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MRV - Regulation

Which ships are in the scope of the EU MRV regulations?

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The EU MRV is applicable for ships >5,000 GT. Exempted are warships, naval auxiliaries, fish-catching or fish-processing ships, wooden ships of a primitive build, ships not propelled by mechanical means or government ships used for non-commercial purposes, ref. 2015/757 Art. 2.1 and 2.2. 

Furthermore, it is not applicable for ship movements and activities not serving the purpose of transporting cargo or passengers for commercial purposes, such as dredging, ice-breaking, pipe laying or offshore installation activities, ref. preamble (14) of Reg. 757. In particular, we know that NMA (Norway) deems offshore supply ships delivering people and cargo to offshore installations as not subject to the MRV regulation.

What is the definition of “cargo carried” for the different ship types?

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Passenger ship (“Passenger ship” means a ship that carries more than twelve passengers but not cargo.): No. of passengers (as defined in MRV Reg. 2016/757, Annex II, § A.1.[d]) 

Container ship (“Container ship” means a ship designed exclusively for the carriage of containers in holds and on deck.): Mass (as defined in MRV Reg. 2016/757, Annex II, § A.1.[f]) 

Oil tanker (“Oil tanker” means a ship constructed or adapted primarily to carry oil in bulk in its cargo spaces. Note that this definition does not include combination carriers, NLS tankers or gas tankers.): Mass

Chemical tanker (“Chemical tanker” means a ship constructed or adapted for the carriage in bulk of any liquid product listed in chapter 17 of the International Bulk Chemical Code (a chemical tanker) or a ship constructed or adapted to carry a cargo of noxious liquid substances in bulk (an NLS tanker).): Mass

LNG carrier (“LNG carrier” means a tanker for the bulk carriage of liquefied natural gas (LNG) (primarily methane) in independently insulated tanks. Liquefaction is achieved at temperatures down to -163°C.): Volume (and its aggregation of part loads)

Gas carrier (“Gas carrier” means a tanker for the bulk carriage of liquefied gases other than LNG.): Mass

Bulk carrier (“Bulk carrier” means a ship which is intended primarily to carry dry cargo in bulk, including such types as ore carriers as defined in SOLAS chapter XII, regulation 1, but excluding combin-ation carriers.): Mass

Combination carrier (“Combination carrier” means a ship designed to load 100% dead weight with both liquid and dry cargo in bulk.): Mass

General cargo ship (“General cargo ship” means a ship with a multi-deck or single-deck hull designed primarily for the carriage of general cargo.): DWT carried (as defined in MRV implementing act, without fuel on board)

Refrigerated cargo ship (“Refrigerated cargo carrier” means a ship designed exclusively for the carriage of refrigerated cargoes in holds.): Mass

Vehicle carrier (“Vehicle carrier” means a multi-deck, roll-on roll-off cargo ship designed for the carriage of empty cars and trucks.): Mass (actual mass or as units occupied multiplied by default values for their weight)

Ro-ro ship (“Ro-ro ship” means a ship designed for the carriage of roll-on roll-off cargo transportation units or with roll-on roll-off cargo spaces.): In essence: Mass no. of cargo units (trucks, cars, etc.) or lane-metres multiplied by default values for their weight (Annex B, EN 16258 [2012])

Ro-pax ship (“Ro-pax ship” means a passenger ship with roll-on roll-off cargo space.): 1. No. of passengers and 2. Mass

Container / ro-ro cargo ship (“Container/ro-ro cargo ship” means a hybrid of a container ship and a ro-ro cargo ship in independent sections.): Volume (occupied deck area multiplied by deck height and added by container volume)

Other ship types (“Other ship types” mean ships not covered by any of the above definitions which fall under the scope of the regulation.): Mass or, DWT carried

Does the EU MRV also cover CO2 emissions from a ship in port or at berth?

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Yes, COemissions in EU ports, including emissions arising from ships at berth or moving within a port.

Is a port stay for bunkering considered a port call for EU-MRV?

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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 and stops for the sole purpose of taking shelter from adverse weather or rendered necessary by search and rescue activities are excluded.

What is an EU port under the jurisdiction of a member state of EU-MRV?

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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 and stops for the sole purpose of taking shelter from adverse weather or rendered necessary by search and rescue activities are excluded.

What is an EU port under the jurisdiction of a member state of EU-MRV?

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

 
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, Svalbard.

Source: European Commission "Reducing emission from the shipping sector"

Are we required to monitor each voyage or can we monitor annually?

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All relevant data need to be monitored on a voyage basis and then aggregated annually. An exemption is applied to vessels which conduct more than 300 voyages per year and all voyages during this year either start from or end at an EU port. These vessels are excluded from reporting on a per-voyage basis and only have to record and report annual data sets.

