A Commission staff working document dated 30 July 2026, submitted by the EU jointly with its 27 Member States to the International Maritime Organization's 21st Intersessional Working Group on Greenhouse Gases (ISWG-GHG 21), proposes a structured framework for discussing chain of custody models needed to ensure fuel supply chain traceability under the draft IMO Net-Zero Framework and the 2024 Life Cycle Assessment (LCA) Guidelines. The submission, which falls under EU exclusive competence and was transmitted to the IMO by the 6 March 2026 deadline, recommends using the ISO standard 22095:2020—including its January 2026 amendments for Mass Balance (ISO 22095-2) and Book & Claim (ISO 22095-3)—as a starting reference point, and calls for an expert group workshop between ISWG-GHG-21 and ISWG-GHG-22 to report on traceability requirements and chain of custody models.
The document sets out parameters for assessing chain of custody systems, including applicable supply chain segments, sector boundaries, temporal characteristics such as mass balancing periods, and interconnected infrastructure elements. It stresses the need to assess interactions, links, and leakages between existing systems to prevent double-claims and double counting across sectors and countries. This initiative builds on the IMO's ongoing work to finalise the Net-Zero Framework, which aims to regulate greenhouse gas emissions from international shipping, and the 2024 LCA Guidelines that establish a lifecycle approach to fuel emissions. The EU's submission is a technical contribution to the IMO's regulatory process, reflecting the bloc's push for robust, verifiable sustainability criteria in maritime fuels.
The proposal has significant implications for shipping companies, fuel suppliers, and EU regulators. For shipping operators, the adoption of a standardised chain of custody model could increase administrative and compliance costs, as they would need to document and verify the sustainability attributes of their fuels throughout the supply chain. Fuel suppliers, particularly those producing alternative fuels such as biofuels or e-fuels, would face new requirements to track and certify their products, potentially favouring larger producers with the resources to implement complex traceability systems. For EU regulators, the framework supports the bloc's broader climate goals by ensuring that emissions reductions claimed under the IMO framework are credible and not double-counted, aligning with the EU's own FuelEU Maritime regulation. However, the proposal also introduces a trade-off between environmental integrity and operational flexibility: while strict traceability prevents fraud and double counting, it may limit the use of book-and-claim systems that allow flexibility in fuel sourcing, potentially increasing costs for smaller operators. The expert workshop proposed by the EU is expected to refine these models before the IMO's next steps, with the Marine Environment Protection Committee (MEPC) likely to consider the outcomes at its subsequent session.