MARPOL Annex VI

MARPOL, ANNEX VI. Regulations for the Prevention of Air Pollution from Ships.

General and scope of application

MARPOL, Annex VI, applies to all ships, except where expressly provided otherwise in specific regulations.

Ships of less than 400 GT need however not being surveyed and certified. In other words, ships of less than 400 GT are not requested to be surveyed unless instructions are received from the Flag Administration or applicable provisions are entered in the Agreement signed between Recognised Organisation (RO) and the Adminstration.

Requirements for control of emissions from ships - MARPOL Annex VI, Chapter 3

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MARPOL, Annex VI (Entry into force 19 May 2005) is covering the following topics :

• Ozone-depleting substances (ODS) emissions from ships,

• Nitrogen Oxide (NOx) emissions from diesel engines of ships,

• Sulphur Oxide (SOx) emissions from ships,

• Volatile organic coumpounds (VOCs) emissions from cargo tanks of oil tankers,

• Shipboard incinerations of waste,

• Fuel oil quality.

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Revised MARPOL Annex VI applies to all ship from 1st of July 2010.

Some new requirements are applicable to new ships built from 01/07/2010 (NOx Technical Code 2008) whereas some other requirements are retroactive (reg.12 ODS Record Book, reg.15 VOC management plan).

Requirements for energy efficiency for ships - MARPOL Annex VI, Chapter 4

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The chapter 4 is covering the following topics :

• Attained Energy Efficiency Design Index (Attained EEDI),

• Attained Energy Efficiency Existing Ship Index (attained EEXI) – Entry into force on 1 November 2022,

• Required Energy Efficiency Design Index (Required EEDI),

• Required Energy Efficiency Existing Ship Index (required EEXI) – Entry into force on 1 November 2022,

• Ship Energy Efficiency Management Plan (SEEMP),

• Collection and reporting of ship fuel oil consumption data,

• Operational carbon intensity – Entry into force on 1 November 2022.

Technical carbon intensity requirements

EEDI

MARPOL, Annex VI as amended by resolution MEPC.203(62) include a new chapter 4 related to the regulations on Energy Efficiency for Ships. The amendments are intended to improve energy efficiency for ships through a set of technical performance standards. These amendments enter into force on 1 January 2013.

EEXI – Entry into force on 1 November 2022

MARPOL, Annex VI as amended by resolution MEPC.328(76) (adopted in a consolidated revised Annex VI “2021 REVISED MARPOL ANNEX VI”). The amendments require ships of 400 gt and above (new and existing), to calculate their attained and required Energy Efficiency Existing Ship Index (EEXI), in accordance with the different values set for ship types and size categories. Refer to interim instructions in Revised Chapter 4 – Reduction of the carbon intensity of international shipping - Resolution MEPC.328(76)

Operational carbon intensity requirements

Collection and reporting of ship fuel oil consumption data - Entry into force on 1 March 2018

MARPOL, Annex VI as amended by resolution MEPC.278(70) requires for ships of 5,000 GT and above :

• To update the Ship Energy Efficiency Management Plan (SEEMP), by adding a Part II relating to the Ship Fuel Oil Consumption Data Collection Plan

• To collect and report the data specified in appendix IX to the Annex VI

Operational carbon intensity – Entry into force on 1 November 2022

MARPOL, Annex VI as amended by resolution MEPC.328(76) (adopted in a consolidated revised Annex VI “2021 REVISED MARPOL ANNEX VI”) requires for ships of 5,000 GT and above, which falls into one or more of the categories described in regulation 28 :

• To update the Ship Energy Efficiency Management Plan (SEEMP), by adding a Part III relating to the operational Carbon Intensity Plan

• To calculate the ship’s attained annual operational carbon intensity and rating on the basis of data collected pursuant to regulation 27 of MARPOL Annex VI

Use of electronic record books under MARPOL

Amendments to allow for electronic record books to be used have been adopted for:

- MARPOL Annexes I, II and V – resolution MEPC.314(74);- MARPOL Annex VI – resolution MEPC.316(74); and- NOX Technical Code 2008 – resolution MEPC.317(74),and enter into force on 1 October 2020.IMO also adopted related Guidelines for the use of electronic record books under MARPOL – resolution MEPC.312(74)

MARPOL amendments are related to the following record books:

.1 Oil Record Book, parts I and II (MARPOL Annex I, regulations 17.1 and 36.1);.2 Cargo Record Book (MARPOL Annex II, regulation 15.1);.3 Garbage Record Book, parts I and II (MARPOL Annex V, regulation 10.3);.4 Ozone-depleting Substances Record Book (MARPOL Annex VI, regulation 12.6);.5 Recording of the tier and on/off status of marine diesel engines (MARPOL Annex VI, regulation 13.5.3);.6 Record of Fuel Oil Changeover (MARPOL Annex VI, regulation 14.6); and.7 Record Book of Engine Parameters (NOX Technical Code, paragraph 6.2.2.7).

Approval of electronic record books and issuance of the ship’s Declaration

An Electronic Record Book means a device or system, approved by the Administration, used to electronically record the required entries for discharges, transfers and other operations as required under the relevant Annex of Marpol in lieu of a hard copy record book, taking into account the “Guidelines for the use of electronic record books under MARPOL”, resolution MEPC.312(74).Any electronic system deemed to meet the above criteria shall be provided with a “Declaration of Marpol electronic Record Book”, to be carried on board the ship for the purpose of regulatory surveys or inspections. Delegating the assessment of the electronic record book against these Guidelines and the issuing of a declaration on behalf of the Administration by recognized organizations (ROs) is at the discretion of the Administration. Refer to flag procedures.(Some flag administration may not accept ERB refer to flag procedures)

Recognised Organisation (RO) Approval of electronic record books under MARPOL

When duly delegated by the Flag Administration, DA_ELEC will assess the conformity of the specific electronic record book to be installed on the concerned ship and issue a Type Approval Certificate.Refer to the flag procedure for possible specific Flag instructions and requirements in relation to the assessment and approval process

Recognised Organisation (RO) Issuance of a Declaration for MARPOL electronic record book

When duly delegated by the ship’s Flag Administration to issue a “Declaration for MARPOL electronic record book” on their behalf (refer to flag procedures), Recognised Organisation (RO) Surveyor shall verify onboard that:- A declaration by the installer that the system is installed in accordance with current regulations, that its performance has been tested and that it is in perfect working order, is available on-board.- Recognised Organisation (RO) Type Approval Letters are available on-board- Any Flag Administration possible specific instructions or requirements are implemented– refer to the flag procedure.

At the completion of a satisfactory verification onboard, Recognised Organisation (RO) surveyor issues a “Declaration for MARPOL electronic record book” on behalf of the Flag Administration (refer to the flag procedure), which is to be available on-board“Declaration for MARPOL electronic record book” based on format provided in the appendix of resolution MEPC.312(74) is available in Certificate Editor and ASMS2.

Periodical survey

It shall be confirmed that MARPOL electronic record book(s), conform to the declaration retained onboard.

Unmanned Non-Self-Propelled (UNSP) Barges – Exemption from Certain Survey and Certification Requirements under the MARPOL Convention

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IMO adopted amendments to MARPOL Annexes I and IV and amendments to MARPOL Annex VI, concerning the exemption of unmanned non-self-propelled (UNSP) barges from certain survey and certification requirements, by resolutions MEPC.330(76) and MEPC.328(76), respectively.These amendments to MARPOL Annex I, IV and VI will enter into force on 1 November 2022.Under MARPOL Annex VI (reg.2.1.32), UNSP Barge means a barge that:

1. is not propelled by mechanical means;

2. has no system, equipment and/or machinery fitted that may generate emissions controlled by Annex VI to the Convention; and

3. has neither persons nor living animals on board;

The above definition include the prerequisites conditions to be confirmed for granting exemptions.

