2024 Report on CNFs in Road Transport – Working Group on Monitoring Methodologies
Eurogas is a participant in the Working Group on Monitoring Methodologies of CO2 Neutral Fuels (CNFs).
This report was prepared to respond to the European Commission’s request to industry, OEMs and fuel companies, to present technological options that can prove and monitor the use of CO2 neutral fuels in new vehicles, and contribute to the European Commission’s commitment to present a methodology for registering vehicles running on CO2 neutral fuels.
Monitoring CO2 neutral fuels implies the tracking and tracing of the fuel from the production or entry point, in case of imports, all the way down to the final use in a given vehicle. The Working Group on Monitoring Methodologies (WGMM) the before features a broad sectorial representation including OEMs and their suppliers, fuel producers and fuels suppliers, fuel retailers and their equipment suppliers, in order to ensure that the TCMV’s proposed methodology fits the requirements of all sectors of the automotive and fuels value chain for a robust and reliable proofing and reporting methodology.
A Technology Neutral, Inclusive and Consistent Definition for CO2 Neutral Fuels is Needed to Avoid Over-Complexity of the EU Regulation
The work of the WGMM started with an assessment of the compromise agreed between Germany and the Executive Vice-President Timmermans in March 2023, and the Commission’s briefing to the member state experts in the TCMV, the proposed fuels definition and the pre-suggested methodologies identified by the Commission services.
The Commission proposal of September 2023 only included eFuels, also labelled RFNBOs, in its definition of CO2 neutral fuels and required these fuels to have a 100% GHG emission savings based on the “lifecycle analysis” of the fuel. This approach is evaluated by the experts in the WGMM as technically very difficult to achieve currently and inconsistent with the overall EU Green Deal goals defined as “net-zero”, recognizing GHG emissions and also absorption/storage by either biogenic or industrial means. The Working Group’s proposal aims to correct this inconsistency, and proposes an alternative definition "CO2 neutral fuel' means all fuels defined by the Renewable Energy Directive (EU) 2018/2001, provided that they meet the sustainability criteria of that Directive and associated delegated acts, where the same amount of CO2 from biomass, ambient air or recycled carbon sources is bound in the fuel production as is released during combustion in the use phase. Those fuels shall include renewable and/or synthetic fuels, such as biofuel, biogas, biomass fuel, renewable liquid and gaseous transport fuel of non-biological origin (RFNBO) or a recycled carbon fuel (RCF).” There should be one unique definition of CO2 neutral fuels for all EU legislative acts.
CO2 Neutral Fuels Complementary to Electrification in Road Transport The report furthermore shows that the inclusion of CO2 neutral fuels in road transport does not weaken the new vehicle CO2 reduction targets, but instead, would be a complement to battery-electric and hydrogen-powered vehicles with the potential of accelerating the decarbonisation of road transport.
Road Transport the Lead Market to Create a Long-Term Investment Case for CO2 Neutral Fuels for the Benefit of all Transport Sectors. Thanks to the size of the market and investment resources, the potential economies of scale, the significant taxation share of fuels, and the need for a market access for the co-products stemming for instance from Sustainable Aviation Fuels (SAF), road transport can be the ideal market for scaling up the uptake of CO2 neutral fuels, enabling industrial scale production and cost reduction for businesses and citizens. The Role of Biofuels? Biofuels represent today 90% of renewables in road transport and they can continue to meet a large part of future increased energy demand. Biofuels are currently commercially available and delivered in sufficient amounts and thus available to accelerate the decarbonisation of the transport sector significantly.
Fuelling Technologies for Vehicles & Retail
The report’s main objective is to provide the Commission, TCMV experts and their administration in Member States with a comprehensive, objective, neutral and technical assessment of all identified fuel monitoring options. The members of the WGMM, and the experts who contributed to the work have no intention to recommend any of the proposed methodologies, the final decision remaining the sole responsibility of the legislator.
Two Potential Approaches, and 11 Technology Options to Monitor CO2 Neutral Fuels The assessment performed by the experts of the WGMM concluded that, in the current stage of technology development, 2 main approaches can be considered for the use and monitoring of CO2 neutral fuels in a new vehicle class after 2035:
• Direct and exclusive CO2 neutral fuel supply to the vehicle where the fuels is delivered through a dedicated and isolated infrastructure end-to-end, in an exclusive manner, through fuel pumps that only supply 100% CO2 Neutral Fuel.
