Reminder on emissions reporting for EU MRV & IMO DCS Regulations

07 January 2021 |  C21001

DromonClass wishes to remind Shipowners/ Managers on the submission of data to be verified within 2021 in order to meet important deadlines.

NOTICE TO
Ship Owners/ Managers/ Operators | Surveyors / Auditors

Regulation (EU) 2015/757 (EU MRV Regulation)

Shipowners of vessels falling under the applicability of Regulation (EU) 2015/757 on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport (known as the EU MRV Regulation) must report 2020 emissions data.

Companies operating ships of 5,000 gross tonnage and above which carry passengers or cargo for commercial purposes to, from or within any EU port, regardless of their flag, must report through THETIS-MRV by 1 April 2021 annual emissions data that have been verified by DromonClass.

The Emission Report of each ship along with supporting information mentioned in the following section for the period between 01/01/2020-31/12/202020 should be submitted to DromonClass.

IMO Data Collection System (DCS)

From 1 January 2019, each ship of 5,000 gross tonnage and above needs to collect the data specified in Appendix IX of MARPOL Annex VI, for this and each subsequent calendar year or portion thereof, as appropriate, according to the methodology included in Part II of the Ship Energy Efficiency Management Plan (SEEMP), as adopted by Resolution MEPC.278(70), entered into force on 1 March 2018.

As the first calendar year for the collection of data came to its end, we wish to remind ShipOwners on important deadlines to assure on time compliance with the IMO Data Collection System:

1. By 31 March 2021, Companies must submit the 2019 data to our Environmental Division for verification.
2. By 31 May 2021, ships must be issued with a Statement of Compliance (SoC) that shall be kept on board and is valid for the calendar year in which it is issued and for the first five months of the following calendar year.

IMPORTANT NOTE: When a vessel is to be sold

When a vessel is to be sold, the new Owner has the responsibility to obtain all relevant documents required under both schemes from the previous Owner and subsequently the liability for non-compliance with the regulation falls under the New Owner. Documents such as bunker delivery notes, cargo manifests etc. that are essential for Verification of Emissions Report (as mentioned in our pre-verification guidelines)  should accompany the ship’s file prior finalizing the ship’s sale.

It’s important to note that even if the ship has been with the previous Owner for even one or two months within the previous calendar year, all applicable data should be gathered and given to the new Owner prior the ship’s delivery. The DoC can be issued only if all Vessel’s data have been Verified for the reporting year 2020, regardless of ownership.

Act now

Ship Owners/ Managers/ Operators are invited to note important deadlines in order to meet the deadlines for both schemes and are urged to submit all required documents for the verification of 2020 ship’s data with all necessary supporting documents latest by the first week of March 2021 to ensure there will be enough time for Verification by 15 March 2021. Emissions Report must be submitted to THETIS MRV to be verified as Satisfactory by DromonClass by the 30^th of April 2021. A DoC must be onboard each vessel by 30 June 2021 as per the EU MRV Regulation.

For IMO DCS Compliance the SoC must be onboard the Vessels by 31 May 2021.

The MRV Regulation entitles Member States to establish and therefore, enforce a system of penalties in case of non-compliance with the EU MRV Regulation,

Since both schemes run in parallel, DromonClass acts as a single Verification Body for both EU MRV and IMO DCS schemes. Since both schemes have a number of similarities, the verification process can take place at one verification audit using the same source of data therefore, reducing the regulatory burden.