The major objective of the following FAQ’s is to assist shipowners, companies, verifiers and stakeholders on the implementation of the MRV (Monitoring, Reporting and Verification) regulation.

It was prepared by Tecnoveritas and does not commit the European Commission. Only the Court of Justice of the European Union is competent to authoritatively interpret the Union law.

What does MRV stand for?
MRV is a recently created legislation by the European Council that has the goal of implementing restrictions to Green House Gases (GHG) emissions to maritime means of transportation, specificaly CO2, considered the most hazardous gas among them. Its target obligates shipowners to monitor, report and verify CO2 emissions, fuel consumptions and transport work of ships.
Is the EU MRV only focusing on CO2 or also other emissions like NOx or SOx?
The EU MRV is only focusing on CO2 emissions.
Why is there a need to monitor, report and verify maritime activities?
Maritime transportation has a considerable environmental impact. That is reflected in GHG emissions (carbon dioxide (CO2), nitrogen oxides (NOx), sulphur oxides (SOx), methane (CH4)) as well as safety and health impact (particulate matter (PM) and black carbon (BC)). Between 1990 and 2007 the resulting CO2 emissions from maritime transportation increased 48%.

Due to this fact it was urgent to take measures and, therefore, the best possible option was to set up a system for monitoring, reporting and verification (MRV system) of CO2 emissions based on the fuel consumption of ships as a first step of a staged approach.

To those who don’t follow the regulations what are the penalties?
There are strict penalties in case of non-compliance. Those penalties should be effective, proportionate and dissuasive.

The penalties are defined by each Member State. It is appropriate to provide the possibility of expulsion for ships that failed to comply for two or more consecutive reporting periods with monitoring and reporting requirements.

Which ships need to monitor and report their verified annual data? Which Ships are exempted?
MRV regulation is applied to big pollutants namely, ships with 5000 GT (Gross Tonnage) or higher, ships for commercial purposes (carrying passengers or cargo), regardless of the flag or country of the shipowner during their voyages from/to EEA ports.

Nevertheless there are ships exempted from MRV:

  • Warships;
  • Naval auxiliaries;
  • Fish-catching or fish-processing ships;
  • Wooden ships of a primitive build;
  • Ships not propelled by mechanical means;
  • Government ships used for non-commercial purpose;
  • Dredging;
  • Ice-breaking;
  • Pipe laying;
  • Offshore installation activities.

Which activities are covered by the Regulation?
The MRV Regulation sets monitoring and reporting obligations for EEA- related voyages carried out after 1st January 2018. Among the activities it covers:

  • Activities starting or ending in a port of call serving the purpose of transporting passengers and cargo for commercial purposes (voyages).
  • Ballast voyages (where ships load or discharge cargo and/or passengers for commercial purposes between ports of call).

Any other ship activities that does not serve the purpose of transporting cargo or passengers for commercial purposes are not subject to the monitoring, reporting and verification requirements (ex: ice-breaking, prospection and extraction of material, support to offshore installations).

What is the definition of port of call and a voyage according to MRV?
A Port of call is a start or an end point of a voyage, where ships stop to load or unload cargo, embark or disembark passengers. Doesn’t count as a port of call, a stop for the purpose of refueling, gathering supplies, relieving crew members, going into dry-dock or provide reparations to the ship and its equipment. It isn’t considered a port of call when for a reason of assistance, distress or by effect of adverse climacteric conditions a ship need take shelter.

In MRV context a voyage is considered a journey between two consecutive ports of call and an “EU MRV voyage” is considered when at least one of the ports of call is in the EU. The kind of voyages involved are:

  • Voyages from ships that come from the last port of call outside of the EU to the first EU port of call;
  • Voyages within EU ports of call;
  • Voyages from EU ports of call to the first port of call outside the EU.

Besides the mentions voyages it should also be considered the laden voyagesSee the following example:

Does the Regulation contemplate “ship to ship transfers” outside ports?
Yes, they are. During a voyage variations of cargo should be considered and a weighted average of cargo should be determined and applied to the voyage.
This regulation is relevant within the EEA (European Economic Area), what countries does it consider?
The countries that are included in the regulation are part of the EU State Members, Iceland, Norway, and the EEA Outermost Region:

 
Per voyage and as an aggregated annual figure what parameters each ship should monitor and report?
The most relevant information to be monitored and reported are:

  • CO2 emissions (based on emissions factors for each type of fuel);
  • Fuel consumption at sea and at berth for each emission source;
  • Voyage data (time at sea, distance travelled, cargo carried, transport work);
  • Energy efficiency parameters (total fuel consumption per distance, total fuel consumption per transport work, total CO2 emissions per distance, and total CO2 emissions per transport work);
  • Emissions sources (main engines, auxiliary engines, boilers, gas turbines, inert gas generators).

