The Marine Environmental Protection Committee (MEPC) of IMO at its 70th session adopted amendments to MARPOL Annex VI establishing a mandatory scheme for the collection and reporting of fuel oil consumption data for each type of fuel used onboard a ship (resolution MEPC.278(70)).

The new Regulation 22A of MARPOL Annex VI applies to all ships of 5,000 GT and above engaged on international voyages.

The regulation does not apply to:

  1. Ships engaged on domestic voyages;
  2. Ships not propelled by mechanical means; and
  3. Platforms, including FPSOs, FSUs and drilling rigs.

In case your ship is typically engaged on domestic voyages and exceptionally requires to undertake a single international voyage, an exemption from the Administration shall be issued (refer to the IMO MEPC.1/Circ.863 for guidance).

 As required by the new Regulation 22A of MARPOL Annex VI:

  1. From calendar year 2019 (i.e. 01/01/2019 to 31/12/2019), each ship of 5,000 gross tonnage and above shall collect the data in a predefined form, for that and each subsequent calendar year or portion thereof, as appropriate, according to the methodology included in the SEEMP.
  2. At the end of each calendar year, the ship shall aggregate the data collected in that calendar year or portion thereof, as appropriate.
  3. Within three months after the end of each calendar year, the ship shall report to its Administration or any organization duly authorized by it, the aggregated value for each datum, via electronic communication and using a standardized format.
  4. Upon verification of the submitted data, the Administration or any organization duly authorized by it will issue to the ship by 31st of May a Statement of Compliance related to fuel oil consumption.
  5. Finally, the Administration will submit aggregated data to the IMO, which will maintain an anonymized IMO Ship Fuel Oil Consumption Database.


In order to collect the required data a new SEEMP Part II has to be developed to outline the methodology used to collect fuel oil consumption data.  The SEEMP Part II shall include information of fuel oil consumption by the main engines, auxiliary engines, gas turbines, boilers and inert gas generator, for each type of fuel oil consumed, regardless of whether a ship is underway or not.

Methods for collecting data on annual fuel oil consumption in metric tonnes include:

  1. Method 1: using bunker delivery notes (BDNs)
  2. Method 2: using flow meters
  3. Method 3: using bunker fuel oil tank monitoring on board
  4. Method 4: direct CO2 emissions measurement (is not required by Regulation 22A of MARPOL Annex VI but may be used).

In addition SEEMP Part II shall include methods to measure distance travelled, hours underway, process that will be used to report the data to the Administration and other information.

SEEMP Part II must be developed following the IMO MEPC.282(70) that includes guidelines for the development of a data collection plan.


The SEEMP Part III will serve as the implementation plan for achieving the required CII and will be subject to verification and company audits. In addition to describing the methodology used for calculating the CII and how to report it, the following must be included in the SEEMP III:

  1. The required CII for the next three years, calculated based on the individual vessel’s specifications
  2. A 3-year implementation plan documenting how the required CII will be achieved during the next three years, with yearly targets
  3. Procedures for self-evaluation and improvement; and
  4. Corrective action plan in case of inferior rating.

Why DromonClass

Since both schemes run in parallel we can act as a single Verification Body for both the IMO DCS and the EU MRV Regulation schemes. Since both schemes (i.e. the IMO and EU) 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.

Under the IMO DCS, we can provide the following services:

  1. Review of the Ship Energy Management Plan (SEEMP);
  2. Verification of the reported data;
  3. Issuance of the Statement of Compliance.


IMO Amendments to MARPOL Annex VI

Download the IMO Resolution MEPC.278(70)

IMO Guidelines for the development of SEEMP

Download the IMO Resolution MEPC.282(70)

IMO Annual Emissions Report

Download DBS format for the annual emissions report