Shipowners have to document fuel consumption of their ships

Maritime shipping too has to become (even) more environmentally friendly. Therefore, since the beginning of 2018, the EU prescribes that the shipowners have to trace the emissions of their ships. This requirement of the so called MRV Regulation are now supplemented with new rules by the International Maritime Organisation IMO. We explain the differences between the two systems.

The Regulation (EU) 2015/757 on the monitoring of carbon dioxide emissions from maritime transport applies since 2018. This regulation is better known under its abbreviation MRV which stands for monitoring, reporting and verification. Now the IMO has added another system: the Data Collection System (in short: DCS). In this system the fuel consumption of maritime ships is established.

Both procedures resemble one another and shipowners can use some of the collected data for both systems. But there are also differences. For example, in Germany different authorities monitor the compliance of the requirements.

We have compiled the most important differences for you in the following table. Below the table, you will find more detailed information about the two procedures.

Procedure: EU MRV Regulation IMO DCS (Data Collection System)
Monitoring of: carbon dioxide emissions IMO DCS (Data Collection System)
Application: from 5000 GT
commercial voyages to or from a port or between ports in the European Community
from 5000 GT
international voyages
(large fishing vessels and offshore jack-up vessels are also included)
Implementation with: verification of a monitoring concept by an accredited verifier with the SEEMP (Ship Energy Efficiency Management Plan), incl. part II, verified by a recognised classification society → survey report or Confirmation of Compliance to Ship Safety Division for approval (until 31. December 2018)
Start of data collection: since 1. January 2018 from 1. January 2019
Data submission: Emission report to Deutsche Emissionshandelsstelle (at the Federal Ministry for the Environment) until 30. April the following year to Ship Safety Division until 1. April the following year;
entry of the data into the IMO database by Ship Safety Division or commissioned class
First submission until: 30. April 2019 1. April 2020
Further information: ISM Circular 01/2018 ISM Circular 05/2018


EU MRV Regulation (carbon dioxide emissions)

The maritime transport regulation EU MRV ((EU) 2015/757) is applicable for ships of 5000 GT and above which conduct commercial voyages to or from a port or between ports in the European Community. The EU Regulation stipulates monitoring of carbon dioxide emissions from maritime traffic with a monitoring concept verified by an accredited verifier.

Annually, an emission report for the ship, based on the collected data and positively assessed by an accredited verifier with a Document of Compliance, is reported to the Deutsche Emissionshandelsstelle until 30. April of the following year. This Emissionshandelsstelle is part of the Federal Ministry for the Environment. The Document of Compliance is to be carried on board the ship.

Emissions have to be collected since 1. January 2018. The first Emission report is due on 30. April 2019.

Further information is given in our ISM Circular 01/2018.

IMO Data Collection System (fuel consumption)

The IMO has approved a system to record data about fuel oil consumption of ships (DCS) for ships on international voyages with 5000 GT an above and has included this in the MARPOL Convention Annex VI. For the implementation, the SEEMP (Ship Energy Efficiency Management Plan) has been extended with a part II: the ship fuel oil consumption data collection plan.

For sea-going ships under German flag, the shipowner submits the SEEMP with the supplemented part II to a recognised classification society for verification. The class submits their Survey Report or the Confirmation of Compliance - Ship Fuel Oil Consumption Data Collection Plan to the Ship Safety Division of the BG Verkehr for approval which issues the relevant confirmation for the ship. The approval by the Ship Safety Division has to occur until 31. December 2018.

The shipping company submits the collected data to the ship safety Division until 1. April of the following year. The first submission is due on 1. April 2020.

The collected data on the fuel oil consumption are entered annually into the IMO database of fuel oil consumption of ships by the Ship Safety Division or the commissioned class. For each ship under German flag, the Ship Safety Division issues a Statement of Compliance - Fuel Oil Consumption Reporting to confirm the proper submission of the annual consumption report to the IMO.

Further information and details about the required data and the various measuring methods are given in the ISM Circular 05/2018.