The EU MRV is applicable for ships above 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 and 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  of Reg. 757). For further information, please refer to the second answer on the EMSA homepage.
Please note: NMA (Norway) deems offshore supply ships delivering people and cargo to offshore installations as not subject to the MRV regulation.
Yes, the EU MRV also covers CO2 emissions in EU ports, including emissions arising from ships at berth or ships moving within a port.
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 and 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, Madeira, Canarias, Guadeloupe, French Guyana, Martinique, Mayotte, Saint Martin and Reunion), and also 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: 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.
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.
The EU MRV is neither class nor flag related, so this will have no effect on the EU MRV reporting.
No, DNV GL can also perform the verification for ships not classed with DNV GL.
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.
The company (i.e. ship operator) is responsible for EU MRV compliance.
If a ship changes company, the new company shall ensure that the ship under its responsibility complies with the requirements of the EU MRV in relation to the entire reporting period during which it takes responsibility for the ship concerned (ref. 2015-757, Art. 11.2).
“Reporting periods” as per the EU 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 entire 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 the emissions during “his” part of the reporting period.
No, DNV GL as verifier only verifies submitted data and issues a DoC based on that report. DNV GL is in no position to confirm that a vessel has not been compliant within the scope of EU MRV during previous years, without verification.
No, according to the second answer on the EMSA homepage, movements related to the installation of wind turbines offshore or to carriage of supplies to wind turbines are subject to the EU MRV.
According to 2015/757 EN, Art. 11.3, the emissions report shall state the technical efficiency, i.e. EEDI/EIV.
If missing, this information must be entered in the DNV GL fleet status portal prior to submitting the emission report, 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 should be calculated according to MEPC.231(65). Data should also be available and consistent in THETIS
The EIV for cruise passenger ships with non-conventional propulsion is calculated according to MEPC.233(65), for all other vessels according to MEPC.231(65). 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
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In case of any change to the monitoring plan, the company shall submit an updated plan to DNV GL, either for verification or to inform DNV GL about the change.
Monitoring plans can be very efficiently amended in the plan generator app in Veracity / Fleet Status / MRV & DCS / Overview.
Verified plans submitted in the DNV GL plan generator app after 11 February 2019 can be accessed via the document link beside the Approved status in Veracity / Fleet Status / MRV & DCS / Overview.
If the plan was submitted using the app before 11 February 2019, companies can access the plan via the preview function, dialogue "Create Monitoring Plan".
Generally, and in particular for plans created manually, i.e. not using the app, companies should be in possession of the monitoring plan they have submitted to DNV GL for verification. Upon satisfactory verification of the plan, DNV GL issues the respective statement of compliance (SoC). In the email with which DNV GL sends the SoC, we recommend that the SoC and the plan are onboarded.
If the monitoring plan (MP) can remain the same, i.e. if only the declaration of the company is changing in the MP, then yes. Otherwise the MP has to be sent to DNV GL for verification and a new one will be issued.
The MRV regulation does not state that the new company can be held responsible for this. DNV GL's understanding is that after change of company, the new company shall submit the MP without undue delay but no later than two months.
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.
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 as emission sources. If the EG engine is, however, used for operational purposes, the EG engine must be regarded as an auxiliary engine and, as such, that engine has to be listed as an emission source in the MP, its consumption be monitored and its emissions be reported in the ER.
As per the regulation, the EEDI/EIV is not a mandatory figure for the MP. We do, however, require this figure for the generation of the monitoring plan, to facilitate the ER review, and for submission during the busy ER preparation and verification phase from January to April.
Voyages or port stays spanning over the turn of the year belong to the old reporting period. The first arrival or departure (at or from a port of call) in the new year marks the end of the old and the beginning of the new reporting period. Please note that ROBs shall be reported for the first arrival or the first departure in the new year (ref. EU Directive 2015/757 Article 3[m]), which DNV GL also applies to port stays.
In cases where a voyage or a port stay started in the old year and still continues after 28 February in the new year, the company shall contact DNV GL. Those cases will be handled on a case-by-case basis.
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.
DNV GL requires that voyages into, within and out of the EU shall be reported for MRV. But DNV GL strongly recommends reporting all voyages. For our clients who have MRV and DCS with us, reporting of all voyages is required anyway.
Reporting for the EU-relevant voyages only might result in several reporting blocks during the reporting period. In such a case, companies shall submit all bunker reports during the blocks and the ROBs at the start and at the end of the blocks.
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.
The manual upload field is available on DNV GL Fleet Status portal > MRV & DCS > Manage data.
There are checks upon upload, so in case of formatting issues, for instance, you get an error notification indicating what needs to be corrected.
Both the log abstract and the bunker reports shall be submitted as .csv files and according to the interface description.
The frequency of the updates is up to the user’s preference. Since DNV GL 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 at DNV GL Fleet Status > MRV & DCS > Manage data > Available templates.
Each file can include single event report, as well as multiple reports – this is up to the user’s preferences.
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.