What is the definition of “cargo carried” for the different ship types and the respective units?

Type of Ships Cargo Units of Cargo
Passenger Ship Ship that carries more than twelve passengers but not cargo. Passengers
Container Ship Ship designed exclusively for the carriage of containers in holds and on deck. Tonnes
Oil tanker Ship constructed or adapted primarily to carry oil in bulk in its cargo spaces. Tonnes
Chemical tanker Ship constructed or adapted for the carriage in bulk of any liquid product listed in the International Bulk Chemical Code (a chemical tanker) or a ship constructed or adapted to carry a cargo of noxious liquid substances in bulk. Tonnes
LNG carrier Tanker for the bulk carriage of liquefied natural gas (LNG) (primarily methane) in independently insulated tanks. Liquefaction is achieved at temperatures down to -163°C). Cubic meters
Gas carrier Tanker for the bulk carriage of liquefied gases other than LNG. Tonnes
Bulk carrier Ship which is intended primarily to carry dry cargo in bulk, including such types as other carriers. Tonnes
Combination carrier Ship designed to load 100% dead weight with both liquid and dry cargo in bulk. Tonnes
General cargo Ship with multi-deck or single-deck hull designed primarily for the carriage of general cargo. Tonnes, Tones of dead-weight carried (ton)
Refrigerated cargo Ship designed exclusively for the carriage of refrigerated cargoes in holds. Tonnes
Vehicle carrier Ship designed for the carriage of empty cars and trucks. Tonnes, Tones of dead-weight carried (ton)
Ro-ro Ship Ship designed for the carriage of roll-on rolloff cargo transportation units or with roll-on roll-off cargo spaces. Tonnes
Ro-pax ship Passenger ship with roll-on roll-off cargo space. Tonnes, Tones of dead-weight carried (ton)
Container/Ro-ro cargo ship Hybrid of a container ship and a ro-ro cargo ship in independent sections. Cubic meters
Other ship types Ships not covered by any of the above definitions which fall under the scope of the regulation. Tonnes, Tones of dead-weight carried (ton)

Who is to assume the MRV obligations for each ship?
The MRV obligations (monitoring plan) are to be considered per ship and the entity fulfilling the obligations is the MRV Company.

It can be either the shipowner or any person that assume the responsibility for the operation of the ship. The Regulation allows the parties involved in the operation of each ship to determine, who assumes the MRV monitoring and reporting obligations.

What are the most relevant deadlines to take in consideration?
According to the Regulation, companies for each ship after 1st January 2018 must fulfill:

31st Dec.2017: Shipowners must complete the Monitoring Plan assessment;
1st Jan.2018: initiates the first Reporting Period. Companies shall monitor the ships CO2 emissions, fuel consumption and other relevant information with a view to aggregate data into an annual emissions report;
31st Dec.2018: End of the first Reporting Period;
30th Apr.2019: Companies must submit a satisfatorily verified emissions report to the EC and Flag State. MRV verifiers are to indicate that the report has been satisfactory and in conditions for issuing a Document of Compliance to be fulfilled;
30th Jun.2019: Companies should carry on board a Document of Compliance (DOC) for the activities of the precedent calendar year.

What if a ship starts carrying out voyages falling under the MRV Shipping Regulation after the deadline of 31stAugust 2017?
For ships which call into EEA ports for the first time after the deadline for submitting monitoring plans, companies should submit a monitoring plan to an accredited verifier without delay, and no later than two months after the ship’s first call at an EEA port.
What if a ship doesn’t carry any voyage and falls under the MRV shipping during a full calendar year?
A ship which has not carried out voyages during a whole reporting period of a calendar year X will not be required by the authorities to have a Document of Compliance on board showing compliance for that specific reporting period, when calling at EEA ports between 30th June of next year and 29th June of the subsequent one.
Companies must submit a monitoring plan for each ship under their responsibility?
No need to. The companies can avoid redundant submission of information, identifying data which applies in an identical way to their fleet and that reflects their technical characteristics and procedures.
What is the content and typical format of the monitoring plan? Does it have to be established in English?
Each company must assure an English translation of the assessed monitoring plan.
The monitoring plan must follow a template as indicated in Regulation EU 2016/1927 Annex I.
In terms of the content necessary, it must include:

