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04 Feb, 2025

International Chamber of Shipping (ICS) Publishes First Definitive Guide on IMO Greenhouse Gas Regulations

The International Chamber of Shipping (ICS) has published the first definitive guide for the maritime sector on compliance with the International Maritime Organization (IMO) greenhouse gas (GHG) regulations. This guide is designed to help decision-makers identify significant technical and operational changes required to meet the IMO’s CO2 reduction targets for 2030.

“Reducing Greenhouse Gas Emissions: A Guide to IMO Regulatory Compliance” provides guidance on preparing for compliance within the IMO regulatory framework, particularly with the amendments made in 2021 to MARPOL Annex VI. It is the first comprehensive guidance and support portfolio developed for the maritime sector.

The guide includes the following key aspects:

Reducing carbon intensity using the Energy Efficiency Design Index (EEDI) for new ships and the Energy Efficiency Existing Ship Index (EEXI) for existing ships.
Submission of Ship Energy Efficiency Management Plans (SEEMP) for external audits and regulatory certification.
Implementation of the Carbon Intensity Indicator (CII), which involves collecting and reporting operational data annually and assigning ships an “A-E” rating.
Modification of existing ships, including technical information relevant to shipbuilding.
ICS plays a crucial role in reducing GHG emissions and, through its engagement with governments and Non-Governmental Organizations (NGOs), is at the center of facilitating and promoting discussions on GHG reduction at the IMO. Thanks to its ongoing dialogue with shipowners’ associations, ICS has gained a deep understanding of the practical concerns that impact shipowners and the information they need to make informed decisions.

The guide, “Reducing Greenhouse Gas Emissions: A Guide to IMO Regulatory Compliance,” is available for £150 and can be accessed via the ICS official website.

Compliance Timeline
Requirements Adopted Before 2021
Energy Efficiency Design Index (EEDI)
EEDI provides a new construction standard to ensure that newly built ships achieve the required efficiency level for reducing CO2 emissions. The standard is periodically revised by the IMO Marine Environment Protection Committee (MEPC) to introduce stricter requirements for future ships.

Ship Energy Efficiency Management Plans (SEEMP)
Following the 2011 amendments to MARPOL Annex VI, the implementation and maintenance of SEEMP became mandatory in 2013.

Data Collection System (DCS) for Fuel Consumption
As of January 1, 2019, ships of 5,000 GT and above must submit fuel consumption data verified by the Flag State or a Recognized Organization (RO) as part of the IMO Data Collection System (DCS), which is required for issuing a Statement of Compliance.

Requirements Adopted in 2021
Energy Efficiency Existing Ship Index (EEXI)
Effective January 1, 2023, existing ships must reduce their carbon intensity through EEXI, a goal-based technical measure similar to EEDI.

Enhanced SEEMP Concept
The 2021 amendments to MARPOL Annex VI introduced a new Part III for SEEMP. The Enhanced SEEMP will be subject to external verification and audits, similar to the philosophy of the IMO ISM Code.

Carbon Intensity Indicators (CII)
The 2021 amendments to MARPOL Annex VI also introduced CII, which assigns an annual “A-E” carbon intensity rating to both new and existing ships.

CII Data Reporting
Carbon intensity data will be verified and reported annually using a modified version of IMO DCS. Following reporting, ships will receive a Statement of Compliance that includes their A-E rating.

BEFORE 2023
Preparation for January 1, 2023
EEXI: Calculation and review of the ship’s EEXI value and planning for technical modifications if necessary.
Preparation of EEXI technical files.
By December 2022
SEEMP Part III must be developed to outline the ship’s operational carbon intensity plan.
Upon satisfactory evaluation by the Administration or RO, a Statement of Compliance will be issued.
Part III includes required annual operational CII values for the ship through 2025.
January 1, 2023
Implementation of the updated SEEMP Part III on board, with Statement of Compliance in place.
Commencement of CII data collection and monitoring for 2023.
First Periodic Survey (IAPP)
Verification of the ship’s attained EEXI value and EEXI technical file.
Upon successful survey completion, the International Energy Efficiency Certificate (IEEC) is issued by the Administration/RO.
November 30, 2023
Deadline for SEEMP-related company audits by the Administration/RO, if required.
December 31, 2023
End of the first year of CII implementation.
2024
January 1, 2024
Beginning of CII implementation for 2024.
March 31, 2024
Deadline for companies to submit the 2023 attained CII for verification by the Administration/RO.
After verification, a Statement of Compliance will be issued unless a corrective action plan is required.
April 30, 2024
Deadline for ships that received an “E” rating in 2023 to submit a corrective action plan for 2024 and 2025.
May 31, 2024
Additional verification by the Administration/RO for ships rated “E” to ensure a corrective action plan has been developed.
Final deadline for the Administration/RO to issue the ship’s 2023 Statement of Compliance, valid until May 31, 2025.
The Statement of Compliance must include the verified CII rating (A-E).
June 30, 2024
Final deadline for the Administration/RO to submit 2023 CII data to IMO DCS.
For further details, please feel free to contact us at any time using the contact numbers below.
If you have any questions regarding this newsletter, you can reach us 24/7 via the contact details provided below.

Esenyel Partners | New ICS Guidance is now available to help Ship Owners and Operators find solutions in EEXI and CII Emission Reduction regulations!
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