International shipping is a large and growing source of greenhouse gas emissions. The EU supports global action to tackle these emissions and has put in place EU-wide data collection measures.
Maritime transport emits around 940 million tonnes of CO2 annually and is responsible for about 2.5% of global greenhouse gas (GHG) emissions (3rd IMO GHG study).
These emissions are projected to increase significantly if mitigation measures are not put in place swiftly. According to the 3rd IMO GHG study, shipping emissions could under a business-as-usual scenario increase between 50% and 250% by 2050, undermining the objectives of the Paris Agreement.
At the same time, there is significant untapped potential to reduce shipping emissions cost-effectively. Many technical and operational measures, such as slow steaming, weather routing, contra-rotating propellers and propulsion efficiency devices, can deliver more fuel savings than the investment required.
Although a global approach to address GHG emissions from international shipping led by the International Maritime Organisation (IMO) would be the most effective and thus preferable, the relatively slow progress in the IMO has triggered the EU to take action.
Shipping emissions represent around 13% of the overall EU greenhouse gas emissions from the transport sector (2015).
In 2013, the Commission set out a strategy towards reducing GHG emissions from the shipping industry.
The strategy consists of 3 consecutive steps:
- Monitoring, reporting and verification of CO2 emissions from large ships using EU ports
- Greenhouse gas reduction targets for the maritime transport sector
- Further measures, including market-based measures, in the medium to long term.
The contribution of the shipping sector to emission reductions consistent with the temperature goals of the Paris Agreement remains an important issue in the EU.
The recent amendment to the EU Emissions Trading System (ETS) Directive, by Directive (EU) 2018/410 of the European Parliament and the Council, emphasises the need to act on shipping emissions as well as all other sectors of the economy.
The Directive also states that the Commission should regularly review IMO action and calls for action to address shipping emissions from the IMO or the EU to start from 2023, including preparatory work and stakeholder consultation.
On 14 July 2021, the European Commission adopted a series of legislative proposals setting out how it intends to achieve climate neutrality in the EU by 2050, including the intermediate target of an at least 55% net reduction in greenhouse gas emissions by 2030. The package proposes to revise several pieces of EU climate legislation, including the EU ETS, Effort Sharing Regulation, transport and land use legislation, setting out in real terms the ways in which the Commission intends to reach EU climate targets under the European Green Deal.
First step: monitor, report and verify CO2 emissions
From 1 January 2018, large ships over 5 000 gross tonnage loading or unloading cargo or passengers at ports in the European Economic Area (EEA) are to monitor and report their related CO2 emissions and other relevant information.
Monitoring, reporting and verification (MRV) of information shall be done in conformity with Regulation 2015/757 (as amended by Delegated Regulation 2016/2071).
Four other legal acts are also relevant:
- Delegated Regulation (EU) 2016/2072 on the verification activities and accreditation of verifiers
- Delegated Regulation (EU) 2016/2071 as regards the methods for monitoring carbon dioxide emissions and the rules for monitoring other relevant information
- Implementing Regulation 2016/1927 on templates
- Implementing Regulation 2016/1928 further defining cargo carried for some ship categories
Main obligations for companies eligible under the EU MRV Regulation:
- Monitoring: From 1 January 2018, companies shall – in line with their respective monitoring plans – monitor for each of their ships CO2 emissions, fuel consumption and other parameters, such as distance travelled, time at sea and cargo carried on a per voyage basis, so as to gather annual data into an emissions report submitted to an accredited MRV shipping verifier.
- Emissions report: From 2019, by 30 April of each year, companies shall, through THETIS MRV, submit to the Commission and to the States in which those ships are registered (‘flag States’) a satisfactorily verified emissions report for each ship that has performed maritime transport activities in the European Economic Area in the previous reporting period (calendar year).
- Document of compliance: From 2019, by 30 June of each year, companies shall ensure that all their ships that have performed activities in the previous reporting period and are visiting ports in the European Economic Area carry on board a document of compliance issued by THETIS MRV. This obligation might be subject to inspections by Member States' authorities.
