Applicability: Owners and operators of ships subject to air emission controls under MARPOL Annex VI

As reported in Class News 33/2017, the IMO has introduced a mandatory fuel oil consumption data collection system (IMO DCS). It requires internationally voyaging ships  of 5000gt or above to start collecting fuel consumption data from 1 January 2019.

The data must be collected using the method described in the ship’s ‘Ship Energy Efficiency Management Plan’ (SEEMP Part II). Existing ships are required to have a confirmed SEEMP Part II by no later than 31 December 2018. New ships delivered on or after 1 January 2019 must have a confirmed SEEMP Part II upon delivery.

The SEEMP Part II plans are required to be confirmed as meeting the IMO requirements by the vessel’s Flag Administration, or a delegated Recognised Organisation (RO), before issuing a Confirmation of Compliance to be retained on board the ship with the plan.

Failure to have a SEEMP Part II with an appropriate Confirmation of Compliance on board, on or after 1 January 2019, may cause issues for ships at Port State Control and other inspections.

What should owners and operators do now?
Owners and operators should submit each SEEMP Part II to Lloyd’s Register (LR) for review, if LR is the delegated RO, as soon as possible.

LR provides a cloud based compliance solution called CO2 Verifier to assist you with verification of both IMO DCS and EU MRV data. Details of CO2 Verifier  can be found on our website along with Guidance on SEEMP Part I and Part II and other Guidance on the EU MRV regulation and the IMO DCS.


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