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IMO/EU/UK GHG Verification


Background

        According to the data from the Fourth IMO GHG Study, the greenhouse gas (GHG) emissions – including carbon dioxide (CO2),methane (CH4) and nitrous oxide (N2O), expressed in CO2e – of total shipping (international, domestic and fishing) were 1,076 million tonnes in 2018 (9.6% increase).The share of shipping emissions in global anthropogenic emissions has increased from 2.76% in 2012 to 2.89% in 2018.In order to significantly reduce greenhouse gas (GHG) emissions from international shipping, effective global measures are desirable.

 

IMO DCS and CII:

        From calendar year 2019, a ship of 5,000 gross tonnage and above shall collect and report ship fuel oil consumption data(DCS) according to the methodology included in SEEMP Part II, and the data shall be verified by administration or RO. The reported data shall be transferred to the IMO Ship Fuel Oil Consumption Database.

        After the end of calendar year 2023 and after the end of each following calendar year, each ship of 5,000 gross tonnage and above which falls into specified ship types as per regulation shall calculate the attained annual operational CII over a 12-month period from 1 January to 31 December for the preceding calendar year, using the data collected in accordance with DCS, according to the methodology and plan described in the SEEMP Part III. The implementation of SEEMP Part III shall be subject to the verification and company audit, which may conducted with the interval of 3 years.




EU MRV/ETS/FuelEU

        In 2015, the decarbonisation of the maritime transport sector in the EU took an important first step forward with the entry into force of Regulation (EU) No 2015/757 on the Monitoring, Reporting and Verification of CO2 emissions (the MRV Regulation).The MRV Regulation established rules where shipping companies report annually, and accredited independent verifiers verify, the reported amounts of carbon dioxide (CO2) emissions and other relevant information from large ships (more than 5000 gross tonnage) calling at EEA ports. After 1 January 2024, the scope of the MRV Regulation expanded to include methane and nitrous oxide emissions from shipping. In addition, from 1 January 2025, general cargo ships between 400 and 5000 gross tonnage, and offshore ships of 400 gross tonnage and above, fell under the scope of the amended MRV Regulation.

        From 1 January 2024, CO2 emissions from ships of and above 5 000 gross tonnage, calling at or departing from ports in the European Economic Area (EEA), no matter what flag they fly (EEA/non EEA), have been included in the EU’s Emissions Trading System (ETS). From 1 January 2027, the emissions from offshore ships of and above 5000 gross tonnage are to ebe included in the ETS. Under this extension, every year, shipping companies have to monitor and report their emissions, as well as purchasing and surrendering ETS emission allowances for each tonne of reported CO2 emissions in the scope of the system.Each shipping company is associated with an administering authority of a Member State to ensure compliance with the Thetis-MRV system.




        The Fuel EU Maritime Regulation is a complementary regulation to the EU ETS, ensuring that the greenhouse gas intensity of fuels used by the shipping sector will gradually decrease over time. It contributes to the EU-wide target of reducing net emissions by at least 55% by 2030, and to achieving climate neutrality in 2050. The Regulation aims to reduce greenhouse gas emissions from the shipping sector, by promoting the use of cleaner fuels and energy, promoting the decarbonisation of the maritime transport sector by setting maximum limits on the yearly greenhouse gas intensity of the energy used by a ship. The new rules also introduce an additional zero-emission requirement at berth, mandating the use of onshore power supply (OPS) or alternative zero-emission technologies in ports by passenger ships and container ships from 1 January 2030, with a view to mitigating air pollution emissions in ports, which are often close to densely populated areas. The Fuel EU Maritime Regulation scope considers vessels above 5 000 gross tonnage, calling EEA ports, no matter what flag they fly (EU/non-EU). From 2025, shipping companies have been reporting their emissions through the Thetis-MRV system.




UK MRV

        Although the UK is no longer part of the EU MRV regime, it has retained and amended EU legislation, so that it establishes a UK MRV regime to monitor, report and verify emissions data from ships calling at UK ports.Ship operators should be collecting emissions data for their ships under the UK MRV regime from 1 January 2022. The UK MRV regime covers ships over 5,000 gross tonnage (irrespective of their Flag State or where the ship operator is registered) which serve the purpose of transporting cargo and passengers for commercial purposes to and from UK ports.

        the UK is working to develop a digital reporting system and has taken a decision to delay the requirement for ship operators to report emissions until the digital reporting system is fully operational. Ship operators and verifiers should continue to collect, verify and hold the data routinely, but are not required to report the data until further guidance on the digital reporting system is issued.




