MRV – Monitoring, Reporting and Verification (EU and UK)

As of 1 January 2024, the EU MRV regulation covers the following types of greenhouse gas emission:

- Carbon dioxide (CO2)

- Methan (CH4)

- Nitrous oxide (N2O)

The EU MRV regulation applies the berth-to-berth concept for voyages. Hence, a voyage starts at berth of one port of call and ends at berth of the next port of call.

Sailing with a pilot and/or anchoring while waiting for port entrance are part of the voyage. The time spent at sea shall be calculated based on port departure and arrival information and shall exclude anchoring.

For a voyage to be covered by the EU MRV, at least one of the two ports of call of the voyage must be located in an EU territory, i.e. voyages into, within and out of the EU shall be reported.

No, only ports where cargo is loaded or unloaded or where passengers embark or disembark are considered ports of call. Consequently, stops 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, as well as stops in port because the ship is in need of assistance or in distress, stops for ship-to-ship transfers carried out outside ports or stops for the sole purpose of taking shelter from adverse weather or rendered necessary by search and rescue activities are excluded.

The expression “ports under the jurisdiction of a Member State” refers to ports located in “EU territory”, i.e. to which EU law fully applies: ports in the nine EU Outermost Regions (Açores, Canarias, French Guyana, Guadeloupe, Madeira, Martinique, Mayotte, Reunion and Saint Martin) as well as ports in Norway (except those on Svarbald) and Iceland qualify as EU ports.

EEA member states’ overseas countries and territories which do not qualify as EU ports of call: Akrotiri, Anguilla, Aruba, Ascension, Bailiwick of Guernsey, Bermuda, British Antarctic Territory, British Indian Ocean Territory, British Virgin Islands, Bonaire, Caico Island, Cayman Islands, Curaçao, Ducie Island, Dhekelia, Falkland Islands, Faroe Islands, French Polynesia, Futuna, Greenland, Henderson, Isle of Man, Jersey, Miquelon, Montserrat, New Caledonia, Oeno Island, Pitcairn, Saba, Saint Barthélemy, Saint Helena, Saint Pierre, Sint Eustatius, Sint Maarten, South Georgia, South Sandwich Islands, Svalbard, Turks Island, Tristan da Cunha, Wallis.

Source: https://www.emsa.europa.eu/reducing-emissions/mrv-changes/faq-mrv-changes.html

All relevant data need to be monitored on a voyage basis and then aggregated annually.

The EU MRV is neither class nor flag related, so this will have no effect on the EU MRV reporting.

No, DNV can also perform the verification for ships not classed with DNV.

The company shall submit a Monitoring Plan to the verifier (DNV) without undue delay and no later than two months after that ship’s first call at a port under the jurisdiction of an EU member state.

The Owner or ISM company is responsible for EU MRV compliance.

From 5 June 2023, revisions to the MRV regulation requires that upon change of company, a partial MRV Emissions Report (ER) is to be submitted for verification. The verified partial MRV ER should be submitted to the administering authority, flag state authorities of member states, the European Commission and the new company as close as practical to the day of change of company and no later than three (3) months thereafter. The verified data covering the previous company’s responsibility period should form part of the MRV ER that will be submitted by the company responsible at the end of the reporting year.

However, the previous company’s emissions for a vessel which has been taken over by a company will not be part of the aggregated emissions data at the company level for the new company. Therefore, the company taking over the ship will not be liable to surrender allowances for the period when the vessel was not under the previous management or ownership. Nevertheless, the current owner/manager still needs to request the verified aggregated MRV data for the previous company’s period to fulfil MRV obligations at the end of the year. This data, combined with the log abstract data, will form a full-year MRV ER. 

No, DNV as verifier only verifies submitted data and issues a DoC based on that report. DNV is in no position to confirm that a vessel has not been compliant within the scope of EU MRV during previous years, without verification.

Movements related to the installation of wind turbines offshore or to the carriage of supplies to wind turbines will continue to be not subject to the EU MRV regulation until the reporting period 2024. 

From reporting period 2025, offshore ships of 400+ GT will have to monitor their emissions according to MRV.From 2027, units of 5,000+ GT will have to also surrender allowances for their emissions according to the ETS; for units of 400 GT to 5,000 GT, this is yet to be decided by the EU. The definition of “offshore ship” is also pending, but we would expect that wind turbine installation vessels would fall under that definition.

