Without proper monitoring and reporting, it will be very difficult if not impossible to enter European Economic Area (EEA) ports after the summer of 2019.

The EU MRV regulation entered into force on 1 July 2015, and it requires shipowners and operators to annually monitor, report and verify CO2 emissions for ships larger than 5,000 gross tonnage calling at any EU or EEA, (including Norway and Iceland) ports. The monitoring, reporting and verification of information should be done in conformity with EU Regulation 2015/757 and as amended by Delegated Regulation 2016/2071 as earlier described on bimco.org. 

You may recall that by 31 August 2017, MRV companies should have submitted a Monitoring Plan to an accredited shipping verifier indicating the method chosen to monitor and report CO2 emissions and other relevant information. 

From 1 January 2018, MRV companies should monitor for each ship for their CO2 emissions, fuel consumption and other parameters, such as distance travelled, time at sea and cargo carried on a per-voyage basis.  The only exemption for "per-voyage recording" is applied to ships that conduct more than 300 voyages per year, and that either start from or end at an EU port. These ships are excluded from reporting on a per-voyage basis and must only record and report annual data sets. The data should be gathered into an annual Emissions Report and submitted to an accredited MRV shipping verifier for verification. 

To submit the emissions report, companies should use the electronic version of the template available in the THETIS MRV automated EU information system, operated by the European Maritime Safety Agency, EMSA. The EMSA template can be found here.

If a ship calls into an EEA port for the first time after the deadline 31 August 2017, without the necessary monitoring plans, the company should submit a monitoring plan to an accredited verifier without delay, and no later than two months after the ship’s first call to an EEA port.

From 2019 (by 30 April) and each year after, the MRV companies should submit a satisfactory, verified emissions report for each of the ships having performed maritime transport within the EEA area during the previous reporting period (calendar year).

From 2019, (by 30 June) and each year after, the MRV companies should ensure that they all carry on board a Document of Compliance issued by THETIS MRV. The penalties for not complying has still to be confirmed by member states. The suggestion is that the penalties will be put into effect, and if repeated may end in an expulsion order for that ship entering the port. This obligation might be subject to inspections by member states' port authorities.

All details on EU MRV and a list of frequently asked questions can be found here.

At the same time and after the International Maritime Organization (IMO) has adopted their global and mandatory fuel consumption data collection system for international shipping (IMO DCS) entering into force January 2019, the EU started a consultation process with the purpose of aligning the two reporting systems. BIMCO believes it is imperative that the EU aligns its MRV regulation into IMO DCS. A full alignment between the two systems is feasible and it will help to keep the cost of the administrative burden as low as possible. Requiring ship operations to manage two distinct and separate reporting systems which collect the same data does not bring any value.

The outcome of the consultation and alignment process is still unknown but until we have a decision, ship operators must monitor and prepare to report their 2018 fuel consumption data in accordance with the EU MRV regulation. Let’s hope for a solution that gives us a single and uniformed reporting system before we enter 2019.