Every year, the Commission publishes a report to inform the public about the CO2 emissions and energy efficiency information of the monitored fleet:
IMO Data Collection System
Following the adoption of the EU MRV Regulation, the IMO established an IMO Data Collection System.
The system requires owners of large ships (above 5 000 gross tonnage) engaged in international shipping to report information on fuel consumption of their ships to the flag States of those ships. The flag States then report aggregated data to the IMO, which shall produce an annual summary report to the IMO Marine Environment Protection Committee.
The IMO system entered into force in March 2018 and the collection of fuel consumption data started on 1 January 2019.
As a result, from 2019, ships calling into EEA ports will have to report under both the EU MRV Regulation and the IMO Data Collection System.
The EU MRV Regulation (Article 22) anticipated this situation as it foresees that the Commission should, in the event of an international agreement on a global MRV system for shipping emissions, review the regulation and, if appropriate, propose amendments to ensure alignment with that international agreement.
In February 2019, the European Commission made a proposal to amend the EU MRV Regulation to take appropriate account of the global data collection system.
Initial IMO greenhouse gas strategy
After considerable efforts over recent years, the IMO agreed in April 2018 on an initial greenhouse gas emissions reduction strategy.
In line with the internationally agreed temperature goals under the Paris Agreement, the strategy includes objectives to
- reduce total annual GHG emissions from shipping by at least 50% by 2050 compared to 2008 levels
- pursue efforts to phase them out as soon as possible in this century.
However, short-, mid- and long-term emission reduction measures, as well as research and innovation, necessary to achieve the objectives under the strategy remain to be developed and agreed.
In October 2018, the IMO Marine Environment Protection Committee agreed on a programme of follow-up actions to implement the initial strategy, with timelines for consideration and agreement on GHG reduction measures:
- Short-term measures are to be decided between 2020 and 2023.
- Proposals for mid- and long-term measures are to be considered, without mentioning the timelines for agreement.
The strategy will be revised in 2023, taking into account
- data from the IMO Data Collection System
- other data, such as reports by the Intergovernmental Panel on Climate Change.
EU support to IMO energy efficiency project
The European Commission contributes €10 million funding to an EC-IMO energy efficiency project.
As part of the 4-year project, Maritime Technology Cooperation Centres have been set up in 5 regions: Africa, Asia, the Caribbean, Latin America and the Pacific.
Through technical assistance and capacity-building, the centres will promote the uptake of low carbon technologies and operations in maritime transport in less developed countries.
This will also support the implementation of the internationally agreed energy efficiency rules and standards – Energy Efficiency Design Index (EEDI) and Ship Energy Efficiency Management Plan (SEEMP).