Greenhouse gas (GHG) emissions from offshore ships shall cover GHG emissions released during voyages from the last port of call to a port of call under the jurisdiction of a member state and from a port of call under the jurisdiction of a member state to the next port of call, as well as within ports of call under the jurisdiction of a member state by the following ships, other than ice breakers, designed or certified to perform service activities offshore or at offshore installations: accommodation ship, anchor handling tug supply vessel, cable layer, cable repair ship, crew/supply vessel, commissioning service operation vessel, diving support vessel, dredger, drilling ship, floating production storage and offloading (FPSO), floating storage and offloading (FSO), gas, hopper dredger, gas processing vessel, mining vessel, offshore construction vessel, offshore supply ship, offshore support vessel, oil, pipe burying vessel, pipe carrier, pipe layer, pipe layer crane vessel, platform supply ship, production testing vessel, research survey vessel, service operation vessel, standby safety vessel, trenching support vessel, well stimulation vessel, wind turbine installation vessel, work/repair vessel.

“Port of call” for offshore vessels means the port where ship stops to relieve the crew.

Yes, if the offshore facility has an asssigned UN/LOCODE and/or is permanently connected to a port. Any offshore facility having an assigned UN/LOCODE and any offshore facility located outside port areas but permanently connected to a port are considered ports within the EU MRV maritime regulation. Stops at those facilities will therefore be considered a port of call, provided that the loading/unloading of cargo or passengers or relieving of the crew take place there.

More information: https://climate.ec.europa.eu/document/download/31875b4f-39b9-4cde-a4e2-fbb8f65ee703_en?filename=policy_transport_shipping_gd1_maritime_en.pdf

EU MRV applies to Windfarm installation jack-ups as such, but as long as they are operating in windfarm installation (and not transporting cargo from one port to the next), those activities are currently not within MRV scope. This means the vessel should have an MRV monitoring plan, but do not need to monitor nor report consumption, time and distance when operating in windfarm installation. If they have been working in this way for an entire year, they don’t need to submit an MRV emissions report for that year.

From reporting period 2025 on, this will change: MRV will introduce the ship type "offshore ships" and has already changed the definition of port of call for offshore ships, so that ports where offshore ships relieve the crew will be considered as ports of call and thus be starting and ending points of MRV-relevant voyages. (The definition of "offshore ship" is pending, but we would expect that wind turbine installation vessels will fall under that definition.)

IMO DCS applies to windfarm installation jack-ups. They are no platforms in the sense of MARPOL Annex VI which would be excluded. They must carry a verified SEEMP II on board (and the related confirmation of compliance) and they must monitor and report their consumption, times and distances at all times and report the annual fuel oil consumption reports.

According to 2015/757 EN, Art. 11.3, the Emissions Report (ER) shall state the technical efficiency, i.e. EEDI or EIV.

If missing, this information must be entered in the DNV Fleet Status portal prior to submitting the ER, using the input field “Technical efficiency” available on the ER review page. Please enter the ship’s EEDI as given on the Energy Efficiency Certificate, or, in case the ship does not have an attained EEDI, the EIV (Estimated Index Value) should be given instead. The EIV shall be calculated according to MEPC.231(65). Data should also be available and consistent in THETIS-MRV.

The EIV for cruise passenger ships with non-conventional propulsion is calculated according to MEPC.233(65), and for all other vessels according to MEPC.231(65). The EEDI is calculated according to MEPC.308(73).

The requirements regarding the declaration of EIV or EEDI in the ER for a particular vessel are as follows: If an Energy Efficiency Certificate (EEC) has been issued on the vessel, the EEDI is stated on that EEC and shall be stated in the ER. In all other cases, the EIV needs to be stated, except for regarding:

• Passenger ships
• Cruise ships with conventional propulsion
• Ship category “Other” as defined in the MRV regulation
• Ships with non-conventional propulsion other than LNG carriers or cruise ships

If in doubt, please contact date@dnv.com.

Both the 2017 and 2024 editions of ISO 8217 may be used for fuel testing, with the fuel grade determined according to the version applied. Table 6 of the MRV Guidance Document 1 allows the identification of the fuel type based on the corresponding ISO 8217 standard version used. DNV accepts applying both versions for emissions reports until further notice. The procedure for verifying the fuel’s viscosity from the BDN, based on both ISO 8217:2024 and ISO 8217:2017 combined, applies as below:

• If the fuel’s viscosity is higher than 80 cSt, the LFO fuel type cannot be reported 
• If the fuel’s viscosity is lower than 20 cSt, the HFO fuel type cannot be reported

In case of any change to the monitoring plan, the company shall submit an updated plan to DNV for verification.

