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Technical Notices

Reduction of Carbon Intensity on International Shipping

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The goal of the new requirements of Chapter 4 of the Annex VI of the MARPOL convention is to reduce the carbon intensity on international shipping, working towards the levels of ambition set out in the Initial IMO Strategy on reduction of GHG emissions from ships, as per IMO Resolution MEPC.304(72).

In order to achieve the goal set out, a ship to which the requirements of Chapter 4 of the Annex VI of the MARPOL convention applies, must comply as applicable, with the following functional requirements to reduce its carbon intensity:

A/ ENERGY EFFICIENCY EXISTING SHIP INDEX (EEXI) 

Ships of 400 gross tonnage and above engaged in international voyages indicated in the Chapter 4 of the Annex VI of the MARPOL, are subject to the Energy Efficiency Existing Ship Index (EEXI) regulations and consequently the EEXI of each such ship is to be calculated. EEXI represents “the amount of CO2 emissions from a ship when the ship sail transports one ton cargo for one nautical mile”. The EEXI that will be calculated, which is actually the Attained EEXI, must be verified by the classification societies on behalf of the flag administrations and must be less or at least equal to the Required EEXI.

The EEXI requirements apply to certain types of ships and namely to Ship Type: Bulk Carrier, Gas Carrier, Tanker, Containership, General Cargo Ship, Refrigerated Cargo Carrier, Combination Carrier, LNG Carrier, Ro-Ro Cargo Ship (Vehicle Carrier), Ro-Ro Cargo Ship, Ro-Ro Passenger Ship, Cruise Passenger Ship Having Non-Conventional Propulsion.

The Attained EEXI of each ship subject to the EEXI regulations is to be calculated in accordance with the “2022 GUIDELINES ON THE METHOD OF CALCULATION OF THE ATTAINED ENERGY EFFICIENCY EXISTING SHIP INDEX (EEXI)” – IMO Resolution MEPC.350(78). Attained EEXI can be calculated by the same formula as Attained EEDI. If the ship’s Attained EEDI is equal to or less than the Required EEXI, the Attained EEDI can be used as an alternative to the Attained EEXI.

The Required EEXI is applicable to Ships of a specific type and equivalent to the Required EEDI, as of 2023. The Required EEXI is calculated by multiplying the EEDI Reference Line by the reduction factor specified for each ship type and size. For details, reference can be made to the regulation 24 of Annex VI of the MARPOL convention – IMO Resolution MEPC.328(76).

Ships need to comply with the EEXI regulations by the first periodical survey of IAPP Certificate on or after 1 January 2023. Ships delivered on or after 1 January 2023 need to comply with the EEXI regulations at delivery.

If the ship’s Attained EEXI exceeds the Required EEXI, the ship needs to implement countermeasures to improve the ship’s Attained EEXI up to the Required EEXI. For reference, examples of the countermeasures are shown below.

  • EPL (Engine Power Limitation)
  • Installation or modification of energy-saving devices
  • Fuel conversion to a low-carbon fuel

The EPL is to be conducted in accordance with “2021 GUIDELINES ON THE SHAFT /ENGINE POWER LIMITATION SYSTEM TO COMPLY WITH THE EEXI REQUIREMENTS AND USE OF A POWER RESERVE” – IMO Resolution MEPC.335(76).

For verification of the attained EEXI, an application for a survey and an EEXI Technical File containing the necessary information for the verification and other relevant background documents should be submitted to our Classification Society for review.

EEXI document review, on-board survey, and issuance/re-issuance of IEE certificates are conducted in accordance with “2021 GUIDELINES ON SURVEY AND CERTIFICATION OF THE ATTAINED ENERGY EFFICIENCY EXISTING SHIP INDEX (EEXI)” – IMO Resolution MEPC.351(78).