Procedure for granting exemptions and issuing Exemption certificates

Unless otherwise instructed by the flag and when duly delegated (refer to flag procedures), the provisions of the circular MEPC.1/Circ.892 (see attached file) applies, including the following steps:

1. The shipowner or operator should apply to the Administration, or the Recognized Organization (RO) acting on its behalf, for exemption(s) with relevant information on the exemption(s) conditions for UNSP barges and relevant drawings (General Arrangement Plan, Capacity Plan and any other plans or documents, as necessary).

2. The Administration, or the RO acting on its behalf, should review the General Arrangement Plan, Capacity Plan and other relevant information to confirm that the relevant conditions referred to in regulation 3.4 of MARPOL Annex VI are met.

3. After a satisfactory review of the submitted plans and information, a survey of the UNSP barge should be carried out to confirm if the actual arrangements on board comply with the exemption conditions, as appropriate.

4. Based on satisfactory results of the survey, certificates for exemption of a UNSP barge from certain survey and certification requirements under MARPOL Annexes VI, as per regulations 3.4 and 8.4 of MARPOL Annex VI and forms set out in appendices of MARPOL Annexes VI, should be issued by the Administration or, by the RO acting on its behalf.

Control of emissions from ships - Chapter 3

Ozone-depleting substances (ODS)

(Reg. VI/12)

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For the purpose of the Annex, ozone-depleting substances (ODS) are those listed in Annexes A, B, C or E of the Montreal Protocol on Substances that Deplete the Ozone Layer, in force at the time of application of this Annex.

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Substances which may be found on ships includes (but are not limited to) :

• Halon 1211 Bromochlorodifluoromethane,

• Halon 1301 Bromotrifluoromethane,

• Halon 2402 (also known as Halon 114B2),

• CFC-11 Trichlorofluomethane,

• CFC-12 Dichlorodifluoromethane,

• CFC-113 1.1.2-Trichloro-1, 2,2-trifluoroethane,

• CFC-114 1.2-Dichloro-1, 1,2,2-tetrafluoroethane,

• CFC-115 Chloropentafluoroethane.

Installations concerned are mainly fixed fire extinguishing systems and refrigerating plants.

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As from the entry into force of the Annex :

• The release of ozone-depleting substances is prohibited.

• New installations containing ozone-depleting substances are probited on all ships (new installations of Halon are already prohibited through the SOLAS Convention). Ships constructed on/after 19 May 2005 shall not be equiped with any installation containing ODS substances. No new installation containing ODS shall be fitted on board a ship constructed before 19 May 2005 (in such cases, new installation excludes repairs or recharges to previously installed installations).

• New installation containing hydrochlorofluocarbons (HCFCs) are however authorized until 1 January 2020.

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The Surveyor makes sure that no new installation containing ozone-depleting substances has been fitted on board . Existing installations are to be recorded in both the Supplement to the IAPP Certificate and the Recognised Organisation (RO) Record Ad WE1318. Those installations which should be recorded are equipment and system such as air conditioning systems, refrigerating plants, fixed and portable fire-extinguishing systems and insulation.

The Surveyor conducts an external examination of the installations to ensure, as far as practicable, that they are maintained and and that there is no leakage and emission of ozone-depleting substances. This could be achieved by using HFC, CFC, HCFC electronic leak detectors, buble test (soap solution), ultrasonic leak detector, etc.

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Marpol Revised Annex VI (01/07/2010) : Reg.12.6. Each ship that has rechargeable systems that contain ODS shall maintain an ODS Record-Book.

Recording installations containing ozone-depleting substances

At the fist survey conducted for certification purposes :

Installations containing ODS are entered in part 1 of the Record of Equipment related to Ozone Depleting Substances and Nitrogene Oxides (NOx), Form AdWE1318.

They are also entered in paragraph 2.1 of the Supplement to the IAPP Certificate / Document of Compliance (Record of construction and equipment).

Leak detection

Periodic leak detection should be performed. An effective leak detection method is to spray soapy water on all joints and connections to ensure they are leak tight. Amongst other means, electronic detectors may also be used. The halide torch method is no longer considered acceptable, especially in confined spaces due to the production of toxic fumes.

Frequently asked questions

Cf. Annex Ozone depleting substances (ODS)

Nitrogen oxydes (NOx)

(Reg.VI/13)

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Any diesel engines with a power output of more than 130 kW installed on ships of over 400 GT and constructed on / after 1 January 2000 are to be surveyed in compliance with regulation 5 of Annex VI and the NOx Technical Code. The regulation not only applies to main engines and generators but also to diesel engines driving compressors, cranes, hydraulic power pack, etc. Diesel engines which have undergone and / or undergo a major conversion on / after 1 January 2000 should comply with the requirements too.

However, diesel engine used solely for emergency purposes, diesel engines installed in lifeboats or, emissions directly arising from the exploration, exploitation and associated offshore processing of sea-bed mineral resources , are not requested to comply with the requirements.

Any diesel engine with a power output of more than 130 kW and installed on any craft constructed on or after 1 January 2000, even if less than 400 GT, to comply with the requirements of the NOx Technical Code.

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The NOx emission limits are related to engine rated crankshaft speed :

Revised Annex VI - New NOx limits

The revised Annex VI of MARPOL entered into force in 1 July 2010. The new revision substantially tightens the NOx limits compared to the previous version of this Annex.

The revised NOx regulations contain a three-tier approach as follows:

Tier I

For marine diesel engines installed on ships constructed from 1 January 2000 to 1 January 2011, the allowable NOx emissions are :

• 17.0 g/kWh when n is less than 130 rpm;

• 45.0*n(-0.2) g/kWh when n is 130 rpm or more but less than 2,000 rpm;

• 9.8 g/kWh when n is 2,000 rpm or more.

Tier II

For marine diesel engines installed on ships constructed on or after 1 January 2011, the allowable NOx emissions are :

• 14.4 g/kWh when n is less than 130 rpm;

• 44.0*n(-0.23) g/kWh when n is 130 rpm or more but less than 2,000 rpm;

• 7.7 g/kWh when n is 2,000 rpm or more.

Tier III

For ships operating in the NOx ECAs, the allowable NOx emissions are :

• 3.4 g/kWh when n is less than 130 rpm;

• 9.0*n(-0.2) g/kWh when n is 130 rpm or more but less than 2,000 rpm;

• 2.0 g/kWh when n is 2,000 rpm or more.

It apply to ships constructed on or after:

1. 1 January 2016 and operating in the North American Emission Control Area or the United States Caribbean Sea Emission Control Area;

   In accordance with the provisions of regulation 13 para.10, the Marine Environment Protection Committee (MEPC), at the 66th session, have reviewed the status of technological developments and confirmed that Tier III requirements should be started from 1 January 2016 as originally scheduled.

2. 1 January 2021 and operating in the Baltic Sea Emission Control Area or the North Sea Emission Control Area;

   NB : Amendments to MARPOL Annex VI to designate the North Sea and the Baltic Sea as emission control areas (ECAs) for nitrogen oxides (NOx) enter into force on 1 January 2019. (Resolution MEPC.286(71))Some exemption may applies, as provided in regulation 13.5.4 and 13.5.5, for ships fitted with non-Tier III compliant marine diesel engines to be built, converted, repaired and/or maintained at shipyards located in the NOx Tier III ECAs.

3. 1 January 2025 and is operating in the Canadian Arctic Emission Control Area;

   NB: Amendments to MARPOL Annex VI to designate the Canadian Arctic and the Norwegian Sea as Emission Control Areas (ECAs) for nitrogen oxides (NOx) enter into force on 1 March 2026. (Resolution MEPC.392(82))

4. 1 March 2026 * and is operating in the Norwegian Sea as Emission Control Area;

   NB: amendments to MARPOL Annex VI to designate the Canadian Arctic and the Norwegian Sea as Emission Control Areas (ECAs) for nitrogen oxides (NOx) enter into force on 1 March 2026. (Resolution MEPC.392(82)).

