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.

On the 5th of May 2023 this publication was withdrawn. This Marine information note has been superseded by MIN 669 (M+F) Amendment 1 - Reporting emissions data into the UK MRV regime.  This MIN expires 31st December 2024.

Where does it apply 

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

Our range of verification services have been designed to help minimise the risk of non-compliance against the MRV Regulation, giving you peace of mind. As a globally trusted and experienced verifier, you can be sure that your data is in safe hands.

Monitoring Plan Assessment
As an accredited and experienced verifier we can perform monitoring plan assessments as required by the regulation. We will work with you to assess your monitoring plans to ensure they comply. The outcome of our assessment will be presented in a Monitoring Conformity Assessment Report.

Emissions Report Verification
We can perform the required annual emissions verification for your vessel and we will work with you to verify your data and information so that a Document of Compliance can be issued. Once the verification is successfully completed the final Verification Report and Document of Compliance will be available to your company.

Pre-Verification Gap Analysis
We can provide a beneficial gap analysis against either your monitoring plans or your emissions report data, or both. This can be tailored to your specific needs. For example, we can focus on specific areas of concern or take a general overall approach. This will identify any gaps, provide confidence in your approach, and smooth the path to compliance.

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 submissions into LR’s Emissions Verifier, 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 Emissions Verifier portal.

Accreditation

According  to MIN 669 (M+F) Amendment 1 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 until the end of 2023, as part of the preparations for the establishment of the UK MRV regime.  

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 end of 2023.  
From 1 January 2024, all verifiers must be accredited by the United Kingdom Accreditation Service (UKAS) for the provision of UK MRV verification work hence LR has already initiated the process to apply for UKAS Accreditation. 

More information

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. 

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.  See below.

This similarity will change as amendments to the EU scheme come into effect from 2024, whereby the ship sizes change and the type of GHG emissions that data needs to be collected on change too. 

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. 

What do I need to do now?

Owners/managers of existing ships that go to the UK were required to review and amend their EU MRV monitoring plans and have them assessed by the end of 2021. Any owners/managers of existing vessels that haven’t been through that process yet, but which will be entering the UK will need to amend their EU MRV monitoring plan to ensure it covers the separate requirements of the UK MRV Scheme and submit it to Lloyd’s Register as soon as possible. No additional evidence needs to be submitted.

Ship operators must submit a monitoring plan to the verifier for newly acquired vessels, no later than two months after the ship’s first call to a UK port.

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.

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. 

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 2023.

From 1 January 2024, all verifiers must be accredited by the United Kingdom Accreditation Service (UKAS). LR has applied to UKAS and updates regarding the accreditation progress will be provided in due course. 

Do I need to start collecting emissions data now?

Yes. Emissions data collection started from 1 January 2022. 

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. This will change as modifications to the EU MRV come into effect from 2024 – some EU MRV plans are to be modified from 2024, some from 2025. 

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.

When do I submit my data for verification to Lloyd's Register?

Ship operators should submit their data to LR for verification following each reporting period (calendar year). As per MIN 669 Amendment 1 data should be submitted by 15 February each year for data collected in the preceding calendar year.

Which data should be submitted for verification?

All UK MRV data collected during the previous reporting period should be submitted for verification.

In their 2023 report, operators will need to include any emissions from a voyage which begins in 2023 and finishes in 2024.

This is then repeated in each subsequent year, for data collected in the preceding calendar year. 

Will Lloyd’s Register submit my data to the UK Administration?

No. LR will verify the data, contact ship owners with any outstanding queries, and maintain final verified reports until requested by the UK Administration.

Currently the UK is working to develop a digital reporting system and has taken a decision to delay the requirement for ship operators to report emissions until the digital reporting system is fully operational. Hence the verified emissions reports should be retained by the ship owner until the system is ready for the verified reports to be submitted.

Do I need a Certificate?

From 30 June 2023 ships that visited the UK in 2022 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.

A decision regarding the responsible party to issue the DoC for the UK MRV is expected by the UK government. Until reporting is required, a separate DoC will not be required by ship operators to cover voyages to and from UK ports, made in the previous reporting period, which fall outside the scope of the EU MRV.

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.

Have the UK Government produced any guidance on this?

Yes. See MIN 669 Amendment 1. 

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