The EEXI Technical File should include, but not be limited to:
a) deadweight (DWT) or gross tonnage (GT) for ro-ro passenger ship and cruise passenger ship having non-conventional propulsion;
b) the rated installed power (MCR) of the main and auxiliary engines;
c) the limited installed power (MCRlim) in cases where the overridable Shaft / Engine Power Limitation system is installed;
d) the ship speed (Vref);
e) the approximate ship speed (Vref,app) for pre-EEDI ships in cases where the speed-power curve is not available, as specified in paragraph 2.2.3.5 of the EEXI Calculation Guidelines;
f) an approved speed-power curve under the EEDI condition as specified in paragraph 2.2 of the EEDI Calculation Guidelines, which is described in the EEDI Technical File, in cases where regulation 22 of MARPOL Annex VI (Attained EEDI) is applied;

If EPL (Engine Power Limitation) is adopted to improve the Attained EEXI, the Onboard Management Manual is to be submitted to our Classification Society for review. In such case the below shall be included in the Onboard Management Manual:

  1. The particulars of the ship (name of ship, distinctive number or letters, port of
  2. registry, IMO number, gross tonnage)
  3. The particulars of the engine (name of manufacturer and type)
  4. Rated installed power (MCR[kw]) and engine speed (NMCR[rpm]) before EPL
  5. Limited installed power (MCRlim[kw])
  6. Method for sealing the EPL
  7. Method for monitoring the EPL (electronically controlled engine)
  8. Procedures and methods for releasing the EPL
  9. Time required for unlimiting the EPL
  10. Procedures for survey of the EPL system by class surveyor
  11. Administrator of the EPL system
  12. Procedure for the report on release of the EPL

 
Important notes:

  1.  The on-board survey will be conducted at the first periodical survey of the IAPP Certificate on or after 1 January 2023.
  2.  On satisfactory completion of the survey, the International Energy Efficiency Certificate, is to be re-issued accordingly. 

 
B/ SHIP ENERGY EFFICIENCY MANAGEMENT PLAN (SEEMP)

Each ship of 400 gross tonnage and above, shall keep on board a ship specific Ship Energy Efficiency Management Plan (SEEMP). This may form part of the ship’s Safety Management System (SMS). The SEEMP shall be developed and reviewed from now and on, taking into account the guidelines adopted by the Organization: 2022 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) – IMO Resolution MEPC.346(78).

In the case of a ship of 5,000 gross tonnage and above, the SEEMP shall include a description of the methodology that will be used to collect the data for each calendar year specified in Appendix IX of the Annex VI of the MARPOL convention – IMO Resolution MEPC.328(76). 

Within three months after the end of each calendar year, the ship shall report to our classification society the aggregated value for each datum specified in this Appendix IX of the Annex VI of the MARPOL convention, in order the Statement of Compliance to be issued, no later than five months from the beginning of the calendar year.

In addition, on or before 1 January 2023 a ship of the type: Bulk Carrier, Gas Carrier, Tanker, Containership, General Cargo Ship, Refrigerated Cargo Carrier, Combination Carrier, LNG Carrier, Ro-Ro Cargo Ship (Vehicle Carrier), Ro-Ro Cargo Ship, Ro-Ro Passenger Ship, Cruise Passenger Ship Having Non-Conventional Propulsion, of 5,000 gross tonnage and above, will need to revise their SEEMP to include:

a) a description of the methodology to be used to calculate the ships Attained Annual Operational CII, and the process that will be used to report this value to the Administration;
b) the Required Annual Operational CII for the next 3 years;
c) an implementation plan documenting how the Required Annual Operational CII will be achieved during the next 3 years; and
d) a procedure for self-evaluation and improvement.

For a ship rated as D for three consecutive years or rated as E, in accordance with regulation 28 of Annex VI of the MARPOL convention, the SEEMP shall be reviewed in accordance with regulation 28.8 of the said Annex, to include a plan of corrective actions to achieve the required annual operational CII.

Important notes:

  1. The revised SEEMP must be submitted to our classification society on time, so to be approved latest 1 January 2023.
  2. The revised SEEMP should take into account the 2022 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) – IMO Resolution MEPC.346(78).
  3. Upon approval of the revised SEEMP, the relevant Confirmation of Compliance, is to be re-issued accordingly.

