EU MRV Regulation

Overview

The regulation covers the monitoring, reporting and verification of CO₂ emissions, cargo carried, miles travelled and time spent at sea. It is applicable to vessels of all flags conducting commercial voyages into, out of and between EEA ports (the EU  plus Norway and Iceland) and will require the submission of a verified ship annual emissions report to a central database and an annual public disclosure of the data on a ship basis.

Irrespective of flag, the regulation applies to ships greater than 5,000 GT (with some exceptions as listed below) undertaking one or more voyages into, out of and between ports that are under the jurisdiction of a EEA Member State. It requires the per-voyage and yearly monitoring of CO₂ emissions, as well as the monitoring of other parameters, including the quantities of cargo carried, distance travelled and time spent at sea.

Where does it apply?

The regulation applies to commercial voyages only, which means any movement of a ship that calls at an EU port to offload or load cargo, or travelling on a ballast voyage, or to embark or disembark passengers for commercial purposes. Voyages calling at an EEA port for bunkering, relieving crew, supply stops, dry-docking, maintenance, safe harbour, etc., are excluded from monitoring and reporting requirements.

Ships exempt from the EU MRV regulation include warships, naval auxiliaries, fish-catching or processing ships, wooden ships of a primitive build, ships not propelled by mechanical means and government ships used for non-commercial purposes.

Offshore vessels fall under the category of ‘other ship types’ and in particular cover service ships, off-shore supply vessels, dredgers and drilling ships. It is recommended that MRV rules should not need to be developed for those ships under consideration to the extent that their movements and activities fall outside the scope of the EU MRV regulation. These ship types, although engaged in the transport of passengers and cargo, rarely follow the rules of ‘traditional’ maritime transport.

Ship movements and activities serving the purpose of supporting ‘offshore activities’ are not under the scope of the EU MRV regulation. In applying this interpretation, ‘offshore activities’ means activities in connection with the exploration of or extraction from the seabed or subsoil, or their natural resources. This also covers the actual task of exploring or extracting.

Monitoring and reporting requirements apply to ships at berth as well as at sea. This includes when a ship is anchored in an EEA port and may not be involved in cargo operations but is using fuel for hotel purposes.

Ships are exempt from the obligation to monitor this information on a per-voyage basis if they undertake more than 300 voyages within the reporting period or if all of their voyages during the period either start or end at a port under the jurisdiction of an EEA member state.

Irrespective of flag, the regulation applies to ships greater than 5,000 GT (with some exceptions as listed below) undertaking one or more voyages into, out of and between ports that are under the jurisdiction of a member state. It requires the per-voyage and yearly monitoring of CO₂ emissions, as well as the monitoring of other parameters, including the quantities of cargo carried, miles travelled and time spent at sea. For the purpose of the EU MRV regulation, the member states are defined in below table.

Table 1: EU countries within the European Economic Area

Ports to be considered within the EU MRV regulation are within the above 'EU territories', where EU law fully applies. Ports of call in the nine EU outermost regions are also included, namely Açores, Madeira, Canarias, Guadeloupe, French Guyana, Martinique, Mayotte, Saint Martin, and Réunion. Table 2 lists the countries and territories where the EU MRV regulation is not applicable.

Table 2: EEA Member states’ overseas countries and territories that do not qualify as EU ports of call

What we offer

Our range of verification services have been designed to help minimise the risk of non-compliance against the MRV Regulation, giving you peace of mind. As a globally trusted and experienced verifier, you can be sure that your data is in safe hands.

Monitoring Plan Assessment

As an accredited and experienced verifier we can perform monitoring plan assessments as required by the regulation. We will work with you to assess your monitoring plans to ensure they comply. The outcome of our assessment will be presented in a Monitoring Conformity Assessment Report.

Emissions Report Verification

We can perform the required annual emissions verification for your vessel and we will work with you to verify your data and information so that a Document of Compliance can be issued. Once the verification is successfully completed the final Verification Report and Document of Compliance will be available to your company.

Pre-Verification Gap Analysis

We can provide a beneficial gap analysis against either your monitoring plans or your emissions report data, or both. This can be tailored to your specific needs. For example, we can focus on specific areas of concern or take a general overall approach. This will identify any gaps, provide confidence in your approach, and smooth the path to compliance.

Key deadlines

• by 30 April of each year, submit a verified emissions report to the European Commission (EC) and relevant flag state 
• 30 June 2019 onwards – carry a valid DoC relating to the relevant reporting period
• 30 June each year – ships’ emissions reports made publicly available by the EC 

Ships that have historically never visited an EEA port and therefore do not have an approved monitoring plan or a DoC are still allowed to trade in the EU, but will need to prepare a monitoring plan within two months of their first visit and will need to submit a report of this voyage for the reporting period. 

