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Alignment of EU MRV Regulation with IMO CO2 Data Collection System

INTERCARGO welcomes the Consultation on the revision of the policy on monitoring, reporting and verification of CO2 emissions from maritime transport undertaken for the purpose to align the EU MRV with the global IMO Data Collection System (IMO DCS).

See also our July 2017 artcile here.

Regulation (EU) 757/2015 on monitoring, reporting and verification of carbon dioxide emissions from maritime transport was adopted and entered into force in 2015. It sets an EU wide scheme for reporting monitored and verified data on shipping CO2 emissions (EU MRV) applying to activities carried out after January 2018.

With the full support of the industry, IMO Member States have agreed inter alia to develop a comprehensive strategy for the further reduction of GHG emissions from shipping. Importantly, this will include an initial strategy, for adoption in 2018, which we are confident will include CO2 reduction objectives for the entire global sector consistent with the spirit of the Paris Agreement. This initial IMO strategy will then be further refined using data from the IMO CO2 data collection system, which will provide data on the CO2 emissions of ships throughout the global fleet.

The European Commission should ensure to the full extent the establishment of a single efficient and effective collection system serving the final goal of reducing CO2 emissions from international shipping in accordance with the Paris Agreement.

Such a full alignment would not only serve the purpose of creating an internationally unified reliable data base for ships CO2 emissions, it would also be in line with the better regulation agenda of the European Commission, which aims for targeted regulation in order to achieve its objectives and bring benefits at minimum cost to the European economy.

A full alignment of the EU MRV Regulation with the IMO Data DCS is to have global regulatory uniformity in order to minimize the additional burden in particular for small and medium-sized shipping companies and avoid any dual systems.

The full alignment and harmonisation of the EU MRV with the IMO DCS means that:

  • The EU MRV Regulation is amended to provide for reporting of the same data monitored under the IMO system; and
  • The data reported under the EU MRV Regulation will not be published; and
  • The verification procedures under the IMO DCS will be used within the EU MRV Regulation; and
  • The monitoring plan templates and reporting formats, procedures and systems are identical.

The EU MRV has to be 100% aligned to the IMO data collection system with verification carried out according to IMO rules and that reported information covering voyages from and to EEA ports will not be published. The use of the existing IMO mechanisms from the Flag State Administrations for enforcement and implementation, under a single and functional global fuel consumption data collection system, is required.

In assisting the review of the European Commission and encouraging full alignment of the EU MRV Regulation with the IMO Data DCS, INTERCARGO has actively participated in the stakeholder consultation process and expressed our opinions in the attached submission, and contributed to the analysis on the effectiveness and potential impacts of such alignment.

Attached the INTERCARGO’s latest submission to this consultation (Member login required).

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