Now with the second DCS reporting year recently ended, it is again time for reporting data on fuel oil consumption to your DCS verifier. To ensure a Statement of Compliance (SoC) is issued in due time before 31 May 2021 as required, the deadline in MARPOL for reporting 2020 data for verification is 31 March 2021. This statutory news is a reminder on how to stay compliant with regulation 22A of MARPOL Annex VI.
Relevant for ship owners and managers as well as flag states.
Be ahead of the deadline
Regulation 22A of MARPOL Annex VI requires ships to collect and report data on their fuel consumption following a yearly cycle. Compliance is evident through the SoC issued annually on behalf of the flag, confirming that the required data for the previous year was submitted in accordance with the methodology and process in the ship’s SEEMP. Flag administrations are important stakeholders in this process too. They have an obligation towards the IMO to ensure their ships comply. Hence, not having a valid SoC may not only be an issue with PSC, but also directly with the flag administration.
For ships to which this regulation applies, it is important that a valid SoC is readily available on board for inspection, together with the Confirmation of Compliance (CoC) for the SEEMP Part II. The CoC (SEEMP Part II) and the validity of the SoC (DCS) will be checked at each periodical statutory survey regardless of whether the DCS verifier having issued the SoC is the flag administration, class (Recognized Organization), or any other verifier approved by the flag administration.
In other words, if DNV GL is your verifier, you need to submit your 2020 data to us as soon as possible, at the latest on 31 March 2021, to ensure that an SoC is issued on time before 31 May 2021 as required.
The DCS data is yours – use them smartly
The DCS data submitted document the status and progress of your ship’s and fleet’s GHG emission performance towards meeting the IMO emissions targets. The DCS data is also of interest to other stakeholders for reporting and benchmarking, for instance, charterers, financial institutions, and ESG (Environment Social Governance) reporting.
When choosing DNV GL as a DCS verifier, you will also gain access to your data in our Emissions Insights dashboard available in My Services on our Veracity data platform. Emissions Insights is a monitoring tool and a smart solution for your environmental emissions management, providing easy data sharing, monitoring, benchmarking, and suggestions for improvement of individual ships and on a fleet level.
EU MRV reporting to THETIS
Equally important and not to be forgotten is the EU MRV reporting, in addition to the DCS reporting for vessels calling at EU ports. By 30 April 2021, companies need to submit the verified MRV Emissions Report to the EU Commission (THETIS). To ensure timely verification, companies should submit their MRV Emissions Reports for verification no later than 31 March 2021.
Early submission of DCS data is required, by 31 March 2021 at the latest. If there are any outstanding issues for any reason concerning the data reporting for 2020, or other reasons to believe that the SoC will not be issued before the deadline, we encourage ship owners/managers to contact their DCS verifier to avoid becoming non-compliant on 1 June 2021.