   * As per regulation 13.5.1.2.3: “ship constructed on or after 1 March 2026" means a ship:.1 for which the building contract is placed on or after 1 March 2026; or.2 in the absence of a building contract, the keel of which is laid or which is at a similar stage of construction on or after 1 September 2026; or.3 the delivery of which is on or after 1 March 2030.The Norwegian Sea NOx ECA makes use of a ʺthree dates criterionʺ (building contract, keel laid and delivery date) which differs from the application format used in other NOx ECAs. This approach aims to ensure more effective implementation of Tier III NOx requirements. Consequently, the new requirements apply to ships delivered on or after 1 March 2030, regardless of keel-laying date. Supplement to IAPP Certificate:To facilitate the verification of compliance for the Norwegian Sea NOx ECA, Resolution MEPC.392(82) introduces changes to the Supplement to the IAPP Certificate. Specifically, Section 1.3 now mandates explicit entry of three dates: Contract Date, Keel Laying Date, and Delivery Date of the ship. In accordance with the provisions in paragraph 3.1 of the Guidance provided in MSC-MEPC.5/Circ.6, re-issuance of the existing IAPP certificate and supplement for NOx emission compliance, after entry into force of the amendment would not be necessary until their expiry.

Furthermore the following provisions have been introduced by the resolution MEPC.251(66):The Tier III requirements apply to installed marine diesel engines when operated in other emission control areas which might be designated in the future for Tier III NOx control. Tier III would apply to ships constructed on or after the date of adoption by the Marine Environment Protection Committee of such an emission control area, or a later date as may be specified in the amendment designating the NOx Tier III emission control area.The Tier III requirements do not apply to a marine diesel engine installed on a ship constructed prior to 1 January 2021 of less than 500 gross tonnage, of 24 m or over in length, which has been specifically designed and is used solely, for recreational purposes

The new Annex VI Tier II and Tier III standards apply only to engines installed on vessels constructed on or after January 1, 2011 (Tier II) and January 1, 2016 (Tier III), or engines that undergo a major conversion on or after those dates. There is no need for issuance of a new EIAPP Certificate to existing engines installed on vessels constructed before these dates.

Major conversion - Replacement of an engine

1. Non –identical replacement engines not required to meet the tier III limits

   Regulation 13.2.2 of MARPOL Annex VI specifies which NOx emission standard shall be applied when a marine diesel engine is replaced with a non-identical marine diesel engine.

   IMO adopted amendments to regulation 13.2.2 (resolution MEPC.385(81)), for an entry into force on 1 August 2025, which include :- Clarification that a marine diesel engine replacing a steam system shall be considered a replacement engine.- New requirement for Administrations to notify the IMO, after the entry-into-force date of the amendments, in all instances where a Tier II, rather than a Tier III, replacement engine had been installed in accordance with the provisions in the regulation 13

   Please refer to the provisions of “2024 Guidelines as required by regulation 13.2.2 in respect of non-identical replacement engines not required to meet the Tier III limit”, as set out at annex to resolution MEPC.386(81).

2. "Time of the replacement or addition" for the applicable NOx Tier standard for the supplement to the IAPP Certificate

   Refer to the UI of MARPOL Annex VI as set out in the annex of MEPC.1/Circ.795/Rev.4 and IACS UI MPC98/rev.1

3. “Identical” / “non identical” replacement engine

   Refer to the UI of MARPOL Annex VI as set out in the annex of MEPC.1/Circ.795/Rev.3

Definition of marine diesel engine - Reg. VI/2

The definition of "marine diesel engine" as amended by res. MEPC.258(67) (entry into force 1 March 2016) includes gas fuelled engine installed on a ship constructed on or after 1 March 2016 or a gas fuelled additional or non-identical replacement engine installed on or after that date is also considered as a marine diesel engine. In conjunction the definition of "Fuel oil" has been amended.

Record requirements for operational compliance with NOx Tier III emission control areas - MEPC.271(69)

MARPOL, Annex VI as amended by resolution MEPC.271(69) include a new reg.13.5.3 related to the logging of engine data on a vessel's entry into or exit from a NOx tier III emission control area.The tier and on/off status of marine diesel engines installed on board a ship to which regulation13.5.1 applies (NOx Tier III provisions) which are certified to both Tier II and Tier III or which are certified to Tier II only shall be recorded in such logbook as prescribed by the Administration at entry into and exit from an NOx Tier III emission control area, or when the on/off status changes within such an area, together with the date, time and position of the ship.Surveyors shall confirm that there is a record taking the form of logbook as prescribed by the Administration, for recording the tier and on/off status as prescribed in reg.13.5.3.

NOx Emission Control Area (ECA)

(Reg. 13.6)

The NOx Tier III emission control areas are:.1 the North American Emission Control Area, which means the area described by the coordinates provided in appendix VII of MARPOL Annex IV;.2 the United States Caribbean Sea Emission Control Area, which means the area described by the coordinates provided in appendix VII of MARPOL Annex VI;.3 the Baltic Sea Emission Control Area as defined in regulation 1.11.2 of MARPOL Annex I; .4 the North Sea Emission Control Area as defined in regulation 1.14.6 of MARPOL Annex V;

.5 the Canadian Arctic Emission Control area, which means the area described by the coordinates provided in appendix VII of MARPOL Annex VI; and.6 the Norwegian Sea as defined in regulation 13.9.4 of MARPOL Annex II.

Use of spare parts for engines complying with NOx Code

Recognised Organisation (RO) as RO cannot accept any parts that are not listed, with identification numbers, in the Engine’s Technical File (i.e. all the components have to have identification markings (IMO ID No.) according to the technical file).

Particular case: Engine designer X – Engine licensee Y

For an Engine X built under License by Y, the technical file only includes the identification numbers for the parts supply under Y Licensee and the identification numbers for the parts supply of the engine designer X supplied parts.

Therefore any other parts even if identical cannot be used.

However if the parts being supplied from another licensee are identical in quality and manufacture to the Y parts and/or to the designer X parts, then the client will require to gain approval from the Flag (or Recognised Organisation (RO) on behalf of the Flag if authorised) for amendment to the Engines' technical file. This amendment to parts supply should be recorded in the "record book of engine parameters" (According to the NOx Technical Code).

In order for such a change to the engine technical file to be accepted, the "engine designer" or the "original licensee" would be required to issue an official statement identifying the subject parts (IMO ID no.) and stating that these parts are direct equivalents to the original ID Parts. The client would have to obtain such proof prior to requesting the Flag or RO to make the amendment in the documentation.

NOx Technical File applies.

NOx Technical Code

This is a mandatory Code developed by the IMO in line with the Annex VI which defines how the NOx limitations shall be done.

Definitions

1. Engine family

   The Engine Family concept shall be interpreted as applicable to mass produced small bore engines (generally high speed) that may, for design purposes, include adjustable features but are generally dispatched with the intent that no ‘installation’ or ‘in service’ setting modifications are undertaken. An Engine Family may have different cylinder bore and stroke dimensions (within the defined limits – see NOx Code paragraph 4.3.8.2.3) (IACS UI MPC53 rev.1).

2. Engine group

   The Engine Group concept shall be interpreted as applicable to any engine intended for main propulsion or auxiliary duties, where adjustment and modification following installation (and through the service life of the engine) is considered routine. an Engine Group effectively have identical bore and stroke dimensions as a result of only one of the parameters defined under NOx Code paragraph 4.4.6.2 being permitted to vary within the defined engine group (IACS UI MPC53 rev.1).