  • Vessel and Company data;
  • Description of the Emission Sources on board (eg main engines, auxiliaries, gas turbines, boilers, inert gas generators and types of fuel used);
  • Description of procedures, systems and responsibilities;
  • Emission factors;
  • Methodologies for sampling;
  • Methods of analysis and description of the laboratories used;
  • Procedures to monitor the voyages and its activity (departure and arrival points, date and time using Greenwich Mean Time,  distance recorded, transport activity, cargo transported, data sources for determination and recording of time spent at sea between ports);
  • Procedures for monitoring fuel consumption on the ship (method chosen for calculation, description of measuring equipment, procedure for measuring fuel and fuel supplies in tanks, method for determining density, procedure to ensure the total uncertainty inherent in measurements);
  • Calculation of Energy Efficiency Average by one of the possible 4 methods: fuel consumption by distance, fuel consumption by activity, CO2emissions by distance or CO2 emissions by activity;
  • Additionally, a number of voluntary fields that might be relevant for limited number of ship categories. These voluntary fields concern for example: Ice class Ship, time and distance spent at sea when navigating on ice, data sources and formulas to determine records (if applicable)

What are the four possible methodologies shipowners can monitor the necessary data?
Shipowners can use any of the following methodologies:

  • Bunker Fuel Delivery Note (BDN) and periodic stocktakes of fuel tanks.
  • Bunker fuel tank monitoring on board.
  • Flow meters for applicable combustion processes
  • Flow meters for applicable combustion processes

Can an accredited MRV entity verify and ship company falling under the MRV regulation?
The verification activities must take in consideration that the verifier avoid any conflict of interest with the company, and should be completely impartial to it.
Relating to per voyage monitoring, under which conditions can a ship be exempted?
A ship can be exempt from the obligation to monitor a per-voyage basis, if:

  • All of the ship’s voyages during the reporting period are EEA-related voyages and
  • The ship performs more than 300 voyages during the reporting period.
  • Both conditions need to be fulfilled at the beginning of the reporting period.

What are the Shipowners Obligations?

  • Develop a monitoring plan (per voyage and annual) which must be submitted to an independent accredited verifier (until 31st August 2017 for assessment and completed before 31st December 2017)
  • Provide to the verifiers emissions data (fuel consumption, GHG, energy efficiency) and ships activity data (distance, cargo, time spent at sea);

What about the Verifiers Role?
In order to fulfil MRV’s obligations and avoid penalties shipowners should require the assistance of an independent accredited entity – the verifier, which has the following responsibilities:

  • Develop a monitoring plan (per voyage and annual) which must be submitted to an independent accredited verifier (until 31st August 2017 for assessment and completed before 31st December 2017)
  • Provide to the verifiers emissions data (fuel consumption, GHG, energy efficiency) and ships activity data (distance, cargo, time spent at sea);
  • Assess the emissions report, verify data credibility and compare estimations based on the ship location data and its features on-board;
  • The verifier must be impartial, independent, capable and accredited;
  • Identify and evaluate the risks related to the monitoring activity (inherent, calculations, control and detections).

Who are the competent bodies that can provide accreditation for verification activities?
According to the Regulation 765/2008, the Commission stipulated that each Member State in the EEA will define National Accreditation Bodies that can grant accreditation to legal entities performing verification activities pursuant to MRV.
Can an entity request accreditation from another National Accreditation Body in the Member State, other than the one which they are established?
Yes. Under exceptional circumstances an entity can request accreditation from another National Accreditation Body of the Member State.

A conformity assessment body may request accreditation by a National Accreditation Body in any one of the following situations:

  • When the Member State in which it is established has decided not to establish a National Accreditation Body and has not had recourse to the National Accreditation Body of another Member State;
  • When the National Accreditation Bodies do not perform accreditation in respect of the conformity assessment activities for which accreditation is sought;
  • When the National Accreditation Bodies have not successfully undergone peer evaluation in respect of the conformity assessment activities for which accreditation is sought.