Monitoring plans can be amended in the MRV Monitoring Plan online form found on Veracity > Fleet Status > MRV & DCS > Monitoring Plans.

Preamble 22 of the the MRV regulation states that the new company should receive a copy of the latest monitoring plan and document of compliance, if applicable, from the old company. Hence, this is intended by the regulation, but the preamble is not enforceable in itself and this provision is apparently not repeated in the regulation itself.

Thus, the old company is in our opinion not required to hand over the approved monitoring plan to the new company according to the MRV regulation. It goes without saying that the respective sale and purchase contract might contain an obligation to deliver the ship with all necessary certificates (this is standard in all sale and purchase contracts) and therefore also the MRV monitoring plan. A potential buyer would want to check the monitoring plan in its due diligence before buying a ship and would also include this in the contract. 

The new company shall submit the new plan without undue delay, but no later than two months after the change of company.

Generally, emergency generator engines do not need to be regarded as an emission source as per the MRV regulation. Only main engines, auxiliary engines, gas turbines, boilers and inert gas generators are regarded as emission sources.

If the emergency generator engine is, however, used for operational purposes, it must be regarded as an auxiliary engine and, as such, has to be listed as an emission source in the monitoring plan. Its consumption shall be monitored, and its emissions be reported in the Emissions Report.The German AA (DEHSt) is currently the only authority that explicitly requires emergency generators to be included in the plans as auxiliary engines. Since they hold the final decision-making authority regarding plan approval, it is necessary to comply with these requirements.

In Veracity, under the EU MRV Monitoring Plans section, you will find a guidance document that outlines how to implement the recommendations of the German AA within your plans.

DNV recommends that the monitoring plan be updated using the online form application in Veracity, in order to obtain a new compliance document and to avoid issues with third parties (e.g. PSC).

The power to be stated in the monitoring plan is the figure stated on the IAPP certificate.

From 1 January 2024, the reporting period for the EU MRV Regulation is defined as from 1 January until 31 December of any given year. For voyages starting and ending in two different years, the respective data should be accounted under the year concerned

DNV requires that all voyages into, within and out of the EU shall be reported for MRV.  For our clients who have MRV and DCS with DNV, reporting of all voyages is required. 

No, the EU MRV regulation defines a voyage using departure-from-berth and arrival-at-berth. Therefore, the reporting of those exact events is required for every single voyage. Start of sea passage and end of sea passage may be reported additionally (if including consumption) but not instead.  

Both the log abstract and the bunker reports can be submitted as XLS or CSV files and according to the interface description. DNV no longer provides any updates or maintenance to the CSV file converter, as standard Excel spreadsheets can now be used as a format for data reporting. The current version of the interface description is available online under OVD Interface description at https://developer.veracity.com/docs/section/datastandards/operationalvesseldata.

The frequency of the updates is up to the user’s preference. Since DNV provides you with a quality check of the data as they come in, we recommend taking advantage of this by submitting the data on a frequent basis in order to fix any issues timely. 

No, for the verification of the emissions, we require all events including consumption and nothing more.

The current version of the interface description is available online under OVD Interface description at https://developer.veracity.com/docs/section/datastandards/operationalvesseldata 

Or through the Fleet Service portal: Vessel Services > MRV & DCS > Manage data > Operational Vessel Data standard (OVD) > OVD Interface description.

Each file can include single or multiple reports – this is up to the user’s preferences.

Yes, a second submission of the same events (identified with the exact same date, time and IMO number) will overwrite those previously submitted. 

Deletion of submitted records can be done at DNV Fleet Status > MRV & DCS > Manage data > Go to Manage data in OVD Admin – by selecting the vessel and the relevant period for deletion.

Alternatively, deletion of submitted records can be done by submitting another file with the same name (correct records shall be kept, and the ones to be deleted shall be omitted).

A system-to-system connection, using modern API technology and allowing fully automated data transfer, can be established anytime upon request – simply send a query to date@dnv.com.

Moreover, many third-party vendors of ship-to-shore reporting systems are already integrated with Veracity – see here for a list of Veracity integrated partners.

