) fully supports the European Green Deal ambition and the 2030 and 2050 goals enshrined in the EU Climate Law. The transport sector as a whole has an important role in helping to lower EU greenhouse gas emissions, which should be achieved whilst guaranteeing a level playing field with other modes and avoiding a modal shift. The greening of the shipping sector is a priority.

bp welcomes the Commission’s FuelEU Maritime proposal to introduce a GHG intensity reduction target for the energy used on ships. Whilst some maritime journeys are possible with battery electric vehicles, the vast majority of deep-sea shipping is going to require a more energy dense alternative to fossil fuel.

The Swedish Gas Association – Energigas Sverige – considers the proposal to be basically well-designed and is generally positive about it. We also believe that the proposed rate of reduction of greenhouse gases appears appropriate, in light of the climate targets set up by the EU. We welcome clear rules and requirements because they eliminate doubts and uncertainties.

We appreciate the European Union’s efforts in leading the energy transition and tackling GHG emissions in the maritime sector. Given the cross-border nature of shipping, it is the right approach to address its GHG impact on a Union level and thereby set an example for the international shipping community to follow.

We completely agree that air pollution produced by ships at berth is a significant concern for coastal areas and port cities. And it is understandable that specific and stringent obligations should be imposed to reduce emissions at berth from ships that draw power from their engines during their stay in port. Their emissions should be addressed as a priority.

Rolls-Royce Power Systems has longstanding experience in providing power and propulsion for commercial marine vessels, including ferries, tugboats, offshore wind farm crew boats, and service and supply vessels. That is why we are exploring sustainable shipping solutions such as engines certified for sustainable fuels, fuel cell systems, electric and hybrid propulsion systems, and methanol engines.

The Mittelstandsverband abfallbasierter Kraftstoffe e.V. (MVaK) represents 21 members which prepare suitable vegetable waste and residues, mainly used cooking oil and waste fatty acids, process them into waste-based biodiesel or trade feedstocks and finished products. The MVaK welcomes the opportunity to comment on the European Commission’s FuelEU Maritime proposal.

We appreciate the European Union’s efforts in leading the energy transition and tackling GHG emissions in the maritime sector. Given the cross-border nature of shipping, it is the right approach to address its GHG impact on a Union level and thereby set an example for the international shipping community to follow.

REPSOL is a global multi-energy company, which shares the world’s ambition to reach climate neutrality in the framework of the Paris Agreement, as well as the EU’s 2050 carbon neutrality objective. REPSOL leads the energy transition by being the first oil and gas company to set the goal of zero net emissions by 2050 and committing to a model that integrates all technologies for decarbonisation, based on improving…

Danish Shipping welcomes the proposal as it – together with the rest of the Fit for 55 package – has the potential to provide the steppingstones for an increased use of renewable and low-carbon fuels in maritime transport and hereby contribute to the target of climate neutrality by 2050.

IBERDROLA welcomes the “Fit for 55 Package” The Green Deal though the “Fit for 55 Package” offers a unique opportunity to set a proper regulatory framework that boosts momentum on the most efficient renewable alternatives to enable decarbonisation and the achievement of EU climate objectives.

General comments: • The Council of the European Union recognised the need to support the development of different alternative fuels (including LNG as a transitional fuel). • As stated in the Impact Assessment accompanying the proposal for regulation, LNG provides a good solution to air pollution issues, allowing reductions in SOx and NOx emissions.

Finnish Forest Industry Federation Industry (FFIF) hope that the FF55 package including FuelEU Maritime will provide regulatory stability which promotes the industry’s investments in climate friendly products and production as well as in sustainable forestry.

Alfaport Voka is the platform by and for companies and professional associations in the port of Antwerp, Belgium. Alfaport Voka is aiming for an accessible, facilitative, cost-competitive and sustainable port of Antwerp with a view to embedding sustainable employment and added value at the port.

The Finnish Shipowners’ Association (FSA) welcomes the opportunity to provide comments to the FuelEU Maritime Regulation. The FSA welcomes the European Commission’s Fit for 55 -package and supports its ambition to deliver the European Green Deal.

Equinor welcomes the proposed Refuel Maritime Regulation aiming to promote the uptake of sustainable alternative fuels. Our company has extensive maritime activities around the world, including around 175 contracted vessels at any time.

FuelsEurope response to the public consultation on the Fuel EU maritime proposal. FuelsEurope supports the Green Deal’s ambition for climate neutrality in 2050 and will work with the EU institutions, member states, and stakeholders, to help create the essential enabling policy framework.

The European Biogas Association (EBA) warmly welcomes the European Commission’s ambitions to increase the share of renewable fuels in the maritime transport fuel mix, thereby strengthening the measures taken at the international level by IMO.

The VDR welcomes the ambitious climate action presented by the European Commission in the Fit for 55 legislative package in July 2021 to make Europe the first climate-neutral continent in the world by 2050. in order for this Regulation on the use of renewable and low carbon fuels in maritime transport (hereinafter “FuelEU Maritime”) to be fully effective in terms of climate protection, the VDR considers that the…

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SEA-LNG Feedback on the FuelEU Maritime Proposal SEA-LNG Founded in 2016, with numerous high-profile members including shipping companies, ports, LNG suppliers, bunkering companies, infrastructure providers and OEMs (Original Equipment Manufacturers), classification societies, banks and brokers, SEA-LNG is a multi-sector industry coalition whose members work together to demonstrate the benefits of LNG as a marine…

Clean Air Task Force (CATF) welcomes the EU climate ambition, leadership on decarbonisation, and pursuit of policies to decouple greenhouse gas emissions from economic growth. The maritime sector will require fundamental changes to become more sustainable. If the sector were a country, it would rank sixth among countries with the highest GHG emissions, ahead of Germany and the UK.

LanzaTech commends the European Commission for its proposal to boost the uptake of sustainable fuels in shipping and ports to reduce emissions from the sector. We welcome the opportunity to respond to the EU Commission's proposal and working alongside the co-legislators in the future.

Thank you for the opportunity to contribute to the development of this important regulation. Yara is one of the world’s largest ammonia producers, as well as one of the world’s largest ammonia shippers, and we have set ourselves ambitious GHG reduction targets for 2025 and 2030.

Neste welcomes the FuelEU Maritime initiative to reduce greenhouse gas emissions from maritime transport. 1) Broad feedstock base for renewable fuels is needed to cost effectively reduce emissions in maritime transport Neste supports a broad feedstock base for sustainable biofuels.

Liquid Wind welcomes the European Commission’s initiative FuelEU Maritime and its proposal of Regulation on the use of renewable and low-carbon fuels in maritime transport. Liquid Wind is a Swedish Power-to-Fuel Development Company committed to reducing carbon emissions.

The Swedish 2030-secretariat is an independent Think tank, committed to decarbonization of transport, but not locked into an specific technological solutions. GHG reduction is the target, sooner rather than later. The maritime sector dominates world trade. It is an energy efficient means of transport, but the scale of operations makes it a large contributor to global emissions.

France Hydrogène welcomes the initiative to support the uptake of renewable and low-carbon fuels in maritime transport. France Hydrogène particularly supports the agnostic and technologically neutral approach of the Regulation, offering a wide range of renewable and low-carbon fuel solutions to decarbonise the sector, such as hydrogen (gas or liquid), synthetic fuels (e-fuels), ammonia, or methanol.

International Council on Clean Transportation (ICCT) is an independent non-profit organization founded to provide first-rate, unbiased research and technical and scientific analysis to environmental regulators. ICCT welcomes the opportunity to comment on the European Commission’s FuelEU Maritime Proposal.

Grainis ltd. Hydrogen Bulgaria works since 2005 on R&D projects for low-cost production of various green biofuels. We have developed a unique technology for full displacement the Fossil Diesel & Fuel Oil for Ships, Boats, etc., with 100% CO2-Neutral Engineered Peanut Oil (EPO), extracted out of fast-growing (60 days, 6 crops/yr.), Edible or Not-Edible Peanuts, cultivated indoors, on roto-shelves, in hyper-intensive…

The Port Authority of the Bay of Algeciras has carried out a study on the impact that the implementation of the ETS legislative proposals and FUEL EU MAIRITIME could have on ports which, like Algeciras, have nearby ports in third countries that do not share the decarbonisation objectives and are therefore able to capture maritime traffic that thereby try to evade the additional cost of these measures, thus reducing…

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We strongly endorse the adoption of a Well-to-Wake accounting approach to measure maritime emissions under the FuelEU Maritime initiative, as it gives a complete picture of the environmental profile of fuels and avoids a shift of emissions to upstream production processes.

The European Commission’s Fit for 55 package sets important new goals for emissions reduction in transport. Giving a prominent role to renewable liquid fuels would create a solid foundation for reaching them. To that end, the EU should fully maximise the tools it has on hand for decarbonisation and de-fossilisation.

The International Association of Oil & Gas Producers (IOGP) supports the goals of the Paris Agreement and the EU’s ambition to reach climate neutrality by 2050. We recognize that there are many challenges on the road to meet this objective as the energy transition will require significant investments, new technologies, effective policies and behavioural changes.

Maritime transport across Europe does not bring people together; it divides them in this race for globalised globalisation. It suspends a huge sword of Damoclès over European waters by the huge risk of shipwreck, collision or fire of thousands of ships sailing every day, every second.

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Please find attached Farm Europe’s Green Energy Platform’s reply to the public consultation on CO2 emissions from shipping – encouraging the use of low-carbon fuels EUROPEAN BIOFUELS MAKE AN ESSENTIAL CONTRIBUTION TO THE GREEN DEAL The transport sector poses one of the greatest challenges to the Green Deal. GHG emissions have risen fast, from 15% of total EU GHG emissions in 1990 to over 25% now.

Dear DG-move, I will not spend time on telling how much I appreciate all the valuable policy making the paper aims at. I will instead point on the few issues I have with the text in the Roadmap, so cutting to the cheese.

We appreciate the opportunity to comment this important initiative, which supports achieving necessary GHG emission reductions in maritime transport. The use of low- and zero-carbon alternative fuels, including biofuels, presents an immediate solution with a significant reduction potential. The development and uptake of these fuels will be critical for achieving a more sustainable future for maritime transport.

The International Association of Oil & Gas Producers’ (IOGP) shares the global ambition to tackle climate change in the framework of the Paris Agreement and supports the EU’s objective of climate neutrality by 2050. There are many challenges on the road to meet this objective as the energy transition will require significant investments, new technologies, effective policies and behavioural changes.

The Methanol Institute would like to thank the European Commission for the opportunity to comments on the Inception Impact Assessment (IIA) of the Fuel EU Maritime initiative. The Methanol Institute serves as the trade association for the global methanol industry and exists to promote Methanol as a marine fuel.

The Dutch Platform Sustainable Biofuels (PDB) welcome a European initiative to accelerate the uptake of sustainable alternative fuels and power in maritime transport, either for inland and shortsea shipping or seagoing vessels. In the Netherlands the volume of international bunkering for shipping outnumbers the volume of transport fuels deployed on Dutch national territory.

The "FuelEU Maritime" initiative is an opportunity to further develop LNG as an alternative fuel, in order to achieve Green-Deal objectives in maritime transport and port areas. Regarding the analyzed barriers, LNG is part of the solution, based on: Predictability and investments Investment risk exists for any fuel, so ship owners need certainty about which fuels they can use and which are available in ports at a…

The MVaK (Mittelstandsverband abfallbasierter Kraftstoffe e.V., waste-based biofuels association) represents 22 medium-sized companies operating along the value chain of waste-based biodiesel production in Germany, Austria and The Netherlands. MVaK members operate a production capacity of about 1 million tons of waste-based biodiesel which reduces GHG emissions by more than 90 percent.

The International Council on Clean Transportation (ICCT) welcomes the opportunity to provide comments on the FuelEU Maritime inception impact assessment roadmap. We approve of the Commission’s intention to support the decarbonization of the marine sector.

EWABA represents 28 members including 21 waste-based biodiesel producing companies with 30 operative production facilities in Europe transforming used cooking oil (UCO) and animal fats into waste biodiesel. In 2019 our members jointly produced 1.725.000t of waste biodiesel with up to +90% GHG reductions, thus enabling “near-term decarbonisation” of the EU transport sector.

Preliminary Snam inputs to the FuelEU Maritime Initiative Snam, as one of the world’s leading energy infrastructure players, welcomes the FuelEU Maritime Initiative and provides the following contributions: 1. The initiative should take a well-to-wake approach, and consider not only the impact of GHG but also of local pollutants.

The following comments stick to the content of the inception document and are only intended to be helpful for the further development of the initiative. They do not compromise any final position on a future legislative proposal. Overall, the initiative is timely and the inception document well focused.

Freshfel Europe is the European Fruit and Vegetable Association and represents the entire supply chain from production to trade to retail. Freshfel has compiled a comprehensive response of the sector on the roadmap for "CO2 Emissions for shipping - encouraging the use of low-carbon fuels, attached here. We remain available for further discussion.

EUROCITIES welcomes the FuelEU Maritime initiative. Climate change, air pollution and noise emissions are significant issues for port cities in our network. Intervention by the EU with regulatory measures and financial instruments is necessary to address these challenges.

Wärtsilä welcomes the Commission’s action to foster emissions reductions in maritime transport. Wärtsilä is ready to contribute to the transition and enable the meeting of ambitious targets with innovative solutions on maritime sector technology.

The German Mechanical Engineering Industry Association (VDMA) is the largest European industrial association. The VDMA represents around 3300 German and European companies in the mechanical engineering industry.

NABU supports the EC’s initiative to develop a regulation to foster the uptake of sustainable alternative fuels (SAF) for ships. The fast uptake is necessary to achieve the Paris Agreement Climate Goals. The sustainability of e-fuels needs to be safeguarded by criteria. SAF must be entirely based on renewable electricity. We expect the SAF production costs to remain higher than the fossils even in the long term.

The Maritime Group of the ART Fuels Forum (Alternative and Renewable Transport Fuels Forum; http://www.artfuelsforum.eu/) would like to provide feedback to the consultation launched by the European Commission on the Inception Impact Assessment of the FuelEU Maritime Initiative.

Hydrogen Europe is the European Hydrogen and Fuel Cell Association. It currently represents more than 160 industry companies, 78 research organizations as well as 21 National Associations. The association partners with the European Commission in the innovation programme Fuel Cells and Hydrogen Joint Undertaking (FCH JU).

The International PtX Hub Berlin recognises the EU Commission’s Initiative „ FuelEU Maritime – Green European Maritime Space “ and is prepared to contribute to its conceptual design, implementation, management and monitoring, in particular with respect to synthetic E-fuels from sustainable Power to X (PtX) processes, both within the EU and beyond.

FuelsEurope supports the Green Deal’s ambition for climate neutrality in 2050 and will work with the EU institutions, Member States, and stakeholders, to help create the essential enabling policy framework. The European refining industry recognises that there is no business as usual and is ready to play an essential role in supporting this ambition by developing alternative fuels, products and services needed to…

Addressing climate protection in the field of maritime shipping is an excellent initiative of the Euro-pean Commission. So far, this mode of transport has contributed virtually nothing to decarbonising Europe. This is mainly due to a lack of regulation. In order to reduce GHG emissions in maritime shipping effectively, a binding mandate is needed.

SEA-LNG input to Inception Impact Assessment of FuelEU SEA-LNG shares the EU’s climate neutrality objective by 2050. We also welcome the ambition to accelerate the achievement of low-emission, climate-neutral shipping and ports by promoting the uptake of sustainable alternative energy. We firmly believe that LNG in the maritime will be crucial in helping achieve these climate and air quality goals.

Total welcomes the initiative of the European Union to create a clear pathway for the demand of sustainable alternative fuels in maritime transport and commits to contribute actively to the emission reductions of this sector.

We welcome the FuelEU Maritime initiative and the possibility to comment on the proposed plans. FuelEU Maritime initiative aims at accelerate the uptake of low-emission, climate-neutral shipping by ramping up the production, deployment and uptake of sustainable alternative fuels. Alternative fuels and technologies are necessary in order to enable the decarbonisation and other emission reductions in shipping sector.

LNG is part of the solution to decarbonize maritime transport: Adoption of LNG as a marine fuel is a first significant step towards the reduction of GHG emissions. A GHG reduction can be achieved today between 15% and 21% in the main global consumer fleet (container, tankers, and bulk).

FEPORT, the European organization representing 1200 private port companies and terminals welcomes the opportunity to provide some initial comments regarding the ReFuelEU Maritime initiative. FEPORT members are committed to green port operations and to contribute to the reduction of shipping emissions in ports FEPORT supports the aim of ReFuel EU Maritime to stimulate the demand of sustainable alternative fuels in…

UPEI – Europe’s Independent Fuel Suppliers, welcomes the opportunity to provide initial comments to the Roadmap, and to be part of the preparatory process for the FuelEU Maritime initiative. UPEI embraces the European Green Deal and ambition to reach climate neutrality by 2050 and therefore supports measures that bring down fuel consumption as well as boosting the deployment of all low- and zero-carbon marine fuels…

CO2 Value Europe (CVE) is the European association dedicated to Carbon Capture and Utilisation (CCU) and represents over 65 members from different sectors along the CCU value chain, including the maritime e-fuels sector. CVE welcomes the European Commission’s FuelEU Maritime initiative to curb CO2 emissions in the European maritime sector by promoting the production and use of sustainable alternative fuels.

The "FuelEU Maritime" initiative is an opportunity to further develop LNG as an alternative fuel, in order to achieve Green Deal objectives in maritime transport and port areas. Regarding the analyzed barriers, LNG is part of the solution, based on: PREDICTABILITY & INVESTMENTS Investment risk exists for any fuel, so shipowners need certainty about which fuels they can use and which are available in ports at a…

Maritime sector is a large and growing source of greenhouse gas emissions and related emissions are projected to increase significantly if mitigation measures are not put in place swiftly. Shipping emissions could increase between 50% and 250% by 2050 under a business-as-usual scenario, undermining the objectives of the Paris Agreement [Third IMO Greenhouse Gas Study 2014].

GAZ-SYSTEM Capital Group supports the European Commission's plan to accelerate the implementation of low-carbon shipping and port operations by supporting the deployment of alternative, sustainable energy sources and vessel propulsion. In terms of climate and air quality, LNG in the maritime sector should and will play a key role in achieving these goals.

- implement EU ETS to maritime activities for all shipowners trading in/out of EU members territorial waters or trading on rivers. - thanks to EU ETS, offer/issue "green shipping" certificates that shipowners can pass onto charterers. - cancel duty-free of all fossil fuels for all shipping activities (inland river and offshore).

The objective of reducing pollutant and greenhouse gas (GHG) emissions is shared but must form part of a long-term vision that is compatible with the specific characteristics of each sector of activity. Maritime transport, whether intercontinental or local, offers a very high density of transport, which makes it possible to achieve among the best results in terms of emissions per t.km.

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At first Surfrider Foundation Europe wants to underline the importance in Europe to achieve Paris Agreement objectif and in particular the Objectif 3 of d'Aichi Convention : decarbonisation will be a way to do it.

Repsol is a multienergy company that is present throughout the value chain, bringing efficient, sustainable, and competitive energy to millions of people. We share the world’s ambition to reach climate neutrality in the framework of the Paris Agreement, as well as, EU’s 2050 carbon neutrality objective.

Milieudefensie - Friends of the Earth Netherlands supports the objective to reduce the emissions from the maritime sector by accelerating the uptake of sustainable alternative fuels and power. We agree with the European Commission that creating a predictable demand in this sector is essential for the investment and mass scale deployment of sustainable alternative fuels and power.