Strategy on maritime transport emissions
- 04/02/2019 – COM (2019) 38 - Proposal for amending Regulation (EU) 2015/757 in order to take appropriate account of the global data collection system for ship fuel oil consumption data
- 28/11/2016 - Decision of the EEA joint committee no 215/2016 amending Annexes XIII (Transport) and XX (Environment) to the EEA Agreement
- 22/11/2016 - Delegated Regulation (EU) 2016/2071 - Methods for monitoring carbon dioxide emissions and the rules for monitoring other relevant information
- 22/11/2016 - Delegated Regulation (EU) 2016/2072 - Monitoring, reporting and verification of carbon dioxide emissions from maritime transport
- 04/11/2016 - Implementing Regulation(EU) 2016/1927 - Templates for monitoring plans, emissions reports and documents of compliance pursuant to Regulation (EU) 2015/757
- 04/11/2016 - Implementing Regulation(EU) 2016/1928 - Determination of cargo carried for categories of ships other than passenger, ro-ro and container ships pursuant to Regulation (EU) 2015/757
- 19/05/2015 - Regulation 2015/757- Monitoring, reporting and verification of carbon dioxide emissions from maritime transport, and amending Directive 2009/16/EC
- 10/03/2015 - COM (2015) 128 - Communication concerning the position of the Council at first reading on the adoption of a Regulation on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport
- 28/06/2013 - COM (2013) 479 - Communication: Integrating maritime transport emissions in the EU's greenhouse gas reduction policies
- 28/06/2013 - COM (2013) 480 - Proposal for a Regulation on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport
- 28/06/2013 – SWD (2013) 236 - Executive summary of impact assessment
- 28/06/2013 – SWD (2013) 237 - Impact assessment - Part 1
- 28/06/2013 – SWD (2013) 237 - Impact assessment - Part 2
- 28/06/2013 – IP/13/622 – Maritime transport: first step to reduce emissions
- 28/06/2013 – MEMO/13/626 - Questions & Answers on greenhouse gas emissions from shipping
Guidance/best practices documents elaborated with MRV shipping experts
- Preparation of monitoring plans by companies
- Monitoring and reporting of fuel consumption, CO2 emissions and other relevant parameters;
- Assessment of monitoring plans by verifiers;
- Backward assessment of monitoring plans;
- Use of external ship tracking data by verifiers;
- Materiality and sampling;
- Verification of emissions reports by verifiers;
- Recommendations for improvements issued by verifiers;
- Assessment of verifiers by National Accreditation Bodies in order to issue an accreditation certificate;
- Dealing with situations where the accreditation is suspended or withdrawn close to the planned issuing date of the Document of Compliance (DOC) by the verifier.
- 26/03/2019 - A study to estimate the benefits of removing market barriers in the shipping sector
- 08/06/2016 - Study on potential impacts of design choice for monitoring, reporting and verification of CO2 emissions from maritime transport
- 03/07/2015 - GHG emission reduction potential of EU-related maritime transport and on its impacts
- 11/12/2014 - Maritime transport greenhouse gas data collection and management (MRV Procedures)
- 13/01/2013 - Support for the impact assessment of a proposal to address maritime transport greenhouse gas emissions (Technical annex)
- 20/09/2012 - Analysis of market barriers to cost effective GHG emission reductions in the maritime transport sector
- 12/2009 - Technical support for European action to reducing Greenhouse Gas Emissions from international
Frequently Asked Questions on the implementation of the MRV shipping Regulation
These Frequently Asked Questions aim to assist MRV (monitoring, reporting and verification) companies, verifiers and other stakeholders to implement the European Union MRV shipping legislation. It requires ships carrying out maritime transport activities to or from EEA ports to monitor and report information including verified data on their CO2 emissions from 1st of January 2018.
The legal framework for these obligations is established under Regulation (EU) 2015/757 on monitoring, reporting and verification of carbon dioxide emissions from maritime transport, (the MRV Shipping Regulation) which has been amended by Delegated Regulation 2016/2072 and it is to be read in conjunction with Delegated Regulation (EU) 2016/2071 and Implementing Regulations (EU) 2016/1927 and 2016/1928.
This document was prepared by DG CLIMA and does not commit the European Commission. Only the Court of Justice of the European Union is competent to authoritatively interpret the Union law.
SECTION I ON SHIPS COVERED BY THE MRV SHIPPING REGULATION
The MRV Shipping Regulation applies to ships above 5000 GT, in respect of their CO emissions released during their voyages from/to EEA ports (see below section on geographical scope) carried out after 1st January 2018.
Ships are subject to the MRV Regulation regardless of their flag. A limited number of categories of ships are excluded, including: warships, naval auxiliaries, fish-catching or fish-processing ships, ships not propelled by mechanical means, and government ships used for non-commercial purposes.
The MRV Shipping Regulation sets monitoring and reporting obligations for EEA- related voyages (see section on geographical scope below) carried out after 1st January 2018.
- originating or terminating in a port of call and
- serving the purpose of transporting passengers and cargo for commercial purposes
are defined as voyages.
