Overview
The UK legislation establishing the new UK MRV regime (SI 2018/1388) is now in place and can be accessed here.
On the 17 September 2021 the UK Government released its guidance on the application of the UK scheme for monitoring, reporting and verifying (MRV) carbon dioxide (CO2) emissions as Marine Information Note 669. Please click here for more information.
The type of vessels within scope of the UK MRV regime and type of emissions data for collection are the same as those under the EU MRV regime.
The only emissions data required to be reported under the UK MRV regime are for the following voyages:
- Voyages between two UK ports
- Voyages between a UK and non-EEA port
- Emissions generated within a UK port
- Emissions generated for voyages between a UK and non-EEA port
- Voyages between a port in the UK and a port in one of the UK Overseas Territories or Crown Dependencies
What we offer
- Assessment of conformity of every ship Monitoring Plan against the requirements defined in the UK MRV regime. The outcome of our assessment will be presented in a Monitoring Conformity Assessment Report.
- Verification of the Annual Emissions Report to verify the data and supporting information in the Emissions Report against the requirements defined in the UK MRV regime. Once the verification is successfully completed the final Verification Report and Document of Compliance will be available to your company.
Key deadlines
The UK has taken a decision to delay the requirement for ship operators to report emissions until a digital solution for reporting is fully operational (expected in 2025). A UK MRV Document of Compliance will not be required until the digital system is operational.
This does not affect the legal requirement for ship operators to monitor vessel emission and submit their emissions reports for annual verification to LR, which remains in place. The UK are only delaying the reporting requirement, with the data from any intervening years to be submitted once the new system is ready.
What should shipowners and ship operators do now?
Shipowners and operators should proceed with both IMO DCS, EU MRV & UK MRV submissions as soon as possible into LR’s CO2 Verifier platform, which can be accessed here, 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 help sections of the CO2 Verifier platform. When the supporting evidence is prepared, it can be bulk uploaded into CO2 Verifier and verification work by our technical staff can begin.
If you require any support with CO2 Verifier, please contact support.co2verifier@lr.org or use the help function built into the platform.
Accreditation
According to MIN 669 (M+F) Reporting Emissions Data into the UK MRV Regime & The Merchant Shipping (Monitoring, Reporting and Verification of Carbon Dioxide Emissions)(Amendment) (EU Exit) Regulations 2018 (UK Statutory Instrument 1388/2018 verifiers which are accredited for the EU MRV regime by a European National Accreditation Body, will be temporarily accepted as verifiers under the UK MRV regime.
The Department for Transport has agreed to extend the period during which the UK will allow verifiers accredited for the EU MRV by a European National Accreditation Body (NAB) to be recognised as verifiers under the UK MRV regime until the end of 2023.
LR is accredited by the Hellenic Accreditation System (E.S.Y.D) and this accreditation will remain valid under the UK MRV Scheme until the above date.
All verifiers must be accredited by the United Kingdom Accreditation Service (UKAS) for the provision of UK MRV verification work hence LR hasLR has already initiated the process to apply for UKAS Accreditation.
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Why does the UK have its own MRV scheme?
Following the UK’s exit from the European Union, the UK government committed to maintaining the existing legislation that was already in place, and therefore has established its own MRV scheme.
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Is the UK scheme similar to the EU scheme?
Yes. It is almost identical. The ships that are required to comply are the same. The types of data that need to be recorded are the same. The only real difference is the voyages that are required to have data recorded for.
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Which voyages does this apply to?
The UK scheme applies to:
- Emissions created on voyages between a UK* and a non-EEA port** Emissions
- Created on voyages between UK ports*
- Emissions generated at UK ports* for the above voyages.
The UK scheme doesn’t apply to voyages between UK ports and EEA** Ports, or vice versa.
*UK ports do not include UK Overseas Territories and Crown Dependencies such as the Isle of Man, the Channel Islands and Gibraltar.
**EEA is the European Economic Area and includes the European Union plus Norway and Iceland for the purposes of this requirement.
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What do I need to do now?
By 31 October 2021 review and amend the monitoring plan to ensure it covers the separate requirements of the UK MRV Scheme and submit it to Lloyd’s Register through CO2 Verifier as soon as possible in order for the assessment to be completed by the end of 2021. No additional evidence needs to be submitted.
By 31 December 2021 onboard systems need to be able to collect and record data separately for the EU and UK MRV Schemes. An assessed monitoring plan is to be in place.
