Stop Choosing Fuels. Start Choosing Rulebooks

I’ve written before about how maritime conversations are shifting from fuels to maths. But as that shift accelerates, a new danger has emerged: Regulatory Illiteracy. Most low-carbon fuel strategies don't fail because the math is wrong; they fail because the rulebook governing the math was misunderstood.

In the new energy economy, the physical properties of a fuel are secondary. What matters is its regulatory DNA, and the corresponding birth certificate to evidence it.

The Molecule is Not the Product

We are moving from an era of commodities to an era of attributes (akin to birth certificates). A "green" molecule is worthless if the regulator does not recognize its origin, its transport path, or its carbon-capture credentials. If you focus on the molecule first, you are buying a physical product and hoping it has financial value.

The Shift: You aren't just buying fuel; you are buying a Right to Operate.

The ROI is in the Accounting, Not the Chemistry

The biggest risk to your ROI isn't the price of Hydrogen or Ammonia, it's The Boundary. A fuel that looks "clean" when you burn it (Tank-to-Wake) might be a "polluter" when you calculate its total lifecycle (Well-to-Wake). If the regulator moves the goalposts from one to the other, your 10-year investment could become a liability overnight.

Don't Delegate Your Strategy to "Compliance"

Most organizations delegate MRV (Monitoring, Reporting, and Verification) to the back office. This is a strategic error. In a regulated market, MRV is your profit engine. It is the mechanism that proves your fuel is worth the premium you paid. So make sure your data is audit-ready from day one.

The New Boardroom Checklist

To flip the script, stop asking your teams about fuel availability. Ask these three questions instead:

  1. Which rulebook are we playing by? (FuelEU, EU ETS, IMO?)

  2. Does our data survive an audit? (Is the proof digital and traceable?)

  3. Are we buying a molecule or an attribute? (Ensure you own the "greenness," not just the liquid.)

The Bottom Line

Regulatory literacy is the only way to avoid Stranded Premium Risk syndrome. Don't pick a fuel and hope the rules fit. Pick the rulebook you want to win in, and then find the fuel that gets you there.

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Systemise Decarbonisation

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January 1st, 2026: The End of the EU ETS "Grace Period"