Learn how Risk-Based Alternative Technology (RBAT) aligns with the EU Green Deal and Fit for 55 package to accelerate maritime decarbonization. Discover regulatory pathways, innovations, and case studies driving Europe’s green shipping future.
Why Maritime Alignment with EU Climate Policy Matters
In the global race toward decarbonization, the European Union has taken a commanding lead with its ambitious EU Green Deal and Fit for 55 package. These frameworks demand deep emissions cuts across sectors—including shipping. While maritime transport accounts for approximately 3% of global CO₂ emissions, it has often been labeled a “hard-to-abate” sector. But change is on the horizon.
As part of Fit for 55, the EU is integrating maritime shipping into the EU Emissions Trading System (EU ETS) and enforcing FuelEU Maritime, a regulation that mandates a steady reduction in ships’ greenhouse gas (GHG) intensity. Yet many of the emerging clean fuels and technologies necessary to comply are not fully addressed by current maritime regulations.
This is where Risk-Based Alternative Technology (RBAT) becomes essential. As a flexible regulatory mechanism recognized by the International Maritime Organization (IMO), RBAT enables shipowners and innovators to propose safety-equivalent solutions when using new fuels such as ammonia, hydrogen, methanol, and battery-electric propulsion—all of which are central to the EU’s climate goals.
Understanding the Fit for 55 Package and the Green Deal
The EU Green Deal is the overarching policy roadmap designed to make Europe the world’s first climate-neutral continent by 2050. The Fit for 55 legislative package supports this by mandating a 55% reduction in GHG emissions by 2030 compared to 1990 levels. In the maritime sector, this translates to:
- Inclusion of CO₂ (and later CH₄ and N₂O) emissions in the EU ETS from 2024
- Introduction of FuelEU Maritime, requiring GHG intensity reductions from 2025, tightening to 80% by 2050
- Incentives for using renewable and low-carbon fuels
- Shore-side electricity (SSE) mandates for ports
According to the European Maritime Safety Agency (EMSA), around 10,000 ships will fall under the ETS and FuelEU by 2030. But this fast-tracked regulation needs a counterpart in flexible, innovation-friendly safety standards—which brings us to RBAT.
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How RBAT Helps Ships Comply with EU Green Shipping Policies
A Flexible Path When Regulations Lag
New fuels like ammonia or hydrogen carry unique risks: toxicity, flammability, material compatibility, and more. The IMO’s International Code of Safety for Ships using Gases or other Low-Flashpoint Fuels (IGF Code) was designed with LNG in mind and is being expanded slowly to include other fuels. RBAT, as outlined in IGF Code Part A-1, 2.3–2.4, allows innovators to propose alternative designs backed by rigorous risk assessments, ensuring equivalent safety while waiting for prescriptive rules to catch up. This allows:
- Use of methanol and ammonia before they are fully codified
- Adoption of fuel cell systems, battery packs, and carbon capture modules
- Faster Flag State approval in alignment with EU timelines
Supporting Fit for 55’s Technology-Neutral Approach
The FuelEU Maritime Regulation emphasizes a technology-neutral pathway—it doesn’t prescribe fuels but enforces performance targets. RBAT complements this by allowing any low- or zero-emission system, provided it meets safety equivalency through:
- Hazard Identification (HAZID)
- Failure Mode and Effects Analysis (FMEA)
- Quantitative Risk Assessment (QRA)
This encourages cross-sector innovation without regulatory delay, a key ambition of the European Commission’s Sustainable and Smart Mobility Strategy.
Key Technologies Enabled by RBAT
Ammonia as Marine Fuel
Ammonia emits no CO₂ at the point of combustion, making it a prime candidate under FuelEU Maritime. But it’s toxic and corrosive. Through RBAT, shipbuilders like Samsung Heavy Industries and class societies like Lloyd’s Register have created ammonia-ready designs. RBAT helps:
- Validate fuel tank positioning
- Ensure ventilation standards in machinery spaces
- Develop safe bunkering protocols
Hydrogen and Fuel Cells
Hydrogen is increasingly seen as critical to green corridor development in Europe (e.g., Rotterdam–Gothenburg, Antwerp–Zeebrugge). Projects like MF Hydra in Norway, supported by DNV, used RBAT to gain regulatory acceptance for:
- High-pressure hydrogen fuel systems
- Fuel cell integration in propulsion
- Leak detection and firefighting equipment
This aligns with EU funding through Horizon Europe and Connecting Europe Facility (CEF), which prioritize hydrogen innovation.
Methanol Dual-Fuel Engines
Methanol is simpler to store and less hazardous than ammonia or hydrogen, and commercial uptake is accelerating. RBAT has enabled:
- Retrofitting container ships (e.g., Maersk Green Methanol Fleet)
- Bunkering safety procedures in ports like Rotterdam and Antwerp
- Fire safety equivalency measures for methanol engine rooms
These pathways match the GHG intensity reduction goals of FuelEU Maritime.
