ISWG-GHG 20/3/8: Developing a quantitative risk-based approach to manage indirect land use change emissions under the IMO Net-Zero Framework
This document reviews the treatment of indirect land use change (ILUC) within the 2024 Guidelines on life cycle GHG intensity of marine fuels (2024 LCA Guidelines) (resolution MEPC.391(81)). Drawing on examples from other regulatory frameworks such as the EU’s Renewable Energy Directive (RED) and ICAO’s CORSIA programme, this document highlights the significant risk that high ILUC emissions from food and feed-based marine fuels could undermine intended GHG savings under the IMO Net-Zero Framework. It argues that a purely qualitative approach cannot prevent the use of high-ILUC risk biofuels under the IMO Net-Zero Framework. Consequently, this document proposes that the Working Group encourage interested Member States and international organizations to provide concrete proposals to MEPC 84 on: 1) how to incorporate quantitative metrics into a risk-based ILUC framework in the 2024 LCA Guidelines; and 2) how to safeguard against the use of fuels made from identified high-ILUC risk feedstocks to ensure the environmental integrity of the IMO Net-Zero Framework.
