New statutory requirements entered into force on 1 January 2023. From this date, it is mandatory for all ships to calculate their attained Energy Efficiency Existing Ship Index (EEXI), to measure their energy efficiency, and to start collecting data to report their annual operational Carbon Intensity Indicator (CII) and CII rating. This statutory news summarizes the two regulations.
Relevant for ship owners and managers.
Energy Efficiency Existing Ship Index (EEXI)
EEXI compliance shall be verified and documented at the first periodical IAPP survey completed on or after 1 January 2023 for vessels obliged to comply with the EEXI requirements. Two key parts must be taken into consideration and will require follow-up action, as appropriate:
a) Statutory scope, where DNV acts on behalf of the flag state administration:
- Verification of Attained EEXI is less than Required EEXI
- Approval of Technical File
- Approval of Onboard Management Manual (OMM) – when measures involve engine power limitation (EPL) or shaft power limitation (SHAPOLI)
- Verification of implementation of measures by DNV surveyor
b) Class scope according to DNV Rules for Classification of Ships to accept alterations if any have been carried out (EPL, energy efficiency devices, etc.):
- Approval where required
- Verification and testing of the installation by DNV surveyor
Upon satisfactory verification of the applicable statutory and class scope by the surveyor, a new IEEC will be issued for the respective vessels. Please note that the verification of the SEEMP kept on board is also a pre-requisite for issuance of the new IEEC.
It is of utmost importance that the EEXI Technical File and OMM are approved, and the mitigating actions/alterations have been carried out at the latest by the time of the first periodical survey for the IAPP Certificate, on or after 1 January 2023. In all cases of non-compliance, DNV (acting on-behalf of flag state administrations) and ship owners/managers must seek advice from the administration concerning the issuance of an IEEC. In the worst case, the vessel might be faced with a Condition of Authority.
The figure below illustrates the process and timelines for statutory and class-related activities to comply with the EEXI requirements.
Ship Energy Efficiency Management Plan (SEEMP) and CII
The SEEMP now consists of three parts:
- Part I: Ship management plan to improve energy efficiency
- Part II: Ship fuel oil consumption data collection plan
- Part III: Ship operational carbon intensity plan
The newest addition, SEEMP Part III is a mandatory, ship-specific document that describes the plan to improve the vessel’s CII rating, and hence its operational energy efficiency, for the next three years. Initial revision of SEEMP Part III must be verified and kept on board the respective vessel from 1 January 2023, together with the corresponding Confirmation of Compliance (CoC).
In My Services on Veracity, DNV provides a free online service to generate the SEEMP Part III under “Vessel Services” and “Manuals & Plans”.
An attained CII will be calculated for the first time for any applicable vessel starting from 2024 based on DCS data for the 2023 reporting period.
DNV recommends its customers to urgently check the status of the approval of the relevant documents (EEXI Technical File, OMM, SEEMP Part III, class-related documentation) before the first scheduled IAPP survey takes place in 2023. In particular the approval and survey of potential mitigating actions, like EPL/ShaPoLi which needs to be finalised at the latest by the time of the first periodical IAPP survey in 2023.
For vessels with an already verified SEEMP Part III, customers are obliged to implement planned energy efficiency measures on their vessels accordingly. DNV strongly recommends starting the process of self-evaluation and improvement of vessels’ CII from the beginning of the 2023 DCS reporting period.
DNV already provides access to a wide range of information on GHG regulations, including EEXI, and SEEMP III, for example through the following sources:
- EEXI topic page
- SEEMP Part III topic page
- CII - Carbon Intensity Indicator topic page
- Emissions Insights – monitoring of preliminary CII Rating
- DNV’s decarbonize shipping information hub
- Technical and Regulatory News including various GHG topics
- DNV Compliance Planner available for customers via My Services on Veracity, which helps to stay ahead of the regulatory requirements