According to Section 8.3.1.6 of guidance document 1 (The EU ETS and MRV Maritime General guidance for shipping companies), the reporting of the fuel type should be according to the ISO 8217 standard (both the 2017 and 2024 editions of ISO 8217 may be used for fuel testing). The procedure for verifying a fuel’s viscosity from the BDN is based on both ISO 8217:2024 and ISO 8217:2017 combined:

• If the fuel’s viscosity is higher than 80 cSt, the LFO fuel type cannot be reported
• If the fuel’s viscosity is lower than 20 cSt, the HFO fuel type cannot be reported

If you have two fuels falling into the same grade by viscosity, those should be reported as the same fuel type for MRV, DCS and FuelEU Maritime.
For further details, please refer to the mentioned guidance and ISO.

The departure event, including the exact cargo, shall be reported when the cargo amount is reliably known.

The port in Korea is the departure port. Since cargo changed there, voyage starts there. The stops in China and Singapore don’t change the cargo so the emissions there count to the voyage. The port in the EU is the relevant arrival port determining the relevant voyage, since cargo will change there. The voyage ends in that EU port. The whole voyage from Korea to the EU is MRV relevant.

This is not a voyage, as it terminates in the same port with the same cargo amount. Thus, this is regarded as a port stay. Furthermore, it is important to note that the departure out to anchorage shall not be reported as the departure from berth, as this would indicate the start of a voyage, which it is not.

Anchoring events do not have to be reported, but the time at anchor elapsed since the last reported event has to be reported. There is no difference between inner and outer anchorage if coming from outside the port area as in this case. 

As per the MRV regulation, drifting and anchoring are two different things. Anchoring is to be reported as anchoring, and drifting is part of the voyage. 

In this scenario, the 30-minute trip is part of the voyage to port 2, which starts under point “b”. Going back to berth is just a stoppage in a harbour, i.e. “waiting at berth” without cargo operations, which does not constitue a relevant port call and is therefore not the end of a voyage.

• The event under point “b” shall be reported as a departure from berth.
• The time the ship is waiting at berth will be regarded as time at sea.
• The departure event under point “c” is not a departure from berth, as it is not the start of an MRV-relevant voyage.

One has to distinguish between all moorings and anchorings (including terminals which are floating, so not a “solid berth” as such, e.g. buoys, anchoring areas, etc.) within a port and outside a port, with a port being defined by the port limits.

If within port, there will be a UNLOCODE which ought to be used and the start and end events should be reported as arrival at berth and departure from berth.

If outside (e.g. outer Elbe anchorage at German Bight or oil platform in North Sea on Norwegian continental shelf, etc.) then there is no code, and the cargo operation is to be regarded and reported as ship-to-ship transfer, i.e. the end of the transfer operation is to be reported as an STS event (event name “STS”).

Any at-sea reports are voluntary, but in case of longer voyages which might be difficult to reproduce without noon reports, the reporting of daily reports such as noon reports can reduce the need for potential follow-up requests.

Generally, emergency generator engines do not need to be regarded an emission source as per the MRV. Only main engines, auxiliary engines, gas turbines, boilers and inert gas generators are regarded emission sources. If the EG engine is, however, used for operational purposes, it must be regarded an auxiliary engine and, as such, that engine has to be listed as an emission source in the monitoring plan (MP), its consumption be monitored and the emissions be reported in the ER.

Yes, but this is automatically done anyway when reporting the required events, arrival at berth and departure from berth.

No, it is voluntary, even for ice-classed vessels. We recommend not reporting those figures separately. Those figures shall, however, not be left out but shall be reported together with the non-ice navigation figures.

No, wind force declaration is voluntary.

Cargo change at a rig, FPSO, offshore field, etc. without UN/LOCODE is to be reported as an STS (event name “STS”).

Also, for a voyage on which STS takes place, the From field is the departure port, the To field the arrival port. The rig, FPSO or offshore field where the STS takes place is not a From/To location and shall not be entered in the From/To field.

Cargo fuel shall be included in the cargo field, i.e. as cargo transported, together with any other cargo.

In case you report the ROB’s fuel type style, please make sure to report 0t, i.e. please do not just leave the field blank.

In case you report the ROB’s fuel BDN style, please report the ROB in any event for every fuel reported to be consumed in this event. There is no need to report the ROB at the beginning of the year.

As per the EU regulation 2015/757, only main engines, auxiliary engines, gas turbines, boilers and inert gas generators are regarded emission sources. Based on the above, it is our understanding that as long as the excavator is not powered by the above-mentioned CO₂ emission sources, the excavator FOC does not need to be reported for the EU MRV.