The services provided by CCS

    1Plan assessment and data verification

         China classification society holds the accreditation of verifier for EU MRV/ETS/FuelEU issued by ACCREDIA, which is the EU National Accreditation Body (NAB) and also the accreditation of verifier for UK MRV issued bu UKAS which is UK’s NAB. CCS provides the service for monitoring plan assessment and reports verification under EU and UK regime. With the aim of providing stakeholders with flexibility for their specific trade and business, CCS launched the service of voyage report verification.

With the authorization of the Administrations of flag States or Regions, China classification society carries out the SEEMP assessment and DCS/CII verification according to the MARPOL Annex VI with amendments, relevant regulations of authorizing States or Regions.

    2Guidelines subject to Ship’s GHG emission verification

        CCS has launched several guidelines to assist shipping company and stakeholders to develope the SEEMP or Monitoring plan and prepare the reports as per regulations. The consolidated and updated version of Guideline is in progress, which will be released in the year 2026. The new Guideline will cover requirements of IMO/EU/UK ship’s GHG emissions.

    3CCS IT platform

        CCS has developed the EEMS system as a tool to assist the clients for data monitoring, evaluation and reporting, which will improve the quality of data and the efficiency of administration.

    4Training and consultation

        With the challenges of compliance and business, CCS designs the universal expert training to provide the knowledge of requirements of regulation, best practice of minimizing operational risks, and improvement of efficiency and cost effectiveness for all clients. Face-to-face and online learning options are available.

 

The process of services provided by CCS:

    1.Assessment of monitoring plan/SEEMP.

        a)The application for assessment of monitoring plan/SEEMP and required documents shall be submitted to the CCS branch office in where the company is located via e-mail.

        b)The CCS branch office will response for the application in one workday and inform the client the relevant information and preliminary arrangement if the application is accepted.

        c)The assessment will be normally completed in 15~30 days from the date of the application accepted. During the assessment, the additional documents and on-site visit (ship and/or company) may be required.

        d)The Non-conformities raised during the assessment shall be corrected and the revised monitoring plan shall be re-submitted for approval.

        e)The Confirmation of Compliance and the assessment report could be issued in one month if there is not any uncorrected non-conformity in the monitoring plan.

    2.Verification of Emission Report/Report at Company Level/FuelEU Report.

        a)The application for verification and required documents shall be submitted to the CCS branch office in where the company is located via e-mail.

        b)The CCS branch office will response for the application in one workday and inform the client the relevant information and preliminary arrangement if the application is accepted.

        c)The verification plan will be sent to the applicant in time for verification preparation and the schedule may be modified according to the actual condition.

        d)The verification will be normally completed in 15~30 days from the date of the application accepted. During the verification, the additional documents and on-site visit (ship and/or company) may be required.

        e)The non-conformities and/or misstatements raised during the verification shall be corrected. In case of the company does not correct the non-conformities and/or misstatements, the company shall explain the main causes of the misstatements or non-conformities.

        f)The Document of Compliance and the verification report could be issued in one month if the emissions report is verified free from any material misstatement.

        g)For EU MRV/ETS/FuelEU, the company shall submit the verified emissions report, report at company level and FuelEU report to the EU Thetis-MRV System. After the confirmation of CCS, the company shall submit the report to EU Commission.

 

Complaints and appeals:

     1.The client may file a complaint against the services provided by CCS to local branch office in where the company is located or the Headquarters of CCS by email.

       Branch office: refer to CCS website: http://www.ccs.org.cn 

       Headquarters: sq@ccs.org.cn

     2.Upon the investigation, an official decision on handling of complaint will be delivered to client within 30~90 workdays.

     3.The client may submit an appeal in writing together with documentations to the CCS headquarters if he/she disagrees with the service results or dissatisfied with the decisions on handling of complaint by this Society.

     4.An investigation team consist of five members of impartiality committee agreed by appellant will investigate the appeal and an official decision will be delivered to the appellant within 90 workdays.


Relevant documents and software

1.  Application for Assessment of Monitoring Plan or Verification of Emission Report

2. CCS  EEMS System

3. The Notice of IMO DCS and EU MRV verification

4. CCS SEEMP Part II Template


For more details, please contact us:

Contact: Liu Yang

Tel.: 0086-10-58112473

E-mail: liuyang@ccs.org.cn