3. Major conversion

   For the purpose of the Regulation 13 (from MARPOL Annex VI), major conversion means a modification on or after 1 January 2000 of a marine diesel engine that has not already been certified to the standards set forth in paragraph 3, 4 or 5.1.1 of this regulation where :

   1. the engine is replaced by a marine diesel engine or an additional marine diesel engine is installed, or

   2. any substantial modification, as defined in the revised NOx Technical Code 2008, is made to the engine, or

   3. the maximum continuous rating of the engine is increased by more than 10% compared to the maximum continuous rating of the original certification of the engine.

   The major conversion clause may have significant involvement as it eventually extends the scope of control to engines which would not otherwise be concerned (installed on ships constructed before 1 January 2000). Any operational or technical modification made after 1 January 2000 (change of fuel timing, fuel injection equipment, etc.) could increase the defined level of NOx emissions. The owners would have to demonstrate that such operational or technical changes do not involve an unacceptable increase in emissions.

4. Substantial modification (as defined in the revised NOx Technical Code 2008)

   1. For engines installed on ships constructed on or after 1 January 2000, substantial modification means any modification to an engine that could potentially cause the engine to exceed the applicable emission limit set out in regulation 13 of MARPOL Annex VI.

   2. For engines installed on ships constructed before 1 January 2000, substantial modification means any modification made to an engine that increases its existing emission characteristics established by the simplified measurement method (as described in 6.3 of the revised NOx Technical Code 2008) in excess of the allowances set out in 6.3.11 of this Code. These changes include, but are not limited to, changes in its operations or in its technical parameters (e.g. changing camshafts, fuel injection systems, air systems, combustion chamber configuration, or timing calibration of the engine). Refer to IACS UI MPC32 rev.1 in relation to this “substantial modification”

5. Engine Manufacturer

   Similarly to the interpretation provided in IACS MPC78/Rev-1, it shall be interpreted that the term “engine manufacturer” is the entity which applied for the engine certification.

Pre-certification of the engine - Procedure for issuance of EIAPP Certificate

Prior to installation on board, every marine diesel engine shall :

• be adjusted to meet the applicable NOx emission limits,

• have its NOx emission measured on a test bed in accordance with the procedures specified in the Ch.5 of the NOx Technical Code,

• be pre-certified by/on behalf of the Flag Administration.

This process is documented by the issuance of an EIAPP certificate by the flag state’s Administration or RO. It’s usually performed at the engine’s manufacturer workshop.

Where the pre-certification test results show that an engine fails to meet the NOx emission limits as required by regulation 13 of Annex VI, a NOx reducing device may be installed.

Where an engine cannot be pre-certified on a test bed, the engine manufacturer, ship-owner or shipbuilder should make an application to the certifying authority requesting on-board test. IACS UI MPC33 rev.2 gives the following interpretation:

“Engines undergoing an onboard certification test shall have a preliminary approved Technical File, pending the results of the emission test. If the result of the emission test does not comply with the applicable NOx regulation, the engines are to be re-adjusted to the compliance condition originally approved, if any, or the applicant is to apply to the Flag Administration for acceptance of further testing.”

Issuance of an EIAPP certificate means the initial compliance of an engine, an engine family or an engine group with the NOx Technical Code requirements.

Normal process

For each engine to which regulation 13 applies, a Technical File is issued by the manufacturer on completion of the tests performed on test bed. It is approved by Recognised Organisation (RO) (DA-MACH) or by a classification society member of IACS which is a recognized organization (RO) of the ship's flag Administration. The Statement of Compliance / EIAPP Certificate is then issued by the same, depending on the authorization granted.

The Technical File and EIAPP Certificate shall be available aboard the ship. The Technical File shall contain information necessary for subsequent surveys.

Engine family and engine group - Parent Engine

To avoid emission testing of each single engine, the NOx Technical Code allows the engine manufacturer to divide the product line into Engine Groups or Engine Families. One engine is then selected as a parent engine and tested. The selected engine shall be one that has the highest NOx emission level in the group and it shall be tested in the most adverse conditions that are allowed for in the Technical File of the engine. This test is then valid for all the engines in the group/family.

Member engines

The member engine should be provided by the manufacturer with its own dedicated Technical File. This Technical File should comply with the requirements displayed in the NOx technical Code and should contain a clear reference to its engine family and its parent engine's EIAPP Certificate.

The EIAPP Certificate/SoC of the member engine is issued by DA-MACH on the basis of its Technical File and the EIAPP Certificate/SoC of the parent engine sent by the attending surveyor.

In addition, the attending surveyor should perform an on board check to ascertain that the settings and engine components are complying with the information given in the Technical File.

Pre-certification of engine systems fitted with Selective Catalytic Reduction (SCR) Systems

Engine systems fitted with SCR should be certified in accordance with chapter 2 of the NTC 2008.

The procedures provided by Scheme A or Scheme B of Guidelines addressing additional aspects to the NOX Technical Code 2008 with regard to particular requirements related to marine diesel engines fitted with Selective Catalytic Reduction (SCR) Systems shall apply as appropriate. Below in are the different versions of SCR Guidelines:

(1) Apply to SCR systems installed on ships the keels of which are laid or which are at a similar stage of construction on or after 1 November 2025; or SCR systems installed on ships the keels of which are laid or which are at a similar stage of construction before 1 November 2025 which have a contractual delivery date of SCR systems to the ship on or after 1 May 2026 or, in the absence of a contractual delivery date, the actual delivery of the SCR system to the ship on or after 1 May 2026;

When the manufacturer chooses the Scheme B for pre-certification, the IAPP initial survey shall not be completed until the on board initial confirmation test provides compliant results.

As per 2011/2017/2025 SCR Guidelines, the applicant for certification is the entity responsible for the complete engine system fitted with SCR.Therefore and also in relation to Definitions, the applicant name is to be indicated in the EIAPP Certificate and its supplement, for entries "Engine Manufacturer" and “Name and address of manufacturer”.Consequently in the supplement of the IAPP Certificate, the applicant name shall be also used in table 2.2.1 for entry "Manufacturer and model", and shall be the same as the one indicated in EIAPP Certificate.

Certification of engines for vessels built before 1 January 2000

Certification of engines for vessels built before 1 January 2000

It may be that an owner wants to obtain the EIAPP Certificate for the diesel engines fitted on board even though these are not required by MARPOL Annex VI (vessels built before 1 January 2000, except those with the engines described in Revised NOx Technical Code - Existing engines installed on a vessel built between 1 January 1990 and 31 December 1999).

The following procedure shall then be followed :

The request of issuance of EIAPP Certificates and the approval of their corresponding individual Technical Files is normally to be applied by the engine manufacturer to Recognised Organisation (RO).

The following procedures may be followed to allow issuance of EIAPP Certificates to existing engines:

1. The engine's manufacturer ensures that the parent engine holds a Recognised Organisation (RO) EIAPP Certificate.

2. The engine's manufacturer applies to DA (DA-MACH Department) for issuance of EIAPP Certificates.

3. The engine's manufacturer supplies to DA with a Technical File for each concerned engine, for approval.

4. The engine's manufacturer proposes on-board verification procedures to check conformance of each engine with the relavant parameters of the parent engine.

5. Recognised Organisation (RO) field surveyor performs an on-board survey in accordance with the verification procedures as per d) here-above. Survey report/result should be sent back to the engine's manufacturer and DA for review.

If the survey result as per e) here-above is satisfactory, Recognised Organisation (RO) will issue the corresponding EIAPP Certificates to the engine's manufacturer.

