Amendments of MARPOL Annex VI – EEXI and Operational Carbon Intensity Reduction.
18 June 2021
Applicability: shipowners, ship operators, ship managers, ship designers, shipbuilders and manufacturers.
The International Maritime Organization (IMO) has just adopted key mandatory requirements to reduce the carbon intensity of shipping: introducing the Energy Efficiency Existing Ship Index (EEXI) and operational carbon intensity reduction.
Lloyd’s Register (LR) is ready to help shipowners and operators to prepare for these two key changes to MARPOL Annex VI, which come into force on 1 November 2022. Preparing now is strongly recommended to achieve statutory approval before the deadline.
This release outlines the key changes and requirements adopted 17 June 2021 by the IMO’s Marine Environment Protection Committee’s 76th session (MEPC 76).
1. Introduction of the Energy Efficiency Existing Ship Index (new Regs. 23 and 25):
This technical efficiency measure requires all applicable vessels above 400 GT that operate internationally to hold:
- An attained EEXI or Energy Efficiency Design Index (EEDI) equal to or below the required EEXI of the vessel
- An Onboard Management Manual approved by a Recognised Organisation (RO), where Overridable Power Limitation (OPL) has been installed to improve the attained EEXI
- A verified attained EEXI (or EEDI where applicable) based on an EEXI (or EEDI where applicable) Technical File
- A Flag or RO issued International Energy Efficiency Certificate or Statement of Compliance following verification of the attained EEXI
Vessels to which EEXI applies must demonstrate compliance by their next scheduled survey – annual, intermediate or renewal – for the International Air Pollution Prevention Certificate (IAPPC) to be issued or endorsed, or the initial survey before the ship enters service for the International Energy Efficiency Certificate (IEEC) to be issued, whichever is the first on or after 1 January 2023.
Actions for ship owners and operators
LR can help with the following:
- If you have not yet commenced your EEXI calculations, we recommend starting now to ensure plenty of time for potential improvements and statutory approval before the deadline
- If you have already completed calculations for your fleet, you should ensure that these are still applicable and arrange for the calculated attained EEXI (and OPL impacts) to be updated where required
- Once a compliant EEXI has been attained, you can progress compilation of your Technical Files and Onboard Management Manuals (where applicable) and then progress with statutory approval
2. Demonstration of Operational Carbon Intensity reduction (new Reg. 28)
Applicable vessels (the same ship types as EEXI but 5,000 GT and above and adding cruise ships using conventional propulsion) will need to demonstrate reductions of carbon intensity between January 2023 and 2030.
Key amendments to MARPOL Annex VI:
- From 1 January 2023, evidence of carbon intensity reduction must be recorded in a new section of the vessel’s existing Management System for Carbon Intensity (SEEMP)
- Emissions data must be submitted through the IMO Data Collection System (DCS) in addition to the existing fuel consumption requirement. Emissions reporting must, as a minimum, include the Annual Efficiency Ratio (for Bulk Carriers, Tankers, Container Ships, General Cargo, LNG Carriers, Gas Carriers, combination carriers and Reefers) or the cgDIST (for passenger cruise ships, vehicle carriers, ro-ro cargo and ropax)
- Annual verification of DCS will continue. From 1 January 2024, vessels will be issued with a Statement of Compliance, covering verified fuel consumption, attained carbon intensity reduction and an annual rating (A to E) based on carbon intensity reduction performance against the required carbon intensity reduction
- Periodic SEEMP verification audits will be introduced to ensure plans are in place to achieve the targets and ensure correction plans are being followed where a vessel is rated E in any given year, or D in three consecutive years. The frequency and specific requirements of these audits is expected to be discussed at MEPC 77 in November 2021, with guidance developed in 2022
Carbon reduction targets and vessel ratings
A set of non-mandatory guidelines were approved by the IMO, setting a carbon intensity reduction of 2% each year between 2023 and 2026. Performance against this target will be used to provide the vessel its rating. The annual target is to be reviewed by the IMO no later than 1 January 2026.
The carbon intensity reduction requirements were approved with no ship-specific correction factors, though these are expected to be revisited during 2022.
Further information on the key outputs can be found in LR's MEPC 76 Summary Report.