EMSA Guidance on Alternative Fuel Vehicles

Sales of Alternative Fuel Vehicles (AFVs), like electric cars and plug-in hybrids, are increasing rapidly in the EU. This means that both passenger and cargo ships will need to transport more and more of these types of vehicles. This is why the European Commission tasked the European Maritime Safety Agency (EMSA) to initiate a working group in 2021 to elaborate standards for the carriage of these vehicles both on ferries and on PCTC ships. The ‘EMSA guidance for AFVs in Ro-Ro spaces’ was published at the end of May 2022 and slightly amended in April 2025 (version 1.2).

ECG was an active member of this working group, besides many other interested parties including shipping lines, national safety organisations and, representing the OEMs, VW Group.

The work in this dedicated group will feed into the revision of the International Convention of Safety of Life at Sea (SOLAS) at the level of the International Maritime Organisation (IMO). This will be done not earlier than 2028 according to ECG’s information sources, that is why a European regional document has been issued on the carriage of Alternative Fuel Vehicles before the international revision can take place.

The document addresses the safety challenges posed by the transport of these vehicles and it contains two main statements for Finished Vehicle Logistics:

• In chapter 3.2.1 the document covers the need to visually identify AFVs by fuel types, although it is not stated how this should be done. This is a topic ECG was dealing with in a small working group in 2020 which resulted in the publication of its own document on the subject: this recommends applying stickers on the windscreen for a better visual identification on ship decks and compounds.
• In chapter 3.2.3 the minimum state of charge level is set at 20%, while the maximum state of charge at 50%. The maximum state of charge is recommended to avoid unnecessary carriage of charge during marine carriage as some scientific evidence shows a higher charged battery would burn at a hotter temperature. The minimum charge is needed to ensure minimum basic driving and operation of the vehicle, covering dwell time at port, vessel load and discharge operations, to First Point of Rest. These are the same figures which came out of the discussions in ECG’s own Electric Vehicles sub-group which analysed the current OEM practices on the minimum and maximum state of charge levels.