What happens if my ship changes class or flag?

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

Is the EU MRV verification related to class?

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

What if a ship calls an EU port without an approved monitoring plan?

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The company shall submit a Monitoring Plan to the verifier (DNV GL) 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.

Who is responsible for EU MRV compliance?

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The company (i.e. ship operator) is responsible for EU MRV compliance.

When a ship changes company (i.e. ship operator) through the year, how is this handled?

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Where there is a change of company for a ship, the new company shall ensure that the ship under its responsibility complies with the requirements of MRV in relation to the entire reporting period during which it takes responsibility for the ship concerned. “Reporting periods” as per MRV are the calendar years. In other words, if the operator takes over the responsibility during a calendar year, he is responsible for the reporting for that calendar year. We recommend that operators taking over vessels during a reporting period check and consider for the purchase how the previous owner has monitored and documented the relevant parameters for reporting Article the emissions during “his” part of the reporting period, ref. 2015-757, Art. 11.2.

MRV - Digital reporting to DNV GL

What is the last event of the old reporting period and what the first event of the new period? How should voyages and port stays extending over the turn of the year be regarded?

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Referring to EU Directive 2015/757 Article 3(m): ‘reporting period’ means one calendar year during which CO2 emissions have to be monitored and reported. For voyages starting and ending in two different calendar years, the monitoring and reporting data shall be accounted under the first calendar year concerned. However, the regulation does not mention the case where a port stay extends over two reporting periods. Therefore the port stay should be cut at the end of a reporting period and the rest of the port stay should be reporting in the next reporting period.

How do vessels not currently on EU-trade have to report their voyages (events) to DNV GL as MRV verifier?

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In case of vessels currently not on EU-trade and entering into an EU trade only at some point later during the reporting period, those vessels need to start reporting to us only with their first MRV-relevant voyage.

Do we have to report voyage data for the whole year or for the EUR relevant voyages only?

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DNV GL require only that voyages in, within and out of EU shall be reported for MRV, but we strongly recommend reporting all voyages. Our system will recognize which voyage are in scope for MRV based on port codes.

This will result in either one year-long reporting period or in several reporting sub-periods throughout the year. Please note that we as verifier require the receipt of all BDN’s during the reporting period(s) and the ROB’s start and end of the reporting period(s).

What types of events shall be reported?

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Voyage events and bunker events.

Which voyage events shall we report?

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Voyage events shall include departure from berth and arrival at berth, following the MRV definition of voyages. In addition, any other events included in the company’s reporting scheme which include consumption shall be reported to obtain a reporting gapless with respect to consumption.

Can we report “start of seapassage” and “end of sea passage” instead of “departure from berth” and “arrival at berth”?

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No, the EU MRV Regulation defines voyage using departure-from-berth and arrival-at-berth, therefore reporting of those exact events is required for every single voyage. SoSP and EoSP may be reported additionally (if including consumption) but not instead.

What is the correct format used for reports submission?

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Both log abstract and bunker reports, as well as ROBs, shall be submitted as csv files and according to the interface description.

How often is it needed to upload the files – daily, weekly, monthly?

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The frequency of the updates is up to the user’s preference. Since DNV GL will provide 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.

In our normal ship-to-shore reporting we are including also events without consumptions. Shall we report those events without consumptions?

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No, for the verification of the emissions we require all events including consumptions and no more.

Where can we find the current version of the MRV interfaces description?

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The current version of the interface description is available online in the DNV GL Fleet Status portal > MRV&DCS tab > Manage data tab > templates

Shall we submit one file per event or multiple reports shall be included in a single file?

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Each file can include single event report, as well as multiple reports – this is up to the user’s preferences.

Is it possible to include reports for several vessels in one csv file?

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Yes, single file can include events reported for several different vessels. Service providers shall make sure that they include vessels only for one MRV customer (vessel manager) in the same file.

Is it possible to modify data after they have been submitted?

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

How can we delete submitted report?

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Deletion of submitted records can be done in DNV GL Fleet Status portal > MRV&DCS tab > Manage data tab by selecting the vessel and the relevant period for deletion. Alternatively, deletion of submitted records can be done via submission of another file with the same name (correct records shall be kept, ones to be deleted shall be omitted).

What is the procedure for manual upload of the csv-report files

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The manual upload field is available on DNV GL Fleet Status portal > MRV&DCS tab > Manage data. There are checks upon upload, so in case of e.g. formatting issues, you get an error notification indicating what needs to be corrected.

How can establish the system-to-system connection between our reporting system and DNV GL?