Ballast voyages, from the last port of call where the ships has discharged cargo or disembarked passengers to the next port of call where cargo is loaded or passengers embark, also serve the purpose of transporting cargo and are therefore subject to the Regulation.
On the other hand, ships' movements that do not serve the purpose of transporting cargo or passengers for commercial purposes are not subject to the monitoring, reporting and verification requirements, for example;
- extraction and subsequent carriage of dredged material,
- ice-breaking activities,
- carrying, laying, and repairing of cables/pipelines for underwater for telecommunications, electric power transmission, or other purposes;
- providing support to offshore installations, such as drilling rigs, natural gas and oil platforms, offshore wind farms, and including in particular:
- carriage and positioning of anchors for drilling rigs,
- providing towage, salvage or other marine assistance/services to offshore installations,
- carriage of supplies and equipment to/ from offshore installations and ships;
- safety or rescue services provided to offshore installations,
- diving support,
- storing oil or gas without processing it,
- installation and decommissioning of subsea structures and offshore installations.
Ports of call are relevant as ending points / starting points of voyages. These are ports where a ship stops to load or unload cargo, or to embark or disembark passengers.
Stops in ports which do not fulfil these conditions are not ports of call, for instance if a ship stops in a port for the sole purpose of refuelling, obtaining supplies, relieving the crew, going into dry-dock or making repairs to the ship and/or its equipment.
Also stops in ports due to the ship being in need of assistance, or in distress or for the sole purpose of taking shelter from adverse weather or rendered necessary by search and rescue activities are not considered ports of call.
"Ship to ship" transfers carried out outside ports are covered by the Regulation as part of a voyage calculated from the last port of call to the next port of call. Variations of cargo arising from "ship to ship transfers" outside ports during a voyage should be taken into account. In those cases a weighted average for cargo carried should be calculated and applied to the entire voyage.
CO2 emissions occurred within EEA ports of call are covered and are to be reported annually as an aggregated annual figure and a separate item under the emissions report. Cargo and other related parameters such as "distance travelled" or "cargo carried" are not to be monitored and reported while ships are just moving within ports of call between two voyages.
The expression "ports of call under the jurisdiction of a Member State" refers to ports of call located on "EU territory", (in other words, to which EU law fully applies). Not all ports belonging to an EU Member State are EU territories (see list below). For a voyage to be covered by the MRV Regulation at least one of the ports of call shall be located in a EU territory. Ports of call in the nine EU outermost regions (Açores, Madeira, Canarias, Guadeloupe, French Guyana, Martinique, Mayotte, Saint Martin and Reunion), and also ports of call in Norway (except those on Svarbald) and Iceland qualify as EU ports of call.
|EEA Member States' Overseas Countries and Territories which do not qualify as EU ports of call|
|Greenland and the Faroe Islands|
|French Polynesia, New Caledonia, Saint Barthélemy, Saint Pierre and Miquelon, Wallis and Futuna|
|Aruba, Bonaire, Saba, Sint Eustatius, Curaçao, Sint Maarten|
|Anguilla, Bermuda, British Antarctic Territory, British Indian Ocean Territory, British Virgin Islands, Cayman Islands, Falkland Islands, Bailiwick of Guernsey, Isle of Man, Jersey, Montserrat, Pitcairn, Henderson, Ducie and Oeno Islands, Saint Helena, Ascension and Tristan da Cunha, South Georgia and the South Sandwich Islands, Turks and Caico Islands, Akrotiri and Dhekelia|
In practical terms, it implies that:
- voyages between a port of call located on the territories above and another port of call qualifying as EU port of call constitute "incoming"/ "outgoing" voyages and are to be monitored and later reported;
- voyages between two ports of call located on the territories above do not fall under the MRV Shipping Regulation.
