CII & SEEMP Part III

August 2022 

The International Maritime Organization (IMO) has agreed on a set of guidelines to support mandatory measures to cut the carbon intensity of all ships. These have been approved by IMO’s Marine Environment Protection Committee (MEPC) and have been adopted on the MEPC 78th session on 1 July 2022.

The amendments to the MARPOL Convention require ships to combine a technical and operational approach to reduce their carbon intensity. This is in line with the ambition of the Initial IMO GHG Strategy, which aims to reduce the carbon intensity of international shipping and was agreed upon in 2018. IMO remains committed to reducing GHG emissions from international shipping and, as a matter of urgency, aims to phase them out as soon as possible in this century.

Two of the targets set in the Initial Strategy were:

  1. Carbon intensity of the ship to decline through implementation of further phases of the energy efficiency design index (EEDI) for new ships to review with the aim to strengthen the energy efficiency design requirements for ships with the percentage improvement for each phase to be determined for each ship type, as appropriate; and
  2. Carbon intensity of international shipping to decline to reduce CO2 emissions per transport work, as an average across international shipping, by at least 40% by 2030, pursuing efforts towards 70% by 2050, compared to 2008.

To meet these targets, the following measures have been introduced:

  1. The Energy Efficiency Existing Ship Index (EEXI), applicable from the first annual, intermediate, or renewal IAPP survey after 1 January 2023. The attained Energy Efficiency Existing Ship Index (EEXI) is required to be calculated for ships of 400 GT and above, in accordance with the different values set for ship types and size categories.
  2. The operational Carbon Intensity Indicator (CII) rating scheme, taking effect from 1 January 2023.
  3. The enhanced Ship Energy Efficiency Management Plan (SEEMP), whereby an approved SEEMP needs to be kept onboard from 1 January 2023. The performance level (CII Rating) would be recorded in the ship’s Ship Energy Efficiency Management Plan (SEEMP).

The above approach aims to address both technical (how the ship is equipped and retrofitted) and operational measures (how the ship operates).

In simple terms, the short-term term measures are aimed at achieving the carbon intensity reduction aims of the IMO initial GHG Strategy.

They do this by requiring all ships to calculate their Energy Efficiency Existing Ship Index (EEXI) and to establish their annual operational carbon intensity indicator (CII) and CII rating.

In other words, ships get a rating of their energy efficiency (A, B, C, D, E – where A is the best). A ship running on a low carbon fuel clearly gets a higher rating than one running on fossil fuel.

However, there are many ways a ship can do to improve its rating through various measures, such as:

  • hull cleaning to reduce drag;
  • speed and routeing optimization;
  • installation of low energy light bulbs;
  • installation of solar/wind auxiliary power for accommodation services; etc

The amendments require IMO to review the effectiveness of the implementation of the CII requirements, by 1 January 2025 at the latest, and, if necessary, develop and adopt further.

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