Like reporting positive BDNs when bunkering bunker tanks, negative BDNs shall be reported when de-bunkering tanks, e.g. for use as cleaner.

Annex I of the MRV regulation does not include a default value for ethane. It is recommended to use as a default value the emissions factor in Resolution MEPC.364(79) EEDI Guidelines (Table 7 in the The EU ETS and MRV Maritime General guidance for shipping companies, document 1).

The sulphur content does not affect the fuel type for emissions reporting. Annex I of the MRV regulation segregates fossil fuel types by viscosity grades instead of sulphur content. 

According to Section 8.3.1.6 of guidance document 1 (The EU ETS and MRV Maritime General guidance for shipping companies), the reporting of the fuel type should be according to the ISO 8217 standard (both the 2017 and 2024 editions of ISO 8217 may be used for fuel testing). Please refer to Table 6 of the MRV guidance document 1, which allows the identification of the fuel type based on the corresponding ISO 8217 standard version used. 

Emissions factors to be used for biofuels are specified by the Commission Delegated Regulation (EU) 2023/2776, Annex I. In case of fuel blends, each blend component shall be considered separately. Please note that only under the EU ETS scheme, where the company uses a fuel complying with the sustainability criteria and GHG emissions-saving criteria for the use of biomass, the CO2 emissions factor of the biomass fraction of the fuel shall be zero. For OVD reporting requirements covering alternative fuels, please visit the OVD resources page.

Please be informed that DNV’s option for vessels with 300+ scheduled voyages per year to report in a way other than per-voyage has been phased-out. On average, the overall effort savings were not justifying the continuation of that approach. We hope that this decision finds your agreement, and we trust that our MRV verification service, which is optimized for the event reporting approach, will fully meet your needs for any of your vessels. 

THETIS-MRV is the EU MRV system to report CO2 emissions from ships according to the EU Regulation 2015/757. THETIS-MRV is accessible via: https://mrv.emsa.europa.eu/#public/eumrv.

EMSA provides information about their THETIS-MRV system, including video tutorials, on their website.

Yes, effective 1 January 2024, it is mandatory to upload the monitoring plan (MP) to the THETIS-MRV platform.
The procedure is as follows:

• The MP must be submitted to the verifier in THETIS-MRV.
• After submission of the MP, the verifier will assess the plan in THETIS and attach the Assessment Report.

Subsequently, the MP must be submitted to the administering authorities (AA) in THETIS for approval. The “Documentation” tab in THETIS will include the Assessment Report issued by the verifier. Any other relevant documentation should be made available to the AA (e.g. external procedures, risk assessment, document mandating the MRV/ETS responsibility, if applicable).

1. Apply for registration as a company user.
2. Enter MRV company details.
3. If necessary, add additional users under the same company account.
4. Define email notification as appropriate.
5. Request a partnership to a verifier.
6. Wait until the verifier accepts the request.
7. Add ships under the scope of the regulation.
8. Update missing mandatory ship particulars.
9. Generate the yearly Emissions Report at the end of the reporting period.
10. Generate the Company Emissions Report. 

A request for partnership has to be sent to DNV, and DNV has to confirm it for the company to be able to add/register ships under the company’s account in THETIS-MRV.

On the EMSA website a “Register Now” button is available to create an account.

For further information, we recommend visiting the EMSA website, with special attention to the video tutorial C01 covering the registration process.

By 30 April of each year, companies shall submit to the EU Commission and to the flag states the Emissions Report (ER), which has been verified as satisfactory by a verifier.

To ensure timely verification, we therefore recommend that companies submit the ERs for verification no later than 31 March.

From 2025, by 31 March of each year, companies shall, for each ship under their responsibility, submit to the administering authority responsible, to the authorities of the flag states concerned for ships flying the flag of a member state and to the Commission an emissions report for the entire reporting period of the previous year, which has been verified as satisfactory by a verifier in accordance with Article 13. The administering authority responsible may require companies to submit their ERs by a date earlier than 31 March, but not earlier than 28 February.

According to MEPC.215(63), the Vref should be the service speed as given in the IHSF database. The database can be found at: 

• https://maritime.ihs.com/Account2/Index
• https://www.imo.org/en/knowledgecentre/indexofimoresolutions/pages/mepc.aspx

Please understand that we cannot support companies with guidance on the processes in THETIS. We kindly ask you to familiarize yourself with the video tutorials on the EMSA homepage. Any questions not clarified by the EMSA video tutorials should be sent to EMSA directly.