The process for incorporating the MRV Shipping Regulation into the European Economic Area Agreement (EEA Agreement) has been launched and will be finalised by mid-2017. It implies that the monitoring, reporting and verification requirements will cover from 1st January 2018 the following:
- voyages from a last port of call outside the European Economic Area (EEA) to a port of call situated in Norway or Iceland (EEA EFTA incoming voyages),
- voyages from a port of call located in Norway or Iceland to their next port of call outside the EEA (EEA EFTA outgoing voyages),
- voyages between two ports of call in Norway and/ or in Iceland (intra EEA EFTA voyages) and,
- emissions within Norvegian and Icelandic ports of call.
MRV obligations are to be fulfilled on a "per ship" basis. The company fulfilling the MRV obligations is called the "MRV company".
The MRV company can be either the shipowner or any other organisation or person, such as the manager or the bareboat charterer, which has assumed the responsibility for the operation of the ship from the shipowner. The MRV companies need to submit a monitoring plan for each of the ships operating under their responsibility to an accredited verifier.
The MRV Shipping Regulation allows the parties involved in the operation of each ship subject to the Regulation to determine, who assumes the MRV monitoring and reporting obligations. From a practical point of view, and if necessary, a relevant clause could be inserted in the charter party (C/P) so as to clarify who is doing what in relation to the MRV Shipping Regulation. In this context, the company mentioned in the SOLAS Safety Management Code could be responsible for MRV requirements.
Changes of MRV company are to be properly reflected in the monitoring plan.
According to the MRV Shipping Regulation, MRV companies shall, for each of their ships carrying out voyages related to "EEA ports" after 1st January 2018, fulfil the following monitoring and reporting obligations:
- By 31st August 2017, MRV companies shall submit a monitoring plan to a MRV accredited verifier. It consists of transparent and complete documentation of the monitoring method and procedures to be applied to each of their ships.
- From 1st January 2018 (1st reporting period under the MRV shipping Regulation) MRV companies shall, on the basis of the ship's satisfactorily assessed monitoring plan, monitor the ships CO2 emissions, fuel consumption and other relevant information with a view to aggregate data into an annual emissions report.
- From 2019, by 30th April of each year, the MRV company responsible for the ship on 31st December of the reporting period submits a satisfactorily verified emissions report to the Commission using a dedicated Union information system (also called THETIS MRV database (still under development). In parallel, MRV verifiers are to indicate that the Emission report has been considered satisfactory so the conditions for issuing a Document of Compliance have been fulfilled.
- From 2019, by 30th June of each year, ships having carried out activities falling under the MRV Regulation during the precedent calendar year (reporting period X) shall carry on board a valid MRV Document of Compliance, issued in accordance with the THETIS MRV database, when calling at EEA ports.
For ships which call into EEA ports for the first time after the deadline for submitting monitoring plans (set on 31st August 2017), MRV companies should submit a monitoring plan to an accredited verifier without delay, and no later than two months after the ship's first call at an EEA port.
A ship which has not carried out any EEA-related voyages during a whole reporting period (calendar year X) will not be required by Member States' authorities to have a Document of Compliance on board showing compliance for that specific reporting period (year X), when calling at EEA ports between 30th June of year X+1 and 29th June of year X+2.
The monitoring plan reflects the technical specifications and the monitoring methods to be applied to the voyages carried out by the ship concerned and which fall under the Regulation. It is prepared by the company having assumed the MRV responsibilities for this specific ship.
To avoid redundant submission of information, MRV companies can identify when sub-mitting information to an accredited verifier; :
- the information which applies in an identical manner to their entire fleet ('company-specific parts');
- the information whih reflects the ship's technical characteristics and specific procedures (ship specific parts).
There are no specific legal requirements regarding the way MRV companies are to submit monitoring plans to accredited verifiers, so it is up to the parties to agree on these issues bilaterally.
Monitoring plans can be established in any language agreed between the MRV company and the accredited verifier. However there is an obligation to ensure that an English translation of the satisfactorily assessed monitoring plan is available.