The Technical File

To assist in engine survey procedures, every marine diesel engine covered by Annex VI and the NOx Technical Code must have a Technical File which identifies the engine's components, settings or operating values which influence exhaust emissions. The Technical File must be prepared by the engine manufacturer and approved by the relevant Certifying Authority, and is required to accompany an engine throughout its life on board the ship. It must be maintained in good order and not subjected to any unauthorised alteration, amendments, omission or deletions. The engine to which the Technical File refers is to be installed in accordance with the rating (kW and speed) and duty cycle as approved together with any limitation imposed by the Technical File.

The Technical File must, at a minimum, contain the following information :

1. Identification of those components, settings and operating values of the engine which influence its NOx emissions;

2. Identification of the full range of allowable adjustments or alternatives for the components of the engine;

3. full record of the relevant engine's performance, including the engine's rated speed and rated power;

4. a system of on-board NOx verification procedures to verify compliance with the NOx emission limits during on-board verification surveys;

5. a copy of the test report for an engine tested for pre-certification or a test report for an engine installed on board ship without pre-certification;

6. if applicable, the designation and restrictions for an engine that is a member of an engine group or engine family;

7. specifications of those spare parts/components which, when used in the engine, according to those specifications, will result in continued compliance of the engine with the NOx emission limits. As per IACS UI MPC45 rev.2 “It is considered that in this context “specification” shall be read as identification marking and as such the identification of a NOx influencing component by a manufacturer’s part number or specific marking scheme would be sufficient”;

8. Information related to SCR - 2011 / 2017 / 2025 SCR Guidelines, as applicable; and

9. the EIAPP Certificate, as applicable.

Initial on board survey

An initial on board survey is conducted by the Recognised Organisation (RO) surveyor after the diesel engine has been fitted. The aim of the survey is to ensure that the engine is maintained within the limits set by its Technical File and the NOx Technical Code.

During the on board survey, a few options are offered to investigate the status of the engine with regard to its NOx emissions.

1. Declaration from the engine manufacturer with regard to adjustments or modifications that could have been possibly made to the engine after its pre-certification and which could affect (or not affect) the NOx emission limits.

2. Demonstration, using the on-board NOx verification procedures contained in the Technical File, that :

   1. No adjustment or modification have been made, or

   2. That the adjustments or modifications are within the approved limits documented in the Technical File.

      If any adjustment or modification is found to be outside the approved limits, it shall be demonstrated that the NOx emissions still stay within the mandatory limits (Reg. VI / 13).

      Such verification is conducted through :

      • A reference to an emission test performed for the relevant engine group and covering the particular adjustments or modifications (Technical Code, 2.3.11), or

      • A simplified on board NOx measurement, or

      • A direct on-board investigation monitoring (this method cannot be used for the initial survey)

      Each diesel engine, whether MP or auxiliary engine, shall be submitted to the survey (except as stated in Untitled above)

What to do when there is no Technical File on board ?

Where a diesel engine falling under the Reg. 13 is not certified and/or is not accompanied by a Technical File, the IAPP Certificate cannot be issued. Owners / Managers should then contact the Engine Manufacturer. It may be that same type of engine (parent engine) could have been certified under the NOx Technical Code and the Manufacturer is holding relevant records and documents. If so, the Manufacturer could make sure that no modification has been brought to the engine which has not been certified and could prepare the Technical File. The engine and the Technical File should be subsequently certified and approved by Recognised Organisation (RO).

Recording of Diesel Engines subjected to the NOx Technical Code

At the fist survey conducted for certification purposes, diesel Engines are entered in part 2 of the Record of Equipment related to Ozone Depleting Substances and Nitrogene Oxides (NOx), Form AdWE1318.

They are also entered in paragraph 2.2 of the Supplement to the IAPP Certificate / Document of Compliance (Record of construction and equipment).

Acceptation of a Statement of compliance

1. Recognised Organisation (RO) issued the Statement of Compliance

   Where Recognised Organisation (RO) receives a request from a Flag Administration to issue an EIAPP Certificate for an engine which has been issued a SoC by Recognised Organisation (RO), then Recognised Organisation (RO) shall issue the EIAPP Certificate.

2. Statement of Compliance or EIAPP Certificate not issued by Recognised Organisation (RO)

   Where a Statement of Compliance (or the EIAPP Certificate) has not been issued by Recognised Organisation (RO), it may be accepted by Recognised Organisation (RO) provided that the Statement of Compliance (or the EIAPP Certificate) has been issued by a Class Society which is both :

   1. a member of IACS and

   2. an organization recognized (RO) by the Flag Administration the Ship is flying.

   The approved Technical File clearly corresponding to the Statement of Compliance (or to the EIAPP Certificate) must also be on board the Ship.

   A copy of same must be provided to Recognised Organisation (RO) as a condition to accept the Engine Certification. The copy is forwarded to the ship's connecting district and kept in the ship's file together with a copy of the Statement of Compliance (or to the EIAPP Certificate).

3. Engine provided with a Statement of Compliance

   The Statement of Compliance may be replaced by a EIAPP Certificate subject to satisfactory verification survey and Flag Administration authorization (Refer to relevant flag procedure). In such a case, the EIAPP Certificate will be issued by the attending Surveyor after completion of the on board verification survey. It is of utmost importance that the Surveyor ensures that there is coherency between the Document/Statement of Compliance (or the EIAPP Certificate) and the approved Technical File.

Change of Flag

Annual surveys

The scope of the annual survey depends on the method used. The check will be done using the on-board NOx verification procedures stated in the Technical File.

1. Documentation

   1. Confirm that there are Engine International Air Pollution Prevention (EIAPP) Certificates for each engine, required to be certified, as described in Chapter 2.1 of the NOx Technical Code;

   2. Confirm that there is on board an approved technical file for each engine required to be certified;

   3. Confirm that there is a record book of engine parameters for each engine required to be certified in the case where the engine parameter check method is used as a mean of onboard NOx verification (NOx Technical Code, paragraph 6.2.3);

2. Nitrogen oxide emissions from each Diesel engine

   1. If engine parameter check method is used :

      The engine parameter check method of survey mainly involves confirming that the NOx sensitive components as listed in the Technical File have either not been changed or if changed have been replaced with direct replacement or components that have been agreed by the Certifying Authority to have the same NOx emission characteristics. Where a Certifying Authority has agreed that a component that is not a direct replacement can be used in that particular engine the Technical File should be amended to include this information.

      The surveyor will require that certain NOx sensitive components are checked during the survey which may require some dismantling of the engine. The surveyor will also check documentation which will include the Technical File and the Record Book of Engine Parameters. The surveyor will also check the engine room log book to ensure that the engine has been operated within the operating limits specified in the Technical File.

      NOx sensitive components can either be marked with a part number or an IMO number but the number must be the same or directly traceable to the number in the Technical File.

      In addition to the Technical File, any engine installed on a ship which utilises the parameter check method option as the onboard NOx verification procedure , is required to maintain the following documentation on board :

      • A record book of engine parameters for recording all of the changes made relative to an engine's components and settings;

      • An engine parameter list of an engine's designated components and settings and/or the documentation of an engine's load-dependent operating values submitted by the engine manufacturer and approved by the certifying authority; and

      • Technical documentation of an engine component modification when a modification is made to any of the engine's designated engine components.

      • Records on periodical spot checks or monitoring as specified by the applicant in the technical file and related to the deterioration rate of SCR performance (e.g. exchange condition for SCR catalyst blocks and recommended exchange time of SCR catalyst blocks). As per 2017 / 2025 SCR Guidelines, the frequency of periodical spot checks is to be defined by the applicant considering the expected deterioration of the catalyst. The frequency for spot-checks should be at least after installation and once every 12 months.

      Descriptions of any changes affecting the designated engine parameters, including adjustments, part replacements and modifications to engine parts, must be recorded chronologically in the engine's Record Book of Engine Parameters. These descriptions must be supplemented with any other applicable data used for the assessment of the engine's NOx levels. Any intended change to the NOx sensitive components or setting outside the limits listed in the Technical File must be approved by the relevant Certifying Authority. Routine replacement of engine components by parts specified in the Technical File that do not alter emission characteristics are not regarded as a “substantial modification'' regardless of whether one part or many parts are replaced.