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System-to-system connection, allowing fully automated data transfer, can be established anytime, if requested: Please send a query to interface.mrv@dnvgl.com. We will provide you with a storage container on the Veracity platform. The storage container is accessible via unique key (SAS token). In order to access the storage container, the Azure Storage Explorer is needed. The automated data transfer can be done programmatically or using the AzCopy. Further information on the upload possibilities can be found at the following website: https://developer.veracity.com/doc/data-fabric-ingest.

I have two fuel types (HFO and LSFO) with the same emission factor. How can I report this through your interface?

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The reporting of the fuel type should be according to the ISO 8217 grade:
Grades RME through RMK, Emission factor 3,114: HFO
Grades RMA through RMD, Emission factor 3,151: LFO
Grades DMX through DMB, Emission factor 3.206: MGO

If you have two fuel types falling into the same range of grades, those should be combined into one fuel type reported.

Upon departure from berth, the exact cargo may not be known (bill of lading not received). When shall we report the cargo?

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

What is Thetis-MRV?

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Thetis-MRV is the EU-MRV system to report CO2 emissions form ships according to the EU Regulation 2015/757. Thetis-MRV is accessible through this link.

Where can companies find detailed information about Thetis-MRV?

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EMSA have provided information about their Thetis-MRV system including video-tutorials on their website.

Is it needed to upload the Monitoring Plan to THETIS?

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No, there is no need to upload the Monitoring Plan and the status of the MP doesn't need to be updated inside THETIS. This is part of the voluntary module in Thetis-MRV. Approval of Monitoring Plans can be handled complety outside of THETIS and that is what DNV GL is applying. Please note that the MP's submitted to DNV GL will not appear in Thetis and that is not an issue, even it the note in Thetis may appear like that ("Monitoring Plan for x is not created"). Please further note that the figures from the monitoring plans submitted to DNV GL and needed for the ER's will be provided in the xml-files available on the DNV GL Fleet Status portal.

What do companies need do within THETIS-MRV?

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1. Apply for a 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 deemed appropriate
5. Request a partnership to a Verifier
6. Wait that 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

Why do I need to request partnership with DNV GL within THETIS-MRV?

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

Do I need to register as owner within THETIS-MRV? Where can I apply for registration?

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The system homepage can be found at https://mrv.emsa.europa.eu where a "Register Now" button is available to create an account. To better understand this process, we recommend the content available in http://www.emsa.europa.eu/thetis-mrv-videos/thetis-mrv-companies.html, with special attention to the video tutorial C01 covering the registration process.

What is the deadline for the shipping companies to upload the ER to Thetis? Is this end of January?

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By 30 April of each year, companies shall submit to the EU Commission and to the Flag States the Emissions Report, which has been verified as satisfactory by a verifier.

This means that for DNV GL as the verifier to be able to verify the Emissions Reports, those reports shall be created in Thetis as soon as possible after the last voyage of the reporting period but not later than by 31 January of each year.

Can the letter of protest against the publication of ER-data by the EU be uploaded to Thetis by DNV GL?

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This letter can be uploaded as pdf file as additional information to the Emissions Report which the company has to upload to Thetis. The upload of the letter as additional information to the ER can only be done by the company in way of the upload of the ER. DNV GL will not consider the mentioned letter of protest in any way.

What is the Vref for calculation of the EIV for the emissions report, ref. 2016/1927 Annex II, Part A, §6.b)?

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According MEPC.215(63), the Vref should be the service speed as given in the IHSF database. The database can be found under https://maritime.ihs.com/Account2/Index. Please be informed that DNV GL we will provide the EIV calculation in the xml-file download for parts A-D of the ER after the reporting period, calculated based on the data in the IHS database. The client will be asked to review and confirm this value. If clients want to access the IHSF database themselves, they would have to register to get access to it.

By when do companies have to submit the satisfactorily verified ER to the commission?

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By 30 April each year the ER for the previous year, verified as satisfactory, has to be submitted to the commission by the company, ref. 2015/757 Art. 11.1

How does the preparation and verification of the annual EU-MRV Emissions Reports work with DNV GL and EMSA's Thetis-MRV?

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DNV GL will provide companies with xml-files covering all 4 parts A to D of the Emissions Reports. These files will be provided for download from the DNV GL class portal. The XML-files will be formatted according to the specification by EMSA/Thetis.

Process for provision of the xml-files and for verification of the ER:
1. Company – Prepare and submit data (log abstracts and bunker reports)
a. Completes the digital voyage reporting of log-abstract and bunker data for 2018 and makes sure that the reporting is free from issues, i.e. no issues are displayed in the data quality tab for the vessel.
b. From 25 January, a new verification status tab will be available under the MRV tab in the DNV GL Fleet Status portal. This will also give an indication if the data is free from issues and if it is ready for review (see step 3b). 