• Fuel Marking: well-established fuel identifier technology that uses a distinct physical marker additive, which can now be used to prove CNF throughout the supply chain.
• Digital Fuel Tracking System (DFTS): already used in industrial safety systems, this technology enables secure digital tracking and ledger accounting of CNF across fuel supply system and vehicle operation.
• On-board Detection: vehicle-based group of technologies that can immediately detect presence or absence of CNF during fuelling by chemical or physical tests, and enable/disable vehicle operation.
• Physical security of fuel connections to enable CNF but prevent fossil-based fuel throughput
• CO2 neutral fuel supply for specific vehicle via the overall fuel supply system, where the CO2 neutral fuel is delivered via the current fuel infrastructure currently shared with petroleum fuels. This approach is particularly adapted for gaseous fuels. The fuel requirements of the vehicle are exactly matched with the same quantity of CNF supplied into the overall fuel supply system and securely monitored and matched with the vehicle through a digital tracking system.
Outcome of the Evaluation Matrix
Option 1 - Mechanical Adaption of Tank Filler / Nozzle: Mechanical adaption of the filler neck and the nozzle would physically prevent that the wrong fuel is filled but in practice, it is prone to tampering and might not be considered as robust enough when used alone. Additionally, it will incorporate high efforts for the development of new standards and hardware at both filling station and vehicle, including additional integration efforts.
Option 2 - Fuel Marker along Upstream and Downstream: A fuel marker and sensor in the vehicle physically tracks the CNF. This methodology is already used for heating oil, but there is currently no off-the-shelf automotive sensor available. New developments for automotive requirements (e.g. robustness, selectivity, sensitivity) are expected. With regards to tampering robustness, marking the fossil fuel may be a more robust solution.
Option 3 - 100% Digital Tracking from Upstream to Downstream DFTS w/ Digital Handshake): The DFTS (digital fuel tracking system) is a 100 % digital solution along the entire delivery chain, completely based on the existing data and infrastructure of the different stakeholders. Via a digital handshake, the reliable pairing of vehicle and nozzle is enabled and allows flexible inducement reaction. Manipulation robustness is assured by reliability checks within a multi-trust centre approach (stakeholder – cloud - vehicle). The solution needs technical adaptations in the vehicle, logistics and fuelling stations.
Option 4 - Hybrid Approach – Upstream Fuel Marker & Sensor Until EU Border – Downstream - DFTS w/ Digital Handshake: A potential means to improve the sensor & marker approach could be a hybrid approach in combination with the DFTS. Within this solution, the lack of automotive ready sensors could be bypassed by performing a digital handshake with filling station, based on a sensor signal which measures the fuel marker in the filling station itself. Less stringent requirements for such a sensor could therefore apply, which leads to lower integration efforts at the OEM side and faster time to market.
Option 5 - Vehicle On-Board Fuel Detection Function: On board fuel detection by processing the existing Engine Control Unit (ECU) signals is a pragmatic software solution which is based on data already available in the vehicle. The solution may work for CNFs with properties which are different to conventional ones such as HVO and Diesel. However, currently no solution for gaseous fuels is known. It might require calibration to include possible future fuels, since the actual measurement value (correlating with property) may change from one fuel source to another, resulting in additional deployment efforts in-field.
Option 6 – Vehicle On-Board Fuel Molecular Sensor: A molecular structure sensor is another option which directly tracks the fuel type in the vehicle. It is not a marker as proposed in Option 2. The on-board sensor is available in series production and fulfils the standards outlined in EN590 and EN228.
It is capable of providing the on-board, real-time final verification required by the EU, as it already does in bus and truck applications to detect fossil fuels. CNF detection has been successfully implemented for standards such as EN14214 and EN15940, and new databases are currently being developed for eFuel molecules like MtG and FT.
Option 7 - Bidirectional Communication Between Vehicle and Filling Station: Bidirectional communication between the vehicle and the filling station provides a tamper-proof approach which could be used as a 1-to-1 pairing solution between nozzle and vehicle. Next to the secure authentication process, the solution provides a filling monitoring and a blockage device in the filler neck, which can inhibit filling with conventional fuel. However, to fulfil tampering requirements, the solution needs technical adaptations.
