Brazil Marine Fuel Registry Pilot Highlights Gaps in Sustainability Records

Summary

Brazil’s trial of a sustainable marine-fuel registry has identified practical challenges involving certification delays, inconsistent product names and safeguards against double counting. The simulated bioethanol transaction examined how sustainability information moves through the supply chain, highlighting the need for digital systems that accommodate commercial workflows without duplicating paperwork.

Pilot examines documentation across the supply chain

The Brazil marine fuel registry pilot simulated a batch of bioethanol moving from production to delivery aboard a ship. Findings were submitted on 15 October for consideration at the International Maritime Organization’s forthcoming greenhouse-gas working-group meeting.

Participants included producer FS Indústria de Biocombustíveis, trader FS Comercialização, bunker supplier Bunker One, shipping company Aliança Navegação e Logística, certification body SCS Global Services and the Brazilian Navy’s Directorate of Ports and Coasts.

The exercise identified a timing mismatch: proof-of-sustainability documents can arrive weeks after fuel delivery and issuance of the bunker delivery note. Participants therefore wanted the registry to accommodate pending documentation.

Other findings concerned different certification schemes using different product names and the importance of comprehensive records to prevent double counting. Participants also sought a system that replaced existing document exchanges rather than adding another administrative layer. Brazil intends to continue voluntary testing.

Physical delivery and certification follow different timelines

The documentation issue has a direct commercial implication. A fuel shipment can be physically transferred before its complete sustainability evidence becomes available.

A workable registry consequently needs to distinguish between a recorded delivery and a completed sustainability claim. Treating both as a single event could leave users unable to represent the actual status of a transaction accurately.

For suppliers and ship operators, the useful outcome would be a clear connection between the delivered fuel and the evidence subsequently attached to it. A pending record would need to remain distinguishable from one whose supporting information has been completed and checked.

The pilot’s findings suggest that system design must account for this sequence from the outset, rather than assuming every document is available when bunkering takes place.

Consistent terminology matters for traceability

Different names for the same product present another challenge when information passes between producers, traders, suppliers and certification organisations.

The practical concern is whether records describing one fuel can be recognised and connected across systems. Without consistent definitions or reliable mapping between terms, participants may face additional reconciliation work.

Double counting raises a related issue: the same sustainability attribute must not support incompatible or repeated claims. A registry’s value therefore depends on the completeness and consistency of the information it records.

These are data-governance questions as much as software questions. A digital platform can organise information, but participants still need common rules governing what is submitted, how records are linked and when claims are considered complete.

IMO lifecycle framework provides the wider context

The registry discussion sits within shipping’s broader transition towards assessing fuels across their full lifecycle.

IMO’s approach covers emissions from production and supply through to onboard use, combining upstream and shipboard emissions. Its 2024 lifecycle guidelines address carbon dioxide, methane and nitrous oxide.

The guidelines also introduce a Fuel Lifecycle Label to convey information relevant to assessment. Actual emissions factors can be used subject to third-party verification and certification.

This framework makes the movement of reliable information commercially important. A fuel’s physical characteristics alone do not establish its lifecycle greenhouse-gas intensity; production methods and supply-chain evidence also influence the assessment.

For buyers evaluating alternative fuels, documentation therefore supports the connection between the product purchased and the environmental attributes claimed.

Further negotiations remain ahead

The Brazilian submission precedes the next round of IMO discussions rather than representing an adopted international registry requirement.

IMO has scheduled its 23rd Intersessional Working Group on Reduction of Greenhouse Gas Emissions from Ships for 23–27 November 2026, ahead of MEPC 85.

The organisation’s September meeting deferred consideration of supporting implementation guidelines and further lifecycle-assessment work to that next session because of time constraints.

The pilot provides an operational perspective for those discussions. Its central lesson is that traceability systems must preserve credible sustainability information while reflecting how fuel transactions actually occur.

For producers, bunker suppliers and shipowners, successful implementation would mean dependable records that can follow a fuel through successive transactions, with fewer repeated exchanges and a clear distinction between provisional information and verified claims.

FAQs

What did the Brazilian pilot test?

A simulated bioethanol transaction from production through delivery to a vessel.

What documentation problem emerged?

Sustainability evidence can become available after fuel delivery and issuance of the bunker delivery note.

Why does product naming matter?

Different terminology can make it harder to connect records for the same fuel across certification systems.

Is the registry mandatory?

Brazil plans to continue voluntary testing; the pilot does not establish an international requirement.

When are the next relevant IMO discussions?

The greenhouse-gas working group is scheduled to meet on 23–27 November 2026.