   2. If the simplified method is used :

      • Review engine documentation contained in the technical file;

      • Confirm that the test procedure has been approved by the Administration;

      • Confirm that the analysers, engine performance sensors, ambient condition measurement equipment, span check gases and other test equipment are the correct type and have been calibrated in accordance with the NOx Technical Code;

      • Confirm that the correct test cycle, as defined in the engine’s technical file, is used for this onboard confirmation test measurements;

      • Ensure that a fuel sample is taken during the test and submitted for analysis;

      • Witness the test and confirm that a copy of the test report has been submitted for approval on completion of the test.

   3. If the direct measurement and monitoring method is used :

      • Review engine documentation method and technical file and verify that the direct measurement and monitoring manual is approved by the Administration;

      • The procedures to be checked in the direct monitoring and measure method and the data obtained as given in the approved onboard monitoring manual should be followed.

Frequently asked questions

See. Annex Nitrogene oxydes (NOx)

Revised NOx Technical Code - Existing engines installed on a vessel built between 1 January 1990 and 31 December 1999

The revised NOx Technical Code entered into force in 1 July 2010. The new revision includes requirements governing NOx emissions from ships constructed from 1 January 1990 to 1 January 2000.

As from 1 July 2010, an engine installed on a vessel built between 1 January 1990 and 31 December 1999 may be required to meet the Tier I (as per Annex VI, regulation 13 (7.4)) if it has a displacement at or above 90 liters per cylinder, and has a power output of more than 5,000 kW. Such an engine is required to meet the Tier I standards if a remanufacture system (called an “Approved Method”) has been certified for it.

Please refer to Resolution MEPC.243(66) - 2014 Guidelines on the Approved Method process.

These existing engines need to be provided with an EIAPP certificate or equivalent (dependant on the Flag state requirements). The certificate shall confirm either that Pre-2000 Engine complies with the applicable NOx emission limit or that an alternative emission reduction option as approved shall be applied.Necessary engine adjustments or the fitting of NOx-reducing kits must take place no later than the first renewal survey that occurs 12 months or more after approval of an applicable method. However, if the supplier of an Approved Method is not able to deliver this at the time of this renewal survey, installation may take place at the next annual survey. Detailed requirements for the approval of NOx-reducing methods have been included in the revised NOx Technical Code.

Sulphur oxydes (SOx)

(Reg.VI/14)

Sulphur content

• The sulphur content of any fuel oil used on board shall not exceed 3.5% m/m, and 0.50% sulphur limit on 1 January 2020 see IMO 2020 Global 0.50% m/m Sulphur cap limit

• The sulphur content of any fuel oil used when operating in a SECA (see SOx Emission Control Areas (SECA)) shall not exceed 0.10% m/m on and after 1 January 2015.

These limits stand, irrespective of the fuel grade or the type of combustion machinery in which the fuel oils are to be used.

Revised Annex VI - New Limits for Sulphur Content in Fuel Oil

The revised Annex VI of MARPOL and the revised NOx Technical Code entered into force in 1 July 2010. The new revision substantially tightens the NOx and Sulphur limits compared to the previous version of this Annex, and also includes requirements governing NOx emissions from ships constructed from 1 January 1990 to 1 January 2000.

The new limits for sulphur content in fuel oil is :

• 3.50 % m/m on and after 1 January 2012

• 0.50 % m/m on and after 1 January 2020

In SECAs:

• 1.00 % m/m on and after 1 July 2010

• 0.10 % m/m on and after 1 January 2015

Sulphur scrubbing is still an acceptable method for compliance, and there is no HFO ban. In order to confirm that the refinery industry can meet the demand for low sulphur fuels by 2020, a review clause has been introduced scheduling a fuel availability review to be completed by 2018.

IMO (MEPC 70 – October 2016) agreed to "1 January 2020" as the effective date of implementation for ships to comply with global 0.50% m/m sulphur content of fuel oil requirement, and adopted resolution MEPC.280(70) on the Effective date of implementation of the fuel oil standard in regulation 14.1.3 of MARPOL Annex VI.

IMO 2020 Global 0.50% m/m Sulphur cap limit

1. Compliance dates

   • 1st January 2020 - Implementation date of global sulphur limit of 0.50% m/m for the fuel oil standard (regulation 14.1.3 of MARPOL Annex VI) See Revised Annex VI - New Limits for Sulphur Content in Fuel Oil

   • 1st March 2020 - Carriage ban of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship

     IMO (MEPC 73 – October 2018) adopted complementary MARPOL amendment to prohibit the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship - unless the ship uses an alternative compliance method (such as an exhaust gas cleaning system "scrubber") accepted by the flag State as an alternative means to meet the sulphur limit requirement. Refer to Exhaust gas cleaning system (EGCS)

     The amendment (Resolution MEPC.305(73)) will enter into force on 1 March 2020)

   Fuel oil of emergency equipment:IMO approved MEPC.1/Circ.795/Rev.4 - unified interpretations to MARPOL Annex V which clarify that Regulation 14.1 of MARPOL Annex VI for the prohibition on carriage of non-compliant fuel oil should be applied to the fuel oil of emergency equipment.

2. Implementation of 2020 Global Sulphur limit

   For a consistent implementation, IMO (MEPC 74 – May 2016) adopted Resolution MEPC.320(74) - 2019 Guidelines on consistent implementation of 0.50% sulphur limit under MARPOL Annex VI – Please refer to the attached file resolution MEPC.320(74).These Guidelines are intended for use by Administrations, port States, shipowners, shipbuilders and fuel oil suppliers. They cover the

   • 2020 ship Implementation

   • Impact on fuel and machinery systems

   • Verification issues and control mechanism and actions

   • Fuel oil non-availability including the FUEL OIL NON-AVAILABILITY REPORT (FONAR) standard format

   • Possible safety implications relating to fuel oils meeting the 0.50% m/m sulphur limit

   Furthermore, IMO (MEPC 73 -October 2018) approved MEPC.1/Circ.878 on Guidance on the development of a ship implementation plan for the consistent implementation of the 0.50% sulphur limit under MARPOL Annex VI. Refer to attached file Circular MEPC.1/Circ.878Circular MEPC.1/Circ.878 para.4 indicates:A ship implementation plan is not a mandatory requirement. A lack of a ship implementation plan or an incomplete ship implementation plan should not be considered as "clear grounds" for a more detailed inspection.

3. Prohibition on the carriage of non-compliant fuel oil for combustion purposes for propulsion or operation on board a ship – survey and certification

   Amendment to regulation 14.1.3 of MARPOL Annex VI (Resolution MEPC.305(73)) enters into force on 1 March 2020. It requires that sulphur content of fuel oil used or carried for use on board a ship shall not exceed 0.50% m/m.2019 Guidelines on consistent implementation of 0.50% sulphur limit under MARPOL Annex VI – MEPC.320(74) indicates that:4.1.1 When undertaking a survey in accordance with regulation 5 of MARPOL Annex VI, the Administration should conduct a survey of a ship to verify that the ship complies with the provisions to implement the 0.50% sulphur limit. In particular, the Administration should check whether the ship carries compliant fuel oils for use, based on the Bunker Delivery Note (BDN) on board, any other document or fuel oil samples as appropriate consistent with the provisions of regulation 18 of MARPOL Annex VI. If carriage of HSHFO for use is identified, the Administration should check whether regulation 3.2, regulation 4 of MARPOL Annex VI are applied to the ship, or if the ship encountered a fuel availability problem and is operating pursuant to regulation 18.2 of MARPOL Annex VI.NB: Consequential amendment to the form of IAPP Certificate enters into force on 1 March 2020 to record compliance with the provisions related to 0.50% sulphur limit. IACS UI MPC 101 rev.1 clarifies that:

   “Section 2.3 of the Supplement ("as documented by bunker delivery notes") allows for an "x" to be entered in all of the relevant check boxes recognizing that the bunker delivery notes, required to be retained on board for a minimum period of three years, provide the subsequent means to check that a ship is actually operating in a manner consistent with the intent as given in section 2.3.”