2. DNV GL – Pre-verification
a. Checks the voyage reporting and communicates with the company until the data are complete and consistent.
b. When the data is free from issues DNV GL provides the ER data for review by the company under the MRV tab in the DNV GL Fleet Status portal.

3. Company – Review and submit ER for verification
a. From 8 February, the ER data will be available for review in the DNV GL Fleet Status portal, given that the submitted data is free from issues (see steps 1 and 2).
b. Reviews the ER and includes any data required for the ER which have so far not been reported to DNV GL*.
c. Submits the ER for verification through the DNV GL Fleet Status portal by 28 February. 

4. DNV GL - Verification
a. Verifies the ER and communicates with the Company for correction or commenting on any issues.
b. When the ER is verified as satisfactory, provides the xml-files for download. The customer will be informed about the verification status. 

5. Company - Downloads xml-files for the ER from the Fleet Portal and uploads to Thetis
a. Downloads the xml-files for the ER from the Fleet Portal, confirming that they will upload the same files to Thetis.
b. Uploads the xml-files to Thetis and submits the ER (The details of that process can be found in the EMSA guidance videos).

6. DNV GL
a. Marks the ER as verified in Thetis.
b. Issues the DoC. 

7. Company
a. Submits the ER to the Commission via Thetis.
b. Downloads the DoC from Thetis and provides it on board the vessel by 30 April. 

* We will calculate all required figures for the ER (transport work, emissions, etc.), if we have the required data from the voyage reporting or from the Monitoring Plans. What we mean here, are figures such as e.g. the split ratio for cargo and passenger emissions for RoPax vessels. 

This process and service are also applicable for vessels reporting using 3rd party reporting systems including DNV GL's Navigator Insight.

How does the upload of emissions reports to Thetis-MRV work?

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For upload of emissions reports, two XML files are required; the “Emission reports” file and the “Emissions” file. These files can contain data for a maximum of 25 ships. If reporting for more than 25 ships, additional XML-files are required. Uploading of the xml-files to Thetis needs to be done by the customer according to the process to be explained by EMSA in the a.m. guidance videos. Generally, all Thetis-MRV process steps are well explained in the video tutorials on the EMSA homepage. To our knowledge there is, however, not yet a video tutorial on this available on the EMSA homepage (status 2018-12-04), but it can be expected that the process will be analogue to the process of xml-file uploads for monitoring plans as explained in tutorial C16 at 1’35.

Can DNV GL support us with information on Thetis processes?

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Please understand that we cannot support you 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.

Our vessel has not performed any EU-MRV related voyages (either not called ports in the EU or not engaged in transport, e.g. offshore operations). Do we have to submit an ER with zero emissions and obtain and DoC for that ER?

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No. 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.

MRV compliance

What happens if my ship changes class or flag?

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

Is the EU MRV verification related to class?

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

What is the process if a ship operator decides to call at an EU port for the first time after 31 August 2017?

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

What should/could I do now to prepare for the IMO DCS (and not only the EU MRV)?

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As the details on the IMO DCS scheme are still pending, it is difficult to present a clear picture. We expect the the amendment of the SEEMP, which will then also require approval by the flag state or a recognized organization, requires some effort, but does not come along with major difficulties. But certainly we recommend our customers to take a look at the IMO DCS requirements as drafted per today when choosing and implementing a monitoring and reporting solution. This will help to make sure that the required data are already captured. DNV GL will inform its customers once further information on the IMO DCS is available.

Who is responsible for EU MRV compliance?

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The company is responsible for EU MRV reporting and is defined as follows: “Company” means the ship owner or any other organization or person, such as the manager or the bareboat charterer, which has assumed responsibility for the operation of the ship from the ship owner. So, in most cases, it will be the DoC holder.

When a ship changes company (owner/manager) through the year (as the ship is monitoring its emission) – how is this handled?

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Where there is a change of company, the new company shall ensure that each ship under its responsibility complies with the requirements of the MRV in relation to the entire reporting period during which it takes responsibility for the ship concerned.

Which companies are accredited for EU MRV verification?

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DNV GL is – together with a handful of other companies - accredited to verify compliance of monitoring plans and emission reports towards the EU Monitoring, Reporting and Verification regulation.

If a ship is calling at an EU port for dry docking or repair only, is this voyage MRV-relevant?

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No, 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 and stops for the sole purpose of taking shelter from adverse weather or rendered necessary by search and rescue activities are excluded.

DNV GL support

Whom to contact in case of questions to DNV GL?

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In order to receive the fastest response, clients should approach THD/DATE in case of questions. The THD-support team will be supported by further experts if required.

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