Positioning Guardrails — tLCAF / zLCAF
Reference page for how DM-XTech describes tLCAF and zLCAF in external materials without implying guaranteed regulatory outcomes, managed “compliance services,” or SAF/crediting claims.
Why the tightening matters
- “Compliance infrastructure” and similar language can be interpreted as a promise that the fuel ensures compliance, avoids penalties, overrides defaults, or removes liabilities.
- It can imply DM-XTech provides a managed MRV / verification service rather than supplying fuel and documentation.
- It may suggest we control how regulators or reporting systems treat non-CO₂ effects, even though acceptance is operator-controlled and verifier-led and may evolve over time.
- Unbounded wording can blur into SAF crediting or regulated environmental claims.
- These misreads create avoidable friction: procurement objections, verifier skepticism, heavier diligence, and misrepresentation disputes.
We sell ASTM-grade drop-in Jet A-1 (tLCAF, and a pathway toward zLCAF variants) plus a standard QA + traceability evidence pack (batch identity, test results, custody trail, delivery records). Any non-CO₂ MRV interpretation remains airline-controlled and verifier-led.
| DO | DON’T |
|---|---|
| Describe deliverables in concrete terms: drop-in fuelQAtraceabilityevidence pack. | Claim outcomes: ensures complianceavoids penaltiesoverrides defaultsremoves liability. |
| Use conditional phrasing: “can support…”, “where accepted…”, “subject to the operator’s MRV plan and verification.” | Use deterministic phrasing: “will eliminate…”, “guarantees…”, “ensures acceptance…”, “prevents…”. |
| State governance clearly: “MRV interpretation remains airline-controlled and verifier-led.” | Imply DM-XTech is the MRV operator/verifier or provides regulated assurance opinions. |
| Keep categories clean: “not SAF”, “not a crediting mechanism”, “drop-in Jet A-1 + documentation.” | Blend into SAF/crediting language unless explicitly true, evidenced, and contractually scoped. |
What the evidence pack includes
Minimum pack (baseline)
- Batch ID; production window; custody chain; basic provenance records
- Certificate of Analysis (ASTM D1655 property set, as applicable)
- Third-party lab results where available (clearly labelled as third-party)
- Sampling protocol summary; sample retention details (when used)
- Delivery/shipping records; uplift logs where available
Optional (only when we truly have it)
- Enhanced characterization (e.g., aromatics breakdown beyond minimum spec)
- Operator-requested formatting for ingestion into internal reporting/assurance systems
- Non-CO₂ relevant proxies presented as inputs (not outcomes), with appropriate caveats
Rule: If we cannot produce it consistently, we do not headline it. If we cannot evidence it, we do not claim it.
Claims discipline checklist (mandatory for non-CO₂ / MRV references)
- Measurable? (property, procedure, document, record)
- Within our control? (fuel + documentation, not regulator acceptance)
- Conditionalized? (“can support…”, “where accepted…”, “subject to…”)
- Category-clean? (no SAF/credit conflation)
- Evidence on file? (report, SOP, template, custody trail)
Technical confirms factual accuracy + repeatability + evidence on file. Marketing confirms clarity, boundedness, and consistency. If either fails, rewrite before publication.