The PSC will check that there is a DoC on board. If a copy is not on board, the ship is not in compliance with the legislation and is thus liable for fines, or even detention, as determined by the member state. 

What should shipowners and ship operators do?

Shipowners and operators should proceed with submissions into LR’s Emissions Verifier, to provide sufficient time for LR to identify any errors or misstatements.
 
The data should be supplemented by an ‘evidence pack’ of supporting information to enable the verification work to be completed. Details of what should be included in the evidence pack are provided in the Emissions Verifier portal.

Accreditation

LR is accredited by the Hellenic Accreditation System (E.S.Y.D) and this accreditation remains valid. As an accredited verification body according to the requirements of ISO 14065, you can be sure that your data will be verified by experienced industry experts.

More information

Which data should be monitoring, reported and submitted?

Each company will be required to produce a ship-specific monitoring plan, which will be used to collect and monitor data on a per-voyage or annual basis, as applicable. The content of the plans could be similar or standardised across a fleet, and as such the plan can be separated into ship-specific and fleet-wide sections.

The monitoring plan is an electronic document in which the company describes the design of the management system that the ship has in place in order to monitor the required parameters and the ship-specific details. There is no requirement to hold the monitoring plan on board the vessel. The content of the monitoring plan is shown in Table 3.

The parameters to be monitored and reported include the following: 

• Port of departure and port of arrival, including the date and hour of departure and arrival
• Amount and emission factor for each type of fuel consumed
• CO₂ emitted
• Distance travelled
• Cargo carried
• Time spent at sea (excluding anchoring)
• Transport work 

It should be noted that the amounts of each type of fuel consumed at sea and at port (respectively) should be reported separately.

CO₂ will be monitored with reference to the following emissions sources on board:

• Main engines
• Auxiliary engines
• Gas turbines
• Boilers
• Inert gas generator 

CO₂ emissions will either be calculated based on fuel consumption and use of IMO default emissions factors for the fuel type being consumed, or by direct emissions monitoring, with a back calculation of the fuel consumption using the relevant emissions factor. As part of the monitoring plan, companies will be able to choose one or more of the following four methods for monitoring fuel consumption in each monitored combustion source.

• Method A – use of bunker delivery notes (BDNs) and periodic stocktakes of fuel tanks (except for those vessels where cargo is used as fuel)
• Method B – bunker fuel-tank monitoring,
• Method C – flow meters (including a gas meter for LNG carriers) for applicable combustion processes
• Method D – direct emission measurements 

A combination of these methods would improve the accuracy of the CO₂ emissions measurement for a given combustion source and is permitted. These monitoring methods are goal based and enable shipowners and operators to make use of existing systems on board ships where possible, avoiding the need for investment in new and potentially expensive equipment.

The density of the fuel also needs to be determined through either the BDNs or onboard measurement systems. Alternatively, the density from a company’s independent fuel analysis can be taken.

Reporting periods are defined as calendar years. For voyages starting and ending in two different calendar years, the monitoring and reporting data is to be accounted under the first calendar year. For example, a voyage starting on 21 December 2018 and ending on 10 January 2019 would be included in the 2018 annual report.

At the start of the first monitoring period, it is recommended that a voyage that started in the previous year but concluded in the first monitoring period be included.

Annually, ‘companies’ (International Safety Management DoC holders) must provide a ship-specific emissions report for the previous calendar year’s activity for each ship. This will include the technical efficiency of the ship (the Energy Efficiency Design Index (EEDI) or the Estimated Index Value (EIV) in accordance with IMO resolution MEPC.231(65), where applicable) and the aggregated data of the parameters outlined in Table 5. Table 5 shows the parameters to be reported annually.

The emissions report will be submitted to a third-party accredited verifier for verification. The verified report will be submitted to the EU THETIS MRV platform. 
Member states (and flag states) will receive and/ or have access to the emissions report and DoCs of ships flying their flag.

• Verification involves the inspection and independent confirmation of information related to the: 
• identification of the company, the ship and the monitoring and reporting system, including the design of processes, systems, risks and controls (this information is to be summarised and referenced in the monitoring plan), and 
• monitoring and reporting of CO₂ emissions and transport work, including documents providing evidence for the reported data points for fuel, distance, time and cargo per voyage, documents demonstrating execution of internal controls, and documents demonstrating adequate calculations, aggregation and consolidation of data.

Is there any guidance on this?

Useful guidance available from the following sources:

• European Commission FAQ's
• EMSA
• LR MRV Regulation Shipowners’ Information Note

You can find detailed information on submissions to THETIS MRV, the Information System to Support Regulation (EU) 2015/57 in the following link: https://www.emsa.europa.eu/thetis-mrv.html

How could Lloyd’s Register assist me further?

For more information and guidance please contact your local office or fill in our Request For Information form. For any technical questions regarding the EU MRV please contact dcsmrv@lr.org