From 1 January 2023 you should submit to Lloyd’s Register through CO2 Verifier the emissions reports of your vessels for the UK MRV Scheme (apart from EU MRV Scheme).
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Do I need to produce a separate UK MRV Monitoring Plan?
No. Ship operators with an existing monitoring plan which conforms to the EU MRV regime, may use their existing plan
– appropriately modified if necessary – for both the EU and the UK MRV regime. -
What changes do I need to make in an existing EU MRV Monitoring Plan?
Your modified Monitoring Plan under the UK MRV regime shall:
- Include which voyages will be reported under the UK MRV regime.
- Include the applicable legal framework is mentioned in the Monitoring Plan.
- Describe how a separate Emissions Report will be generated for the purposes of the UK MRV regime.
If different from the one already applicable for EU MRV, indicate the method which will be used to monitor and report emissions data, based on fuel consumption and other parameters, such as distance travelled, time at sea and cargo carried on a per voyage basis.
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Is Lloyd’s Register an accredited verifier?
Yes. Verifiers which are accredited for the EU MRV regime by a European National Accreditation Body are temporarily accepted as verifiers under the UK MRV regime until the end of 2022.
The Department for Transport has agreed to extend the period during which the UK will allow verifiers accredited for the EU MRV by a European National Accreditation Body (NAB) to be recognized as verifiers under the UK MRV regime until the end of 2023.
All verifiers must be accredited by the United Kingdom Accreditation Service (UKAS). LR is applying to UKAS and updates regarding the accreditation progress will be provided in due course.
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When do I need to start collecting emissions data?
Emissions data collection starts from 1 January 2022.
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Is the type of data I collect the same as that for the EU MRV scheme?
Yes. The type of data and parameters which need to be monitored on a per-voyage basis under the UK MRV regime are the same as those required under the EU MRV regime.
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How do I submit my data for verification?
Exactly the same way it was done for EU MRV. All required data will be submitted to Lloyd’s Register via CO2 Verifier.
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When do I submit my data for verification to Lloyd's Register?
The first year in which data needs to be submitted is 2023, for data collected during the 2022 reporting period. Ship operators should submit their data to LR for verification following each reporting period (calendar year). As per MIN 669 data should be submitted by 15 February 2023. This is then repeated in each subsequent year, for data collected in the preceding calendar year.
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Which data should be submitted for verification?
All UK MRV data collected during the previous reporting period should be submitted for verification.
No emissions data should be reported under the UK MRV for a voyage which begins in 2021 and finishes in 2022, because the UK is not collecting 2021 emissions data. However, in their 2022 report, operators will need to include any emissions from a voyage which begins in 2022 and finishes in 2023.
This is then repeated in each subsequent year, for data collected in the preceding calendar year.
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Will Lloyd’s Register submit my data to the UK Administration?
Yes. LR will verify the data, contact ship owners with any outstanding queries, and submit final reports to the UK Administration by 30 April each year, as soon as the equivalent to THETIS platform is ready.
Currently the UK has taken a decision to delay the requirement for ship operators to report emissions until a digital solution for reporting is fully operational (expected in 2025). A UK MRV Document of Compliance will not be required until the digital system is operational.
This does not affect the legal requirement for ship operators to monitor vessel emission and submit their emissions reports for annual verification to LR, which remains in place. The UK are only delaying the reporting requirement, with the data from any intervening years to be submitted once the new system is ready.
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Do I need a Certificate?
From 30 June of each year (as soon as the equivalent to THETIS platform is ready), ships that visited the UK will need to have a Document of Compliance (DoC) onboard, similar to that under the EU MRV scheme.
The DoC under the EU scheme is downloadable from THETIS_MRV. It’s unclear at this time if a similar arrangement
will be in place for the UK, or if the DoC will be issued by the UK government or the verifier.Each year a new DoC will be required for data collected and verified during the preceding calendar year.
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Do I have to prove that I have reported my UK to EEA emission under the MRV scheme?
Yes. The EU MRV DoC will be acceptable evidence for this.
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Have the UK Government produced any guidance on this?
Yes. See MIN 669.
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How could Lloyd’s Register assist me further?
For more information and guidance on contracting please contact your local office or fill in our Request For Information form
For any technical questions regarding the UK MRV Scheme please contact dcsmrv@lr.org