tLCAF / zLCAF — Approved Claims & Forbidden Claims
Internal guardrails for agency briefs, investor materials, partner discussions, and minisite copy. The objective is MRV-aware positioning without implying guaranteed regulatory outcomes, managed compliance services, or SAF/crediting claims.
One-Page Sheet
Non-negotiables (always true)
- Identity tLCAF / zLCAF are positioned as drop-in Jet A-1 products; do not blur into SAF or crediting unless explicitly scoped and evidenced.
- Deliverable We supply fuel + QA + traceability evidence. We do not “deliver compliance.”
- Control MRV interpretation is airline-controlled and verifier-led, subject to the operator’s plan and verification procedures.
Approved claim pattern
We provide inputs. We describe what we can produce and document at batch level.
Use: “can support…”, “where accepted…”, “subject to operator MRV plan and verification…”
If it’s not measurable, repeatable, and evidenced, it’s not a headline claim.
Forbidden claim pattern
We promise outcomes. We imply guaranteed acceptance, penalty avoidance, default overrides, or liability removal.
Avoid: “ensure compliance”, “prevent penalties”, “override defaults”, “certified for MRV”.
Even if intended as metaphor, external readers often interpret literally.
Approved Claims
| Category | Approved claims (examples) | Boundaries / notes |
|---|---|---|
| Product identity |
• “ASTM-grade drop-in Jet A-1 (tLCAF)” • “Drop-in Jet A-1 chemistry with documented fuel properties” • “zLCAF: development pathway toward ultra-low/zero aromatics variants (spec-bounded)” |
Do not imply SAF, credits, or mandated SAF compliance. Avoid “certified by regulators” unless documented. |
| Documentation |
• “QA + traceability evidence pack (CoA, batch ID, custody trail, delivery records)” • “Chain-of-custody documentation available per batch” • “Third-party test reports where available” |
Only promise what we can produce routinely. Clearly label third-party vs internal. |
| Operational framing |
• “Designed for fast market entry: drop-in fuel + standard QA” • “Low operational choreography: documentation cadence aligned to procurement/assurance workflows” • “Supports auditability and review” |
“Supports review” ≠ “delivers verification.” Keep it workflow-support, not compliance-service. |
| MRV-aware language |
• “Can help reduce reliance on default assumptions where primary fuel-property data is accepted” • “MRV interpretation remains airline-controlled and verifier-led” • “Provides inputs that can be used (or not used) within the operator’s MRV plan” |
Always conditionalize: can / where accepted / subject to.Never claim acceptance is guaranteed. |
| Performance claims |
• “High inherent lubricity / ultra-low sulfur (as evidenced by CoA)” • “Lower aromatics profile vs baseline fuel (per test results)” • “Batch-level properties documented and traceable” |
Tie to evidence: CoA, lab report, method. Avoid climate outcome claims unless carefully bounded. |
Forbidden Claims
| Forbidden claim / phrasing | Why it’s risky | Safe rewrite |
|---|---|---|
| “Compliance infrastructure” | Implies we deliver compliance outcomes or operate a regulated compliance workflow. | “Evidence pack” / “QA + traceability documentation” |
| “Ensures compliance / guarantees acceptance” | Outcome guarantee; acceptance is operator/verifier/regulator dependent. | “Can support…” + “subject to operator MRV plan and verification” |
| “Overrides defaults / eliminates default penalties” | Implies control over reporting defaults and regulator treatment. | “Can help reduce reliance on default assumptions where accepted” |
| “Prevents liabilities / avoids penalties” | Legal exposure; reads like a warranty against enforcement risk. | “Supports auditability and review; does not constitute assurance” |
| “Certified/approved for MRV” | Regulatory claim; must be formally true and evidenced. | “Documentation available to support verification review” |
| “NEATS/system integration” (unqualified) | Implies technical integration and scope we may not have contractually. | “Formatted outputs available on request” / “operator ingestion support” |
| Any SAF crediting implication | Category confusion; tLCAF/zLCAF are not SAF unless explicitly structured as such. | “Drop-in Jet A-1 + documentation; not a crediting mechanism” |
Agency-Brief Template
Standard “bounded claims” paragraph
DM-XTech supplies ASTM-grade drop-in Jet A-1 (tLCAF) and a development pathway toward zLCAF variants, together with a QA + traceability evidence pack (batch identity, test results/CoA, custody trail, and delivery records where available). Any non-CO₂ MRV interpretation remains airline-controlled and verifier-led, subject to the operator’s MRV plan and applicable verification procedures. DM-XTech does not provide regulated compliance services, verification opinions, or outcome guarantees; we provide fuel and supporting documentation inputs for operator evaluation.
Quick rule for reviewers: if a sentence sounds like a warranty (“ensures”, “prevents”, “guarantees”), rewrite it into an input-based, conditional statement (“can support”, “where accepted”, “subject to…”).