Both EU MRV (Monitoring, Reporting and Verification) and IMO DCS (Data Collection System) requirements are mandatory, and are the first step in a process to collect and analyse CO2 emission data for the shipping industry. EU MRV data collection already started from 1 January 2018, while IMO DCS data collection on fuel consumption to comply with the IMO DCS regulations starts 1 January 2019. This statutory news provides practical advice on IMO DCS compliance.
Relevant for ship owners and managers, shipyards, design offices, suppliers and flag states.
Whilst the EU scheme focuses on CO2 emissions from shipping activities to, from and within the EU area, the IMO scheme covers emissions from shipping globally. Whether, how and when the two regimes will converge is not yet decided, however.
A conclusion of the two schemes, as well as the full timeline, can be found on our IMO DCS web pages.
With only some eight months to go before IMO DCS data collection starts, DNV GL has compiled a list of a few practical clarifications and recommendations:
Combined reporting for EU MRV and IMO DCS is recommended:
- If your vessel(s) is subject to both EU MRV and IMO DCS, reporting is required as per the respective requirements. However, combined reporting for the two schemes can be done through a combined reporting template. Shipping companies which have already contracted DNV GL as their MRV verifier only need to make minor adjustments for the DCS reporting.
- Methods for the monitoring and measurements of fuel consumption are described in SEEMP Part II (see below). A web application to ease the completion and submission of SEEMP Part II will be available from DNV GL in June 2018. Further information about this web application will be provided in due course on our IMO DCS web pages.
What kind of reporting is required from ships to meet the regulatory and verification obligations?
- For the purpose of verifying the data collected, DNV GL requires the ship to submit detailed data via regular reporting on specific events throughout the year. Event reports are required to calculate:
- Consumption data: Based on log abstract reports (arrival/noon/departure) containing position, fuel consumption, distance and time. As a minimum, ships should report upon all port departures and arrivals. For ship operators applying noon reports as part of their performance monitoring, such daily reporting can be used as a basis for the reports.
- Fuel balance: To enable verification of the overall fuel balance for the reporting period (year), the ship operator is required to provide documentation of bunker delivery notes (BDN) for each bunker delivery as well as remaining on board (ROB) reports. ROB should as a minimum be reported at the start, middle and end of the year.
SEEMP Part II is for recording fuel consumption for IMO DCS
A few clarifications with respect to SEEMP Part II:
- SEEMP Part II should be submitted separately to SEEMP Part I, which should already be in place on board the ship. Hence, only the new Part II of the SEEMP is now subject to approval according to the MARPOL Annex VI, Reg. 5.4.5.
- The approved SEEMP Part II is to be on board all ships in service on or before 31 December 2018 as an appendix to the SEEMP Part I, regardless of the vessel delivery date.
- SEEMP Part II should describe the monitoring of fuel consumption for the main fuel consumers on board for propulsion and normal operations, i.e. main engine, auxiliary engines, boilers and inert gas generators (not fuel consumed by the emergency generators, lifeboat engines, etc.).
- DNV GL, as Recognized Organization (RO), will also approve SEEMP Part II plans for non-DNV GL-classed vessels, subject to authorization and approval by the respective flag. Furthermore, it is up to the flag to decide if the RO covering the statutory work for a vessel can be different from the RO verifying the fuel oil consumption (FOC) report for that vessel.
Flag acceptance and ROs for IMO DCS
Some clarifications to the role of ROs for IMO DCS:
- DNV GL is authorized by most flag authorities for statutory services and is in the process of becoming authorized for DCS too. Some flags, however, for instance Liberia, will also authorize companies other than traditional class societies (ROs) to perform DCS verification work.
- Since the respective flag authorities may issue further flag-specific requirements (we do not expect any significant flag-specific requirements, however), it is advisable to contact the relevant flag for more detailed and updated information.
- For practical purposes, we recommend that our customers use the same verifier for EU MRV and IMO DCS.
- Prepare SEEMP Part II by using our SEEMP II digital reporting tool, which will be available by June 2018 on our Veracity platform. This will be an online template where you are guided in preparing the document. We recommend preparing SEEMP II using this app well in advance of the 31 December 2018 deadline to ensure timely assessment for compliance.
- Prepare for the DCS reporting of the required data once announced by DNV GL in due time. As for MRV, DNV GL will offer a fully digital reporting approach (meaning: no manual dispatch of data files or similar).
Customers choosing DNV GL as their verifier for the yearly DCS FOC reports will receive all required information from DNV GL throughout the coming months to prepare for their obligations.