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SEEMP Part III

Since 1 January 2023, ships of 5,000 GT (Gross Tonnage) and above are required to have a verified Ship Energy Efficiency Management Plan, or SEEMP Part III, on board to document how their vessel plans to achieve its Carbon Intensity Indicator (CII) targets. The CII is a rating system for ships that the International Maritime Organization (IMO) developed.

The plan must include a description of how the vessel will operate and maintain its fuel efficiency throughout the year in line with its overall objective of reducing CO₂ emissions and meeting its CO₂ reduction commitments. SEEMP Part III documentation is in addition to SEEMP Part I and SEEMP Part II.

Which vessels must have SEEMP Part III on board?

The SEEMP Part III applies to any vessel on international voyages of 5,000GT and above, and within the categories mentioned in Regulation 26.3 of MARPOL Annex VI. These are: bulk carrier, combination carrier, containership, cruise passenger ship, gas carrier, general cargo ship, LNG carrier, refrigerated cargo carrier, ro-ro cargo ship, ro-ro cargo ship (vehicle carrier), ro-ro passenger ship, tanker, as defined in Regulation 2 of MARPOL Annex VI.

Steps to compliance:

1. Develop the Initial SEEMP Part III containing:

• CII Calculation Methodology
• Reporting Process
• Three-Year Required CII Values
• Three-Year Implementation Plan
• Self-Evaluation Procedure

2. Submit for Verification - The completed SEEMP Part III must be examined and verified by the Administration or an authorized Recognized Organization before a Confirmation of Compliance can be issued.

3. Implement the Plan - This is the stage where the SEEMP part III becomes an active management tool rather than simply a compliance document. Data must be collected and monitored throughout the year.

4. Calculate the Attained Annual CII and report - At the end of the reporting year calculate the attained annual operational CII and corresponding CII rating (A–E). Compare this with the required CII and the planned performance trajectory. Data and calculations must then be reported to the Administration / RO for verification and issuance of the Statement of Compliance.

5. Conduct Self-Evaluation – reviewing what worked, and didn't work to deliver planned emission reduction, including why this happened. Assess what needs to change. As necessary adjust the three-year plan.

6. Corrective Actions (if required)

If the ship receives:

• D rating for three consecutive years, or
• E rating in any year

the SEEMP Part III must be revised to include a Corrective Action Plan (CAP). The revised SEEMP must then be revised and verified.

7. Periodic update of the SEEMP part III – IF any of the elements of the SEEMP III re updates, or every three years, the SEEMP III must be re-verified by the Administration / RO.

NOTE: Ships delivered before 1 August 2025 which currently have an approved SEEMP Part III (Ship Operational Carbon Intensity Plan) will need to have this revised to include an implementation plan demonstrating how the required CII will be met for the three year- period 2026- 2028, as per the Guidelines for the Verification. See Class News 13/2025 for further details. 

8. Company Audit - Under MARPOL Annex VI Regulation 26.3.3, SEEMP Part III is subject to periodic company audits. The audit scope includes verifying that:

• The approved SEEMP continues to comply with Regulation 26.3.1.
• The ship is being operated in accordance with SEEMP Part III.
• Progress is being made on the three-year implementation plan.
• Progress is being made on any corrective action plan.
• Self-evaluation activities are being carried out.

Responsibilities for implementation and monitoring are clearly assigned.

These audits are generally undertaken at least once in every three years and within six months of issuance of the Statement of Compliance for fuel oil consumption reporting and operational carbon intensity rating.

For a more information see Class News 22/24: New guidelines for SEEMP Part III company audits and SEEMP Part III Company and Shipboard Audit FAQs.

How LR can help

We can assist ship owners and operators with the following:

1. SEEMP Part III template: to ensure you comply with regulatory requirements, we have designed a SEEMP Part III template with comprehensive guidance on how to complete it.
2. SEEMP Part III advisory: our advisory experts are available to assist you in preparing your SEEMP Part III plan, as well as vessel-specific analysis for improving your CII rating if required.
3. SEEMP Part III verification: submit your SEEMP Part III to us for review as soon as possible to ensure its onboard.