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

As previously reported (Class News 01/2017), the IMO fuel oil consumption data collection system (IMO DCS) will come into force on 1 March 2018. The IMO recently finalised guidance to assist with the implementation of the regulation.

Here is a summary of the MARPOL Annex VI amendments adopted in 2016 (see Resolution MEPC.278(70)), along with existing and new guidelines to address these:

  • Ships of 5,000 GT and above engaged in international shipping will be required, from 2020 onwards, to submit to their Flag Administration or a Recognised Organisation (RO) nominated by the Flag (usually the ship’s Classification Society) annual reports on fuel oil consumption data for the previous calendar year (e.g. 2019 data), using a methodology to be described and included in the Ship Energy Efficiency Management Plan (SEEMP Part II needed on or before 31 Dec 2018).

See Resolution MEPC.282(70) on 2016 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP).

  • Upon the verification of the submitted data, the Flag Administration or RO will issue to the ship a Statement of Compliance related to fuel oil consumption.

See Resolution MEPC.292(71) on 2017 Guidelines for Administration verification of ship fuel oil consumption data.

  • Flag Administrations will submit aggregate data to the IMO, which will maintain an anonymised IMO Ship Fuel Oil Consumption Database and an annual report will be published.

Ships flying the flag of a non-Party State to MARPOL Annex VI will still be required to demonstrate compliance with these requirements.

What should owners and operators do now?
Owners and operators should start considering the means for collecting the fuel oil consumption data that is most appropriate for each ship and update the SEEMPs of their ships to reflect this process. Following this, they should submit each SEEMP Part II to Lloyd’s Register (LR) for approval, if LR is the delegated RO, as soon as possible.

LR has prepared Guidance on SEEMP Part I and Part II, which includes a template.

Once the first reporting period ends (i.e. calendar year 2019), ships can use the annual reporting template to submit their annual data.

To assist clients with the practical application of the IMO DCS regulation and the relevant EU scheme (MRV), LR has prepared Guidance on the EU MRV regulation and the IMO DCS for shipowners and operators.