This article examines the adequacy of the Greenhouse Gas Fuel Intensity (GFI) indicator, which is a key element of the IMO's developing Regulations on the Net-Zero Framework and the methodology for assessing Well-to-Wake (WtW) lifecycle emissions. Based on a representative sample of ships under the Russian flag (oil tankers, container ships, dry cargo ships (general cargo)) with various CII ratings, the authors performed a series of calculations for seven scenarios replacing conventional fuel with very low sulfur fuel oil (VLSFO) and biofuels (FAME, HVO).

The results of the study showed that the GFI indicator is insensitive to a ship's operational efficiency, and switching to alternative fuel types does not lead to a significant reduction in the carbon footprint under the WtW methodology. It was established that by 2030, most ships will be obliged to pay "carbon fees" to the IMO Net-Zero Fund. Paradoxically, the most economically advantageous strategy for a shipowner in the short term is to refrain from implementing biofuels, as their adoption leads to double expenses (higher fuel costs plus the IMO payments). The authors conclude that in its current form, the GFI is an instrument of fiscal, rather than direct environmental, regulation. Its effectiveness is only possible through a comprehensive approach that combines energy efficiency improvements and the use of external energy sources.