Option 8 - CNF Exclusively Available in EU market: While this scenario is unrealistic to be considered for 2035, it is one that is certainly possible in the longer-term and so is worthy of considering as part of the overall transition strategy for transport in the EU. This assumes that CNF is exclusively available, likely some years away, and would be the result of substantial scale-up of CNFs for road transport alongside the needs of other sectors, and also the reduction of overall liquid and gaseous fuels demand, achieved by efficiency and electrification.
Option 9 - Mass-Balanced CNF Supply to Each CNF Vehicle: Mass-balancing is an indirect solution which focuses on an input-output approach, controlled by booking and claiming of certificates. Trading markets such as electricity and gaseous fuels in pipelines are efficiently controlled by such an approach. This means for a potential CNF application, that the fuel may not be physically consumed in the claiming CNF vehicle. But the fuel supply system reliably assures that the CNF amount is introduced in average elsewhere into the market. Such a solution would benefit from high system efficiency, fast ramp-up of fuel production and fuel supply chain whilst enabling that in the introduction phase filling stations do not need to have a dedicated CNF pump.
Option 10 - Fuel Usage Balancing: Fuel Usage Balancing solution uses a mass-balancing approach based on tracking of fuel energy in the vehicle tank without a handshake between filling station and vehicle. Instead of the filling station, the responsibility of certificate handling is transferred to the motorist, who is directly connected with a certificate marketplace, which may be an efficient solution for fleet customers in commercial vehicle segment.
However, for average end-customer in passenger car segment, the solution might be a burden by transferring too much responsibility to the motorist for certificate handling.
Option 11– Digital Tracking with Mass Balancing: Since mass-balancing (Option 9) is based on a certificate handling mechanism which incorporates average reporting of the stakeholders to an authority, a hybrid solution in combination with a DFTS (see option 3) is proposed. This system benefits from a fast accumulation of certificates on single vehicle level since it can include the DFTS as monitoring platform and performer of the digital handshake between the vehicle and the filling station. So, accurate and in-time certificate handling could be assured per individual vehicle. In addition, the vehicle has an inducement system mechanism to monitor the usage of CO2 neutral fuels.
Methodology Assessment from Customer and Retailer Perspective
The report also focuses on the requirements and considerations for customers and retail sectors to ensure the successful integration and acceptance of CNF powered vehicles, and the enabling technologies (Chapter 6). It addresses the technology requirements for a successful CNF roll-out and monitoring. To this end, it evaluates the identified technology options from various angles including availability, costs implications, ease of use, security of monitoring and inducement technologies.
These technologies also have potential applications beyond the European Union, thereby laying a robust foundation for the widespread adoption of CNF. It is important to ensure that CNF dedicated vehicles can operate beyond EU boundaries and to establish control mechanisms that prevent the use of non-CNFs. Options for this issue are also addressed.
The report furthermore provides an analysis of the effective inducement system required for supporting the EU’s CO2 Neutral Fuel (CNF) requirements. The experts recommend the incorporation a fuelling monitoring system to track CNF use to ensure the vehicle is exclusively fuelled with CNF, an inducement system in the form of a mechanism that reacts if non-CNF is detected, enforcing compliance through various responses.
Finally, the report explores the issue of regulatory geofencing which is a direct consequence from the inducement systems chosen to ensure compliance with CNF requirements. Regulatory geofencing influences how vehicles function outside EU borders and affects the resale value of used vehicles in non-EU regions. The analysis describes the implications for vehicle usability, enforcement, and potential misuse outside the EU, and the impact on customers.
Regulatory Evaluation
The report is completed by a detailed analysis of all regulations to identify adaptations that may be required to recognise individual CNF monitoring methodologies (Chapter 7). The report describes the advantages, disadvantages and impacts from a regulatory perspective, which includes an assessment of the prospect and time duration for potential implementations, and formulates brief amendments where possible.
The report “Monitoring the use of CO2 Neutral Fuels in Road Transport – a Cross-Sectoral Industry Assessment” is available in digital version and will complemented with factsheet type information for all monitoring methodologies described.
