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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

        The UK government has issued the 2026 No.245 and 2026 No.392 Orders, revoking the original UK MRV-related instruments and implementing the revised UK ETS Order from July 1, 2026. 

Compared to the EU ETS, the main differences of the UK ETS include:

1. It only applies to voyages between UK ports of call and activities within UK ports of call. Voyages between a port of call in Northern Ireland and a port of call in Great Britain are subject to 50% of the UK ETS allowances, other applicable voyages and activities within UK ports of call are subject to 100% of the UK ETS allowances.

2. The shipowner or the ISM management company authorized by the shipowner to assume UK ETS responsibility should apply to the UK corresponding regulators for the company level emissions monitoring plan (using the METS system), and the regulators will issue the emissions monitoring plan. There is no longer a requirement for the verifier to approve the individual ship's monitoring plan. Shipowner or the authorized ISM management company must apply to regulator for emission plan before the end of the period of 42 days commencing with the day it performs its first maritime activity.

3. The emission factor for the fuel that meets the requirements of Article 37 of Order is 0.

4. Shipowner or the authorized ISM management company should submit the annual emissions report by March 31 of each year starting from 2027, along with the verifier's verification report (using the METS system); and surrender the UK ETS allowances by April 30 of each year.

5. The UK ETS allowances for the period from July 1, 2026 to December 31, 2026 and the period from January 1, 2027 to December 31, 2027 can be surrendered together by April 30, 2028.

6. The Document of Compliance under the original UK MRV mechanism will no longer be issued for ships.


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.


Impartiality and Independence Statement

To ensure the impartiality and independence related to verification activities carried out by CCS comply with the requirements of regulation and standard, the below MRV application is to be rejected by CCS:

1. The confirmation or verification application from the applicant that CCS has provided the technical services to, and

2. CCS has the relationship with those who provided technical services to the responsible party that support the poses an unacceptable risk to impartiality.

To ensure the impartiality and independence of MRV verification relevant staff, CCS ensures:

1. shall not use the personnel with actual or potential conflict of interest to carry out MRV verification activities;

2. the personnel who carried out assessment of monitoring plan, shall not verify the emission report for the same vessel;

3. shall not use the personnel who provide the technical service to the company to carry out the verification activities;

All the verification activities carried out by CCS is to be done independently.

In order to assist company to understand the convention, regulation and related guidelines, CCS will carry out training about those public information, but that does not mean that the verification for the companies participating in the training will be more easier, faster and cheaper.

 

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: Chen jiejun

Tel.: 0086-021-38103406

E-mail: jjchen@ccs.org.cn