MRV companies shall prepare monitoring plans using a template corresponding to the model in Annex I of the Implementing Regulation (EU) 2016/1927. Information concerning all mandatory items, as identified in the monitoring plan model, has to be included, regardless of the way this information is structured. Companies can decide how to organise the information to reflect their monitoring systems and procedures.
Additionally, a number of voluntary fields that might be relevant for limited number of ship categories, are identified in the monitoring plan model in Annex I to Regulation 2016/1927. These voluntary fields concern for example:
- the ice class of the ship and procedures, responsibilities, formulae and data sources for determining and recording the distance travelled and the time spent at sea when navigating through ice, if applicable and
- other procedures relevant to monitoring of fuel consumed and CO2 emitted such as the procedures for determining and recording the fuel consumption for dynamic positioning, or the average density of cargo transported.
Information on procedures and other elements included under the voluntary fields on the monitoring plan is also part of the assessment by the verifier.
A MRV company is exempt from the obligation to monitor a specified ship on a "per-voyage basis", if according to schedule:
- all of the ship's voyages during the reporting period are EEA-related voyages and
- the ship performs more than 300 voyages during the reporting period.
Both conditions need to be fulfilled at the beginning of the reporting period.
In practical terms, it implies that providing data to the verifier on 'per voyage' monitoring is not compulsory to the extent that other documents and data (such as BDNs) could be used to calculate the ship's aggregated data.
MRV companies have to document their procedures to calculate aggregated data in the monitoring plan according to the table C.1 of the template in Annex I to Implementing Regulation 2016/1927.
National Accreditation Bodies (NABs) pursuant to Commission Regulation (EC) 765/2008 are the sole competent bodies in EEA Member States granting accreditation to legal entities performing verification activities pursuant to the MRV Shipping Regulation.
As a general rule legal entities established in the EEA shall request accreditation from the national accreditation body of the Member State in which they are established, or from the national body to which that Member State has had recourse. Only under exceptional circumstances that are identified under Regulation 765/2008, can an EEA legal entity request accreditation by a different NAB.
Non-EU legal entities have a choice to introduce a request in any of the European national accreditation bodies providing for accreditation for MRV shipping activities.
A list of NABs providing accreditation for MRV shipping verification activities together with access to the different NABs' list of accredited verifiers as provided in their web page.
As part of the accreditation process, the competent NAB carries out an assessment of whether all the requirements in Delegated Regulation EU 2016/2072 on verification and accreditation pursuant to the MRV shipping Regulation and in EN/ISO 14065 have been met. The assessment process will include a review of the relevant documents, office visit (s) and one or more witness audits of the performance and competence of the verifier's staff. As a result an accreditation certificate will be issued to the legal entity.
There might be differences in the process carried out by each NAB so please refer to the competent NAB as soon as possible so as to prepare for a timely start of the accreditation process. Also planning of the accreditation process has to be agreed upon between the legal entity seeking accreditation and the competent NAB.
National accreditation bodies (NABs) are to set up and manage a public database which includes information on at least:
- the name, accreditation number and address of each verifier accredited by that NAB;
- the date on which the accreditation or certification was granted and its expiry date; and
- information on administrative measures that have been imposed upon the verifier.
MRV companies will be able to select any duly accredited verifier irrespective of the ship's flag or the place where the MRV company is based and where the accredited verifier is based.
An accredited verifier can perform verification activities for any ship falling under the MRV Shipping Regulation, irrespective of where the MRV company is based, of where the ship is registered and of where the verifier itself is based. However, verification activities for a MRV company in respect of which the verifier has a conflict of interest or pose an unacceptable risk to their impartiality are not possible.
A verifier must be accredited by the time it issues its conclusions on monitoring plans or on emissions reports.
To ensure that verifiers are accredited in time, verifiers should submit their request for accreditation sufficiently in time so as to enable the NAB to complete the whole accreditation process in time.