   The surveyor will re-issue the supplement at the opportunity of the first IAPP survey (annual, intermediate, renewal) occurring after the date of the entry into force of the amendments, unless provided with written instruction by the Administration to apply a different application criterion.

Procedures for sampling and verification of the sulphur content of fuel oil - DESIGNATING IN-USE FUEL OIL SAMPLING POINT(S)

Consistent implementation and verification of 2020 Global Sulphur limit

To support consistent implementation and verification of the 0.50% sulphur limit, IMO adopted amendments to MARPOL Annex VI as Resolution MEPC.324(75) for an entry into force on 1 April 2022. These amendments define 3 different types of fuel oil sampling:- “MARPOL delivered sample” already required, and, two new samples, namely :- “In-use sample” ,and - “On board sample”. Refer to MARPOL annex VI/reg.2 for the definition of these type of samples.The new provisions require that:The onboard sample shall be drawn taking into account the guidelines developed by the IMO. Refer to the 2020 Guidelines for on board sampling of fuel oil intended to be used or carried for use on board a ship (MEPC.1/Circ.889).The in-use sample shall be drawn taking into account the guidelines developed by the IMO . Refer to the 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships (MEPC.1/Circ.864/Rev.1)Amendments include mandatory provisions for the fitting or designating of “in use” fuel oil sampling points – refer to below In-use fuel oil sampling point(s)

In-use fuel oil sampling point(s)

New regulation14.10 as amended by resolution MEPC.324(75) requires sampling point(s) to be fitted or designated for the purpose of taking representative samples of the fuel oil being used on board the ship taking into account the 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships (MEPC.1/Circ.864/Rev.1).

New provisions in regulation 14.10 (i.e. fitting or designating of “in use” fuel oil sampling points) apply to:- New ships constructed on or after 1 April 2022 upon delivery; and - Existing ships, constructed before 1 April 2022, not later than the first IAPP renewal survey on or after 1 April 2023 (regulation 14.11)

Recognised Organisation (RO) process for survey and certification

For ships fitted with designated sampling point(s) in accordance with regulation 14.11 (i.e. retroactive application for existing ships constructed before 1 April 2022), the Recognised Organisation (RO) process for survey and certification to be carried out not later than the first IAPP renewal survey on or after 1 April 2023, is as follows:

1. Plan review

   For each ship (ship > 400GT with IAPP Certificate), the ENGINES FUEL OIL PIPING DIAGRAM is to be reviewed by the LPO to confirm compliance with the provisions of 2019 Guidelines for on board sampling for the verification of the sulphur content of the fuel oil used on board ships (MEPC.1/Circ.864/Rev.1). Refer to flag procedures for possible specific Flag State instructions.

2. Survey to confirm onboard installation

   The Surveyor shall verify that fitted or designated “in use” sampling point(s) fulfil all of the following conditions (provisions of MEPC.1/Circ.864/Rev.1):.1 be easily and safely accessible;.2 take into account different fuel oil grades being used for the fuel oil combustion machinery item;.3 be downstream of the in-use fuel oil service tank;.4 be as close to the fuel oil combustion machinery as safely feasible taking into account the type of fuel oil, flow-rate, temperature, and pressure behind the selected sampling point;.5 be clearly marked for easy identification and described in either the piping diagram or other relevant documents; (NB: have been duly reported in ENGINES FUEL OIL PIPING DIAGRAM reviewed by LPO).6 each sampling point should be located in a position shielded from any heated surface or electrical equipment and the shielding device or construction should be sturdy enough to endure leaks, splashes or spray under design pressure of the fuel oil supply line so as to preclude impingement of fuel oil onto such surface or equipment; and.7 the sampling arrangement should be provided with suitable drainage to the drain tank or other safe location.

3. Recording of designated “in use” sampling point(s) in the supplement to IAPP Certificate

   The supplement to International Air Pollution Prevention Certificate (IAPP Certificate) has been amended by resolution MEPC.324(75) to include new provisions to be recorded, as appropriate. Revised supplement to IAPP Certificate applies and is available in ASMS Certificate from 1 April 2022.Surveyor shall, not later than the first IAPP renewal survey on or after 1 April 2023, record, as appropriate, the new provisions of the supplement to IAPP Certificate (i.e. new paragraphs 2.3.4 and 2.3.5).

SOx Emission Control Areas (SECA)

1. A lower limit is placed in special areas, SOx emission control areas (SECA), where the sulphur content shall not exceed 0.10% m/m on and after 1 January 2015, unless an equivalent arrangement approved in accordance with regulation 4.1 of MARPOL Annex VI (e.g. an exhaust gas cleaning system (EGCS-SOx)) is installed on board and is at least as effective in terms of SOx emission reductions as compared to using a fuel oil with a sulphur content limit value of 0.10% m/m.

   The ship owner is to consult with the manufacturers of the machinery concerned on board the ship (propulsion engines, auxiliary engines, boilers, fuel feed/circulating/transfer/supply pumps, purifiers with their feed pumps, etc.), whether their equipment is suitable to operate with low sulfur fuel or not, without performing any modification. Any proposed modifications must be submitted to the concerned LPO in coordination with MOC.

2. The Baltic Sea (as defined in regulation 1.11.2 of MARPOL Annex I), the North Sea (definition in MARPOL, Annex V, reg.5(f), which also includes both the Channel and the Skagerrak) and the North American area and the United States Caribbean sea area (as described by the coordinates provided in appendix VII to the MARPOL Annex VI) are SECA.

   Sulphur content requirement not exceeding 0.10% m/m on and after 1 January 2015 applies to these above listed areas.

3. MED SOx emission control areas (SECA)IMO adopted resolution MEPC.361(79) establishing a Mediterranean Emission Control Area (ECA) for sulphur oxides and particulate matter.The amendments will enter into force on 1 May 2024. However, ships operating in this ECA are exempted from the sulphur oxide and particulate matter requirements for the first 12 months.And from 1 May 2025 the sulphur content requirement not exceeding 0.10% m/m applies to this area.

4. Canadian Arctic and the Norwegian Sea SOx emission control areas (SECA)

   Amendments to MARPOL Annex VI to designate the Canadian Arctic and the Norwegian Sea as Emission Control Areas (ECAs) for Sulphur Oxides and Particulate Matter, enter into force on 1 March 2026. (Resolution MEPC.392(82)).In accordance with MARPOL Annex VI Regulation 14.7, a 12-month grace period from the entry into force of the amendments (i.e. 1 March 2026) applies to newly designated ECAs to allow for logistical adjustments in fuel supply. And from 1 Mach 2027 the sulphur content requirement not exceeding 0.10% m/m applies to this area.

Fuel oil tanks

1. Fuel oil change over – SECA

   It is likely, at least as a first step, that the majority of ships will comply with the SECA requirements limiting the sulphur fuel oil content by the use of low sulphur residual fuel or gas oils. It is therefore necessary to ensure that ships entering a SECA have both the segregate bunker capacity to carry those low sulphur residual fuel or gas oils and the means to change over from the standard sulphur fuel (i.e., not exceeding 3.5% m/m and 0.50% sulphur limit on 1 January 2020, see IMO 2020 Global 0.50% m/m Sulphur cap limit) to the lower sulphur fuel (i.e., not exceeding 0.10% m/m on and after 1 January 2015) before they enter the SECA.

