Simulation study on regulatory compliance costs of alternative marine fuels under IMO GHG mid-term measures
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This study quantitatively compares and analyzes the regulatory compliance costs of alternative marine fuels based on midterm measures for greenhouse gas (GHG) reduction approved at the 83rd session of the Marine Environment Protection Committee (MEPC) of the International Maritime Organization (IMO) in April 2025. The IMO mid-term measures introduce GHG Fuel Intensity (GFI) standards along with the Remedial Unit (RU) and the Surplus Unit (SU), thereby creating a regulatory framework that directly impacts the economics of fuel transition in the shipping industry. This study evaluated key marine fuels, including HFO, LNG, biofuels, and e-methanol, by calculating the attained GFI values based on their respective GHG intensities and lower calorific values (LCV). We further assessed the annual RU and SU revenue associated with each fuel. Simulation results indicate that high-carbon fuels such as HFO, LFO, and MDO/MGO will face a significant increase in regulatory compliance costs after 2030, owing to escalating RU charges. In contrast, low-carbon fuels, such as Bio100, Bio-LNG, and e-methanol, maintain long-term cost stability despite higher initial fuel prices, mainly through revenues generated by SU trading.
Abstract
This study quantitatively compares and analyzes the regulatory compliance costs of alternative marine fuels based on midterm measures for greenhouse gas (GHG) reduction approved at the 83rd session of the Marine Environment Protection Committee (MEPC) of the International Maritime Organization (IMO) in April 2025. The IMO mid-term measures introduce GHG Fuel Intensity (GFI) standards along with the Remedial Unit (RU) and the Surplus Unit (SU), thereby creating a regulatory framework that directly impacts the economics of fuel transition in the shipping industry. This study evaluated key marine fuels, including HFO, LNG, biofuels, and e-methanol, by calculating the attained GFI values based on their respective GHG intensities and lower calorific values (LCV). We further assessed the annual RU and SU revenue associated with each fuel. Simulation results indicate that high-carbon fuels such as HFO, LFO, and MDO/MGO will face a significant increase in regulatory compliance costs after 2030, owing to escalating RU charges. In contrast, low-carbon fuels, such as Bio100, Bio-LNG, and e-methanol, maintain long-term cost stability despite higher initial fuel prices, mainly through revenues generated by SU trading.