Yes, a second submission of the same events (identified with exactly the same date, time and IMO number) will overwrite those previously submitted.
Please view the guidance video on this topic here.
Deletion of submitted records can be done at DNV GL Fleet Status > MRV & DCS > Manage data 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).
System-to-system connection, allowing fully automated data transfer, can be established anytime, if requested by sending a query to firstname.lastname@example.org. We will then provide you with a storage container on the Veracity platform.
The storage container is accessible via a unique key (SAS token). In order to access the storage container, 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
The reporting of the fuel type should be according to the ISO 8217 grade:
If you have two fuel types falling into the same range of grades, those should be combined into one fuel type reported.
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 no voyage, since it terminates in the same port. Thus, this is regarded a port stay. The anchoring time shall therefore not be reported. Furthermore, it is important to note that the departure out to anchorage shall not be reported as departure from berth, as this would indicate the start of a voyage, which it isn't.
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, drifting and anchoring are two different things. Anchoring is to be reported as anchoring, drifting is part of the voyage.
In this scenario, the 30-minute trip is part of the voyage to port 2, which is starting in b. Going back to berth is just a stoppage in a harbour, “waiting at berth” without cargo operations and therefore not a relevant port call and thus not the end of a voyage.
As per Article 9 of the MRV regulation 2015-757, ships are exempted from per-voyage monitoring if scheduled to perform more than 300 voyages per year.
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”).
In general, any fuel with a different name but the same emission factor as one of the standard fuels, as per the MRV regulation, should be reported under the corresponding standard fuel. With reference to the EU MRV “Guidance/Best practices document on monitoring and reporting of fuel consumption, CO2 emissions and other relevant parameters pursuant to Regulation 2015/757 on monitoring, reporting and verification emissions from maritime transport”, please note paragraph 5.1.6 advising that the emissions factor to be applied for “hybrid fuels” within RMA to RMD grades is the same as for light fuel oil and the fuel should be reported as LFO. Hybrid fuels with viscosity above the range indicated for the RMA to RMD grades, i.e. from 80 cSt, should be considered RME or higher grade fuel and reported as HFO.
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.
According to the second answer on the EMSA homepage, carriage of supplies and equipment to/from offshore installations and ships is not subject to the MRV.
It goes without saying that, according to the main MRV regulation, cargo transport between ports, however, needs to be reported.
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.
Please make sure to report 0t, i.e. please don’t just leave the field blank.
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.
The Cf for ethane is 2.931, using the same calculation method as for methane according to the MEPC 59/4/10.
The reporting of the fuel type should be according to the ISO 8217 grade, merely viscosity being decisive:
The emissions from the combustion of 0.5% VLSFOs, which, depending on the stock of the bunker supplier, may be of residual (HFOs/LFOs) or distillate (MDO/MGO) type, may be monitored as follows:
After Brexit cut-off date, the UK will be in a transition period during which EU regulations still apply. The transition period will end 31.12.2020 unless otherwise agreed between the UK and EU. After the transition period, when EU regulations will no longer be applicable, all UK ports will be treated as non-EEA ports, that means a voyage from an EEA port to a UK port is then treated as a voyage out of the EU and a voyage from an UK port to an EEA port is treated as a voyage into the EU. Please continue reporting as usual. We would come back with more information should voyages and port stays starting before and ending after the end of the transition period will require special reporting.
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 this link.
EMSA provides information about their THETIS-MRV system, including video tutorials, on their website.
No, there is no need to upload the monitoring plan (MP), 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 MPs can be handled complety outside of THETIS and this is what DNV GL is applying.
Please note: The MPs submitted to DNV GL will not appear in THETIS and this is not an issue, even if the note in THETIS may appear like that (“Monitoring Plan for x is not created”).
A request for partnership has to be sent to DNV GL, and DNV GL has to confirm it for the company to be able to add/register ships under the company’s account in THETIS-MRV.
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.
To ensure timely verification, we recommend that companies submit the ERs for verification no later than 31 March each year.
DNV GL verifies ERs but is not involved in the publication of ERs, neither actively nor indirectly, and cannot influence the EC's practice.
Shipowners associations are supporting their members by providing templates for letters of protest against the publication, so companies might want to contact their associations.
These letters can be uploaded as .pdf files as additional information to the Emissions Reports 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.
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.
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).
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.
Customers will be informed about the completion of the ER 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.
The EEDI, or alternatively EIV, is a mandatory figure for the ER (ref. regulation [EU] 2015/757, Article 11, 3 [v]).
The EEDI, if applicable, can be found on the Energy Efficiency Certificate.
If the EEDI is not applicable, the EIV (Estimated Index Value) should be calculated according to MEPC.231(65).
Data should also be available and consistent in THETIS.
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 statement of compliance (SoC) are kept on board.
The Emissions Report itself and the verification report (issued by 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 the ER 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.
The DoC is not a certificate which states continuous compliance, but a document stating compliance at a given time.
Note that the DoC is not issued on behalf of a flag.
DNV GL 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 EMSA website.
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