   Where tanks intended for fuel containing the standard sulphur content and tanks intended for low sulphur fuel are fitted, the Surveyor may be requested to verify that fuel switching "Change over" arrangements or procedures are provided and operational. The attached file : "LSFO changover - Guidelines to surveyors Rev.2.doc " provides guidelines on change over procedures, witnessing of fuel changeover and verification of test procedures.

Exhaust gas cleaning system (EGCS)

Compliance framework of MARPOL Annex VI

Regulation 14 of Annex VI requires ships to use fuel oil with a sulphur content not exceeding that stipulated in regulations 14.1 or 14.4. However, regulation 4 allows, with the approval of the Administration, the use of an alternative compliance method at least as effective in terms of emission reductions as that required by MARPOL Annex VI taking into account guidelines developed by the IMO.Equivalents (e.g. EGCS) as set forth in regulation 4 of MARPOL Annex VI needs to be confirmed by the flag Administration of each vessel onto which the equipment is to be installed on a case-by-case basis.

2015 Guidelines for exhaust gas cleaning systems – MEPC.259(68) - superseded see 2.5.7.3

IMO adopted the 2015 Guidelines for exhaust gas cleaning systems MEPC.259(68) see attached files “MEPC.259(68)”. These guidelines are recommendatory in nature, however, Administrations are invited to base the implementation of the relevant requirements of regulation 4 of MARPOL Annex VI on them.The purpose of these guidelines is to specify the requirements for the testing, survey, certification and verification of EGC systems under regulation 4 of MARPOL Annex VI to ensure that they provide effective equivalence to the requirements of regulations 14.1 and 14.4 of MARPOL Annex VI.Refer to EGCS - Flow chart of compliance process for installation and initial survey

2021 Guidelines for exhaust gas cleaning systems – MEPC.340(77)

IMO adopted 2021 Guidelines for exhaust gas cleaning systems, to update the last version adopted in 2015.The revision is aimed at enhancing the uniform application of the guidelines, in light of recent technical developments and experience gathered from approvals and operation of such alternative compliance systems. Among others the following modifications have been introduced:

• Revised minimum recording frequency, new parameters and applicable limits values to be recorded in Data recording and processing device (para. 4.4.7, 5.4.2, 7.2 and 10.4)

• For the emission testing, the extractive sample systems should be verified to be free of ingress leakage (para.6.10)

• Nitrate analysis process has been modified allowing to report nitrate concentrations gathered from similar installations instead of always performing individual water sampling and analysis (para. 10.1.5.3)

• Delay for Nitrate analysis has been clarified (i.e. within the first three months of operation after installation/initial survey and three months prior to each renewal survey) (para. 10.1.5.2)

• Record book to be maintained on board the ship for a minimum period of three years after the last entry has been made (para.4.4.9 and 5.7.1)

• Provisions in relation to non-compliant conditions or temporarily ongoing compliance as per 8.2.8 of 2021 guidelines to be included in the OMM, ETM and SECP (para. 4.2.2.1, 5.6.1, 8.2.8, 8.2.10 and 9.1.4)

The updated guidelines are applicable to:

1. EGCSs installed on ships the keels of which are laid or which are at a similar stage of construction on or after 1 June 2022; or

2. EGCSs installed on ships the keels of which are laid or which are at a similar stage of construction before 1 June 2022, which have a contractual delivery date of EGCS to the ship on or after 1 June 2022 or, in the absence of a contractual delivery date, the actual delivery of the EGCS to the ship on or after 1 June 2022; or

3. Amendments as those specified in paragraphs 4.2.2.4 or 5.6.3 of the 2021 guidelines (i.e. EGCS Technical Manual “Scheme A” or “Scheme B” which affect the performance of the EGCS with respect to emissions to air and/or water) to existing EGCS undertaken on or after 1 June 2022.

Approval of EGCS

Recognised Organisation (RO) acting as a RO on behalf of the ship’s Flag Administration, will certify and approve EGCS covering the statutory requirements of MARPOL annex VI taking into consideration guidelines referenced in 2015 Guidelines for exhaust gas cleaning systems – MEPC.259(68) - superseded see 2.5.7.3 or 2021 Guidelines for exhaust gas cleaning systems – MEPC.340(77) as applicable.

(Any application for EGCS installation and approval shall be submitted to DA_MACH - Refer to the related technical procedure)

Approval scheme for statutory requirements

2015 and 2021 Guidelines for exhaust gas cleaning systems permit two approval schemes:

1. Scheme A

   Under this scheme, serial manufactured units is possible by certifying one EGC unit as meeting the Certified Value specified by the manufacturer (e.g. the emission level the unit is capable of achieving on a continuous basis).

2. Scheme B

   Under this scheme, a case by case EGC unit is certified based on the principle of continuous exhaust gas monitoring of the EGCS, approved by the Administration or Recognised Organisation (RO) (DA_ELEC).

Both Scheme A and scheme B are subject to an initial survey. It is also subject to periodic survey as part of the ship’s International Air Pollution Prevention Certification.

Initial survey process

Initial survey is divided in two parts:

• Survey after the installation of the EGCS

• Survey at the first port of call

Refer to Groups and Codes

At the completion of a satisfactory initial survey, MOC shall submit a “confirmation letter” to the Flag Administration for their acceptance of the equivalency under the provision of regulation 4 of MARPOL Annex VI. See model of confirmation letter in the attached file: “EGCS model Confirmation letter to the Flag schemeB_rev0.docx” for EGCS installed in compliance with 2015 guidelines or “EGCS model Confirmation letter to the Flag schemeB_2021guidelines_rev0.docx” for EGCS installed in compliance with 2021 guidelines.

Endorsement of the IAPP Certificate after the initial survey

Endorsement of the Supplement to the ship's International Air Pollution Certificate is subject to:

• Satisfactory completion of the two parts of the initial survey (as an occasional IAPP survey)

• Agreement received by the Flag Administration for the use of the alternative compliance method following the submission by Recognised Organisation (RO) of a confirmation letter

• Section 2.6 “equivalents”

  Where the following information shall be recorded: System or equipment: Equipment served by scrubber e.g. main engine, boilers and auxiliary engines.Equivalent use: Information for the scrubber system, such as maker, model number, system type (open loop, closed loop or hybrid) and serial number, as well as the standard that the scrubber has been approved to (e.g. MEPC.259(68) or MEPC.340(77)), are to be included.Approval reference: Information on Recognised Organisation (RO) confirmation letter and flag Administration evidence of acceptance, are to be included in this column.

• Section 2.3.1.2 and Section 2.3.2.2 as appropriate

The following sections of the Supplement to the ship's International Air Pollution Certificate shall be duly completed:

Nitrates test at renewal survey of IAPP certificate

Within three months prior to each renewal survey, a sample of the discharge water from each EGCS shall be drawn and analysed for nitrate content and results and sent to DA_MACH for their assessment (MSC340(77) para.10.1.5.1)

EGCS malfunction

IMO approved MEPC.1/Circ.883/Rev.1 - Guidance on indication of ongoing compliance in the case of the failure of a single monitoring instrument, and recommended actions to take if the exhaust gas cleaning system (EGCS) fails to meet the provisions of the EGCS Guidelines This circular revokes MEPC.1/Circ.883

This guidelines covers issues related to - System malfunction- Short-term exceedances- Interim indication of ongoing compliance in the case of sensor failure- Notifications to relevant AuthoritiesThe provisions of this guidelines shall be taken into account at surveys to ensure that EGC performance is maintained and that the unit is used as required.

NB : As per MEPC.1/Circ.883/Rev.1 provisions, EGCS malfunction* that lasts more than one hour or repetitive malfunctions have to be reported by the owner to Flag Administration and port Stateʹs Administration along with an explