– The Ministry of Oceans and Fisheries’ draft Enforcement Rule under the Special Act on Support for the Establishment of Green Shipping Corridors includes ships powered by biofuels or renewable synthetic fuels in the category of green ships.
– The greenhouse gas reduction potential of biofuels and renewable synthetic fuels varies depending on feedstocks and production methods.
– The Ministry of Oceans and Fisheries must establish standards to verify life-cycle greenhouse gas reductions and the sustainability of fuel supply chains.
The Special Act on Support for the Establishment of Green Shipping Corridors, enacted in March 2026, aims to support the shipping industry’s response to international greenhouse gas regulations and its transition toward more environmentally sustainable operations. Ahead of the Act’s entry into force in April 2027, the Ministry of Oceans and Fisheries (MOF) opened a public consultation on its draft Enforcement Decree and Enforcement Rule from September 2 to October 13, 2026. Under Article 2(4) of the draft Enforcement Rule, ships powered by biofuels or renewable synthetic fuels are included in the category of green ships. However, the provision defines green ships solely on the basis of fuel type, without establishing specific requirements to verify actual greenhouse gas reductions or the sustainability of fuel supply chains.
Not all biofuels and renewable synthetic fuels produce fewer greenhouse gas emissions than fossil fuels or are environmentally sustainable. In particular, when biofuel feedstock production involves deforestation or peatland degradation, the resulting emissions can offset the expected climate benefits or even lead to higher overall emissions. The greenhouse gas emissions associated with renewable synthetic fuels also vary depending on the energy sources and feedstocks used in their production. Green ship designation should therefore be based not simply on the use of particular fuels, but on greenhouse gas emissions across the entire life cycle, from feedstock production to fuel consumption.
In 2023, the International Maritime Organization (IMO) adopted a target of achieving net-zero greenhouse gas emissions from international shipping by or around 2050 and developed guidelines for assessing the life-cycle greenhouse gas emissions of marine fuels. Although these guidelines are not yet legally binding, they provide a technical foundation for the IMO’s efforts to regulate greenhouse gas emissions from marine fuels. The European Union (EU) has moved further by implementing the FuelEU Maritime Regulation since 2025.
The regulation imposes progressively stricter reduction requirements based on the life-cycle greenhouse gas intensity of the total energy actually used on board ships. In particular, biofuels produced from food and feed crops, as well as biofuels that fail to meet sustainability criteria, are assigned emission factors equivalent to those of the least favorable fossil fuel pathway. In other words, the regulation evaluates actual emissions reductions and production conditions rather than fuel labels.
South Korea’s biofuel supply chain is already heavily dependent on imported feedstocks, particularly palm oil-derived materials. According to data published by the United States Department of Agriculture (USDA) in 2026, approximately 77% of the feedstocks used for domestic biodiesel production in 2024 were imported, with palm oil-derived materials accounting for about 93% of those imports. Palm oil-derived feedstocks also represented approximately 72% of all feedstocks used in domestic biodiesel production. As the government continues to increase the mandatory biodiesel blending rate, expanding biofuel demand into the shipping sector would intensify competition for feedstocks and could further deepen dependence on palm oil-derived materials.
In Indonesia and other major palm oil-producing countries, large-scale plantation development has been associated with deforestation, peatland destruction, violations of land rights affecting local communities and Indigenous Peoples, and labor rights abuses. Given the close links between South Korea’s biofuel supply chains and overseas production areas, environmental and human rights impacts arising from feedstock production and procurement must also be addressed. Granting green ship status to vessels using biofuels without adequately assessing environmental and human rights risks throughout their feedstock supply chains could result in environmental and human rights abuses in overseas feedstock-producing regions being concealed under the label of “green.”
On October 13, Alliance for Resource & Climate Justice Center (ARC) submitted formal comments to the Ministry of Oceans and Fisheries calling for amendments to Article 2(4) of the draft Enforcement Rule. ARC proposed introducing requirements to verify life-cycle greenhouse gas reductions as part of the criteria for green ship designation, with emissions reductions calculated on the basis of the types and quantities of fuels actually used on board. ARC also called for excluding biofuels derived from food and feed crops, as well as feedstocks associated with high risks of deforestation, peatland degradation, and direct or indirect land-use change, from eligibility for green ship designation. In addition, ARC urged the government to mandate feedstock supply chain traceability and environmental and human rights due diligence. For renewable synthetic fuels, ARC proposed requirements to verify the use of renewable energy-based hydrogen, the origins of carbon inputs, and life-cycle greenhouse gas emissions.
The Ministry of Oceans and Fisheries must reconsider the draft Enforcement Rule, which allows ships to qualify for green ship status simply by using biofuels or renewable synthetic fuels. Clear and enforceable standards are needed to verify genuine greenhouse gas reductions and assess environmental and human rights risks throughout fuel supply chains.
October 15, 2026
Alliance for Resource & Climate Justice Center