No. According to FAQ 11 on the EMSA homepage: a ship that has not carried out any EEA-related voyages during a whole reporting period (calendar year) will not be required to submit a verified emissions report under the terms of Article 11 of the MRV regulation. The ship will not be required by member states’ authorities to have a Document of Compliance (DoC) on board as a proof of compliance for that specific reporting period, when calling at EEA ports between 30 June of the following year and 29 June of the year after.

Customers will be informed about the completion of the Emissions Report verification and the availability of the XML files for download by way of the respective status at Veracity > Fleet Status > MRV & DCS > Verification > MRV ER status.

According to Article 4 of the implementing regulation 2016/1927, the verifiers shall use the electronic version of the template available in THETIS-MRV when issuing the DoC. The electronic template does not require adding any signature other that the name of the verifier. The document available in THETIS should be considered valid by PSC.

Only the MRV Document of Compliance (DoC) on the annual Emissions Report must be on board. We also recommend that the MRV monitoring plan (MP) and the corresponding Assessment Report (AR) be kept on board.

The Emissions Report itself and the verification report (issued by the verifier or THETIS) do not need to be on board.

In order to change reports submitted to the Commission, the company must formally withdraw them by clicking the button “Revise report” on the top right of the THETIS window. Then the report can be amended. After amending, the report needs to be re-verified by the verifier. The verifier assesses the report and verifies it, makes a new Verification Report and issues a new DoC. Upon receipt of the Emissions Report from the verifier, the company can then re-submit it to the Commission.

This is covered by the functionality in THETIS; hence, there is no need for separate information to the flag administration. Flag administrations have access to THETIS and can also choose to receive alerts if considered necessary.

No, the DoC is issued stating the vessel name and flag at the end of the reporting period and does not need to be changed if those change.

DNV recommends that the greatest deadweight the ship is capable of carrying (corresponding to the greatest summer load line draft assigned to the vessel) is used as deadweight where applicable. The presence of multiple load line certificates should be noted as additional information where available.

Please refer to the table linked in the lower right corner of the following page: https://mrv.emsa.europa.eu/#public/emission-report.

According to Article 9(6b) of Commission Delegated Regulation (EU) 2019/1122, when none of the ship(s) under the responsibility of a shipping company have carried out activities within the ETS scope in a reporting year, an open MOHA should be set to the “Excluded” status. It is a responsibility of the national administrator in the Union Registry to grant a MOHA the “Excluded” status, upon instruction of the relevant administering authority. The administering authority may, if necessary, request the shipping company to provide a verified zero-company-level Emissions Report or other relevant evidence to ascertain whether relevant activities were carried out within the ETS scope. To facilitate the process, it is good practice for a shipping company to reach out to the relevant administering authority as soon as it becomes aware that it did not have any activities within the ETS scope in a reporting year before the annual deadline to report verified emissions (i.e. 31 March). Upon setting the MOHA status to “Excluded”, the shipping company will not be required to enter any emissions value in the MOHA for that reporting year. 

If the shipping company does not intend to perform voyages from/to EEA ports in the future, it can consider closing the MOHA. 

Source: https://climate.ec.europa.eu/eu-action/transport-decarbonisation/reducing-emissions-shipping-sector/faq-maritime-transport-eu-emissions-trading-system-ets_en#key-players.

We have received the following information from CLIMA-MRV-SHIPPING-HELPDESK@ec.europa.eu:

• Question: Is an Emissions Report (ER) required for the part of the year during which the vessel was still operated?
  • Answer: Yes, an ER is necessary in case the ship’s activities fell into the scope of the regulation. 
• Question: Who would have to submit the ER? Typically, vessels are handed over to the scrapping yard just before the last voyage into the scrapping facility.
  • Answer: The company in charge of the ship before the scrapping yard. 
• Question: When would the ER have to be submitted? During the year or at the beginning of the next year?
  • Answer: As soon as possible but before the applicable deadlines for ERs.

Regarding the allocation of the CO2 emissions from RoPax vessels to passenger and cargo transport, the correct approach is that the total CO2 emissions per period (incl. port emissions) must be split into passenger- and cargo-related transport. In other words, the sum of passenger- and cargo-related emissions would be the total CO2 emissions per period. This has been confirmed with EC, and this is what we apply.

Yes, from 2024 onwards, methane (CH4) emissions resulting from methane slippage must be included in the emissions report. The methane slip is calculated based on fuel consumption, engine type and the slippage coefficient per fuel type.