Environmental Defense Fund (EDF) welcomes the opportunity to comment on the European Commission’s proposed plans to incentivise sustainable fuels in maritime transport. The key points the Commission must consider are: • Any policy on maritime fuels must take a full lifecycle approach. In addition to accounting for well-to-wake direct emissions, indirect emissions (such as ILUC) also need to be considered.

Edison welcomes the opportunity to share some preliminary views on the roadmap related to the initiative “FuelEU Maritime - Green European Maritime Space” launched by the European Commission. We strongly believe this initiative will contribute to developing a comprehensive framework for a substantial uptake of sustainable alternative fuels in maritime transport.

The "FuelEU Maritime" initiative is an opportunity to further develop LNG as an alternative fuel, in order to achieve Green-Deal objectives in maritime transport and port areas. Regarding the analyzed barriers, LNG is part of the solution, based on: Predictability & investments Investment risk exists for any fuel, so shipowners need certainty about which fuels they can use and which are available in ports at a…

We welcome the EC initiative to develop an effective EU regulation to drive the uptake of sustainable alternative fuels in EU shipping. We agree with the EC assessment that creating a predictable demand in the shipping industry is essential for the investment and mass scale deployment of sustainable alternative fuels.

The International WindShip Association (IWSA) and the French Association Wind Ship (APTMD-IWSA) are pleased to present a joint submission to comment on this EC initiative. Although this initiative seems really relevant, we are concerned about the absence of an important source of renewable energy and of the technologies which allow it to be exploited: WIND.

The shipping industry is fully committed to progress according to the IMO timetable to reduce its GHG emissions. We welcome the EU’s commitment to lead the fight against climate change. The EU should contribute to the development of global standards and strengthen the competitive position of the European shipping industry and the European maritime cluster.

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EUROMOT, the European Association of Internal Combustion Engine Manufacturers, would like to submit its comments on the consultation on the European Commission’s Inception Impact Assessment on “FuelEU Maritime – Green European Maritime Space”. In particular, we would like to raise the following issues in the attached position paper: 1. Technical requirements on marine propulsion systems and marine power units 2.

The French Association for Hydrogen and Fuel Cells (AFHYPAC) represents 160 stakeholders from the hydrogen sector in France, including major industrial groups, SME-ETI and local authorities involved in the deployment of hydrogen technologies.

Environmental Action Germany welcomes the opportunity to comment on this EC initiative. We wish to make the following comments: 1. Crop biofuels are more damaging to the climate than fossil fuels. Crop biofuels must be phased out entirely and must not be incentivised for use in shipping. 2. Advanced biofuels based on wastes and residues are not automatically sustainable.

The German Environment Agency (UBA) strongly supports the Commission’s initiative. Especially in the light of the current crisis, it offers a unique opportunity to rethink established business models and to promote sustainable growth. It is a necessary step to achieve the Paris Agreement Climate Goals. Shipping needs a long-term regulatory strategy on the path to climate neutrality.

SEA Europe welcomes the ambition of the European Commission’s “European Green Deal” (EUGD) which is in line with that of the European “Waterborne” Technology Platform (https://www.waterborne.eu/), which aims at providing solutions by 2030, applicable for all main ship types and services, in order to achieve zero-emission waterborne transport by 2050.

The initiative is very relevant and timely. However, the inception report is apparently focusing mainly on Horizon Europe (i.e. R&I budget) and on shore side electrical supply. Although beneficial, these two approaches present the following limitations: a) deployment of R&I results necessarily imply medium to long term time frames i.e.

ZWE welcomes the FuelEU Maritime Initiative. In order to further develop the initiative we recommend the following: I. Policy Coherence: any potential support to waste-based fuels should be in line with other environmental and climate policies.

With regard to the MRV, in which the CO2 emissions are reported, we have the following comments: Almost 100% of the CO2 emissions are currently calculated from the fuel consumption of the engines / boilers. The consumption is almost never measured directly, but read manually from gauges (before / after) or roughly estimated by sounding the tanks (the accepted tolerance in the bunker process alone is 4%).