Carbon Capture Systems (CCS)
Onboard CCS is under active development by companies like Wärtsilä and Alfa Laval. Because CCS units alter ship layouts and involve high-pressure storage, RBAT is essential to:
- Model accidental release scenarios
- Ensure integration with ship ventilation systems
- Confirm structural integrity and heat dispersion
The EU’s Innovation Fund has already committed over €3 billion to CCS trials, many involving shipping.
Case Studies: RBAT in Action for European Fit for 55 Compliance
Port of Antwerp-Bruges Hydrogen-Powered Tugboat
Europe’s first hydrogen-powered tugboat, Hydrotug 1, was launched in 2023. Approved by Bureau Veritas, it uses RBAT to:
- Certify double-walled fuel tanks
- Implement leak-proof fuel cell compartments
- Train crew in new safety procedures
The vessel supports Antwerp’s role as a green fuel hub under the TEN-T Core Network.
Maersk’s Methanol Retrofits Across Europe
RBAT was crucial for Maersk’s early adoption of methanol, allowing them to:
- Conduct bunkering in regulated ports under temporary approvals
- Retrofit older ships in shipyards across Spain and the Netherlands
- Use fire-resistant engine coatings instead of full structural overhaul
Wärtsilä’s CCS Pilot with the EU Innovation Fund
Wärtsilä’s pilot CCS module, installed on a vessel operating between Finland and Germany, received conditional acceptance via RBAT to:
- Test exhaust gas rerouting
- Simulate emergency venting
- Align with Flag State (Finland) and Class (DNV) guidance
It’s part of the EU’s goal to cut GHG emissions from maritime by 80% by 2050.
Challenges and Regulatory Gaps
Inconsistent RBAT Implementation
While the IMO allows RBAT, different Flag States interpret risk thresholds differently. This can slow down deployment in cross-border operations.
The European Maritime Safety Agency (EMSA) and Paris MoU are working on a shared RBAT framework to smoothen approvals across EU waters.
Limited Capacity Among Port Authorities
EU ports must assess and approve new fuels under ISGINTT and port state rules. However, many lack trained inspectors.
The European Commission’s DG MOVE is funding training programs through CEF Transport to build this expertise.
Risk Communication and Public Trust
Toxic fuels like ammonia face public resistance in port cities. Transparency in RBAT assessments is essential.
Initiatives like GreenPorts Europe and the Baltic Ports Organization now include community stakeholders in safety planning.
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Future Outlook: Scaling with Confidence
RBAT is set to become a cornerstone of EU maritime innovation, especially as new regulatory packages emerge:
- ReFuelEU Maritime (2025) will link shipping to the Renewable Energy Directive
- Maritime ETS Phase 2 (2026) to include methane and nitrous oxide
- A full revision of the IGF Code (expected 2027–2028) to codify hydrogen and ammonia
In parallel, expect:
- Greater use of digital twins and simulation-based risk modeling
- AI-enhanced safety case development tools (e.g., DNV’s MarOS, Thetius RBAT plugins)
- Standardized port bunkering corridors with mutual recognition of RBAT cases
These trends will help meet Fit for 55 targets while boosting Europe’s maritime leadership.
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FAQ: RBAT and the EU Green Maritime Strategy
What is RBAT in shipping? Risk-Based Alternative Technology allows non-traditional ship designs or fuels if equivalent safety can be demonstrated.
How does RBAT relate to the EU Green Deal? RBAT helps shipowners adopt new fuels and technologies needed to meet the EU’s climate goals under Fit for 55.
Is RBAT part of IMO law? Yes, the IGF Code allows RBAT under Part A-1 for ships using low-flashpoint fuels.
Does every EU country recognize RBAT equally? Not always. EMSA and the European Commission are working on more harmonized interpretations.
What fuels are supported under RBAT? Hydrogen, ammonia, methanol, LNG, and even CCS systems can be validated via RBAT.
Do EU ports support RBAT vessels? Yes, especially major ports like Rotterdam, Antwerp, Hamburg, and Valencia.
Is RBAT only for new ships? No, it can also be applied to retrofits and hybrid propulsion systems.
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Conclusion: Bridging Innovation and Regulation
RBAT is more than a technical loophole—it’s a crucial enabler of Europe’s maritime transition. As the EU pushes toward climate neutrality, RBAT provides the agility needed to adopt fuels and technologies not yet fully codified. Whether it’s hydrogen tugs, ammonia-ready tankers, or onboard carbon capture, RBAT turns possibility into regulatory reality.
For shipowners, designers, and port operators, mastering RBAT is not just about compliance—it’s about leadership in the future of green maritime transport.
References
- European Commission: Fit for 55 Package
- FuelEU Maritime Regulation Overview
- IMO IGF Code
- EMSA: Maritime Green Deal Measures
- Clarksons Research: Alternative Fuel Ships
- DNV: RBAT and Alternative Fuels
- Wärtsilä CCS Pilot
- Port of Antwerp-Bruges Hydrogen Projects
- Paris MoU on Port State Control
- Baltic Ports Organization
- Maersk Methanol Fleet
- Thetius Maritime Tech Insights
- GreenPorts Europe
- TEN-T Corridor Maps