The International Chamber of Shipping (ICS) has published the first comprehensive guide for the maritime sector on IMO greenhouse gas regulations to help decision-makers identify key technical and operational changes they will face in achieving the 2030 CO2 reduction targets accepted by the International Maritime Organization (IMO).
Greenhouse Gas Emission Reduction: IMO Regulatory Compliance Guide provides guidance for preparing compliance with the IMO regulatory framework, especially the amendments made in MARPOL Annex VI in 2021, during the decarbonization process. This is published as the first guidance and support portfolio developed for the maritime sector.
The Guide covers the following aspects:
Reduction of 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 audit and legal certification.
Use of the Carbon Intensity Indicator (CII) and collection and submission of operational data where ships are rated “A-E” annually.
Modification of existing ships, including information related to ship construction.
ICS plays a key role in greenhouse gas emission reduction, facilitating and promoting greenhouse gas discussions at IMO through its regular contact with governments and non-governmental organizations. Thanks to ongoing dialogue with shipowner association members, ICS has gained a real understanding of the information shipowners need to address practical concerns affecting them and to make informed decisions.
Greenhouse Gas Emission Reduction: IMO Regulatory Compliance Guide is priced at £150 and can be accessed from the ICS official website.
Compliance Timeline
Requirements accepted before 2021:
Energy Efficiency Design Index (EEDI):
EEDI provides a new construction standard aimed at ensuring newly built ships meet the required efficiency levels to reduce CO2 emissions. The standard is periodically revised by IMO MEPC to strengthen applications for future ships.
Ship Energy Efficiency Management Plans (SEEMP):
The creation and possession of SEEMPs became mandatory in 2013 following amendments made in MARPOL Annex VI in 2011.
Ship Fuel Consumption Data Collection System (DCS):
From January 1, 2019, ships of 5,000 GT and above are required to submit verified fuel consumption data for use in the IMO Data Collection System (DCS) and a Compliance Declaration certified by Flag States or Recognized Organizations (RO).
Requirements accepted in 2021:
Energy Efficiency Existing Ship Index (EEXI):
Starting January 1, 2023, existing ships will be required to reduce their carbon intensity through a target-based technical measure, the Energy Efficiency Existing Ship Index, similar to EEDI.
Enhanced SEEMP Concept: The 2021 amendments to MARPOL Annex VI introduce a new Section III for the already mandatory SEEMP. The enhanced SEEMP will be subject to external verifications and audits, in line with the IMO ISM Code philosophy.
Carbon Intensity Indicators (CII):
Also, under the 2021 amendments to MARPOL Annex VI, operational Carbon Intensity Indicators (CII) for new and existing ships will be used to indicate their annual “A-E” carbon intensity rating.
Reporting of Carbon Intensity Indicator (CII) Data:
Data related to carbon intensity, which will be verified and reported using the modified version of the IMO DCS, will be submitted annually. After reporting, ships will receive a Compliance Declaration containing an “A-E” rating.
2023 and Earlier
Preparation for January 1, 2023:
EEXI:
Calculation of the ship’s EEXI value, review, and planning of technical modifications, if necessary.
EEXI Technical Files: Preparation of technical files for EEXI.
By December 2022 or earlier:
SEEMP:
A new Section III of SEEMP detailing the ship’s operational carbon intensity plan must be created.
Satisfactory Evaluation: When satisfactory evaluations are made by the Administration or RO, a Compliance Approval is issued.
January 1, 2023:
Updated SEEMP Section III: Application of the updated SEEMP Section III on the ship with Compliance Approval.
CII Data Collection: Beginning of CII data collection and monitoring.
First Periodic Survey (IAPP):
Verification of the ship’s “Achieved EEXI” value and EEXI technical files. Following a satisfactory survey, the Administration/RO will issue the International Energy Efficiency Certificate (IEEC).
November 30, 2023:
Deadline for requested firm audits related to SEEMP by the Administration/RO.
December 31, 2023:
End of CII implementation for 2023.
2024
January 1, 2024:
Beginning of CII implementation for 2024.
March 31, 2024:
Deadline for firms to submit the 2023 “Achieved CII” for verification by the Administration/RO. A Compliance Declaration will be issued unless corrective action plans are required.
April 30, 2024:
Deadline for submission of corrective action plans for ships rated E in 2023, applicable for 2024 and 2025.
May 31, 2024:
Verification of corrective action plan creation for ships rated E (by the Administration/RO).
June 30, 2024:
Deadline for transferring 2023 CII data to IMO DCS by the Administration/RO.
For further details on this topic, feel free to contact us anytime via the contact numbers below.