 
C/ OPERATIONAL CARBON INTENSITY (CII)

The Operational Carbon Intensity (CII) requirements apply to certain types of ships and namely to Ship Type: Bulk Carrier, Gas Carrier, Tanker, Containership, General Cargo Ship, Refrigerated Cargo Carrier, Combination Carrier, LNG Carrier, Ro-Ro Cargo Ship (Vehicle Carrier), Ro-Ro Cargo Ship, Ro-Ro Passenger Ship, Cruise Passenger Ship Having Non-Conventional Propulsion.

i/ Attained annual operational carbon intensity indicator (attained annual operational CII) 

After the end of calendar year 2023 and after the end of each following calendar year, each ship of the type indicated above, of 5,000 gross tonnage and above, shall calculate the attained annual operational CII over a 12-month period from 1 January to 31 December for the preceding calendar year, using the data collected in accordance with regulation 27 of Annex I of the MARPOL convention – which is related to the “Collection and Reporting of the Ship Fuel Oil Consumption Data”, taking into account the guidelines adopted by the Organization: 2022 Guidelines on Operational Carbon Intensity Indicators and The Calculation Methods (CII Guidelines, G1) – IMO Resolution MEPC.352(78).

Within three months after the end of each calendar year, the ship shall report to our classification society, the attained annual operational CII via electronic communication, taking into account the guidelines adopted by the Organization: 2022 Guidelines on Operational Carbon Intensity Indicators and The Calculation Methods (CII Guidelines, G1) – IMO Resolution MEPC.352(78), in order the Statement of Compliance to be issued.

Important note:

  1. Upon receipt for each calendar year (a) of the data specified in Appendix IX of the Annex VI of the MARPOL convention – IMO Resolution MEPC.328(76) and (b) the attained annual operational CII, our classification society shall issue to the ship, no later than five months from the beginning of the calendar year “Statement of Compliance related to fuel oil consumption reporting and operational carbon intensity rating”, upon determination and verification of the data submitted pursuant to the applicable regulations of Annex VI of the MARPOL convention.

 
ii/ Required annual operational carbon intensity indicator (required annual operational CII)

For each ship of 5,000 gross tonnage and above the required annual operational CII shall be determined as follows:

Required annual operational CII  =  (1 –  Z / 100)  •  CIIR

where,

Z,    is the annual reduction factor to ensure continuous improvement of the ship’s operational carbon intensity within a specific rating level; and

CIIR,  is the reference value.

The annual reduction factor Z and the reference value CIIR shall be the values defined taking into account the guidelines adopted by the Organization: 2021 Guidelines on the Operational Carbon Intensity Reduction Factors relative to Reference Lines (CII Reduction Factors Guidelines, G3), 2022 Guidelines on the Reference Lines for use with Operational Carbon Intensity Indicators (CII Reference Lines Guidelines, G2), 2022 Guidelines on the Operational Carbon Intensity Rating of Ships (CII Rating Guidelines, G4) and 2022 Interim Guidelines on Correction Factors and Voyage Adjustments for CII Calculations (CII Guidelines, G5) – IMO Resolutions MEPC.338(76), MEPC.353(78), MEPC.354(78), MEPC.355(78).

Operational carbon intensity rating 

The attained annual operational CII shall be documented and verified against the required annual operational CII to determine operational carbon intensity rating A, B, C, D or E, indicating a major superior, minor superior, moderate, minor inferior, or inferior performance level, taking into account the guidelines developed by the Organization. The middle point of rating level C shall be the value equivalent to the required annual operational CII set out in paragraph 4 of regulation 28 of Annex VI of the MARPOL convention.

Corrective actions and incentives 

A ship rated as D for three consecutive years or rated as E, shall develop a plan of corrective actions to achieve the required annual operational CII.

The SEEMP shall be reviewed to include the plan of corrective actions accordingly, taking into account the guidelines of the Organization. The revised SEEMP shall be submitted to our classification society, preferably together with, but in no case later than 1 month after reporting the attained annual operational CII in accordance with paragraph 2 of this regulation.

A ship rated as D for three consecutive years or rated as E, shall duly undertake the planned corrective actions in accordance with the revised SEEMP.

Administrations, port authorities and other stakeholders as appropriate, are encouraged to provide incentives to ships rated as A or B.

Review 

A review shall be completed by 1 January 2026 by the Organization to assess:

a) the effectiveness of this regulation in reducing the carbon intensity of international shipping;
b) the need for reinforced corrective actions or other means of remedy, including possible additional EEXI requirements;
c) the need for enhancement of the enforcement mechanism;
d) the need for enhancement of the data collection system; and
e) the revision of the Z factor and CIIR values.

If based on the review the Parties decide to adopt amendments to this regulation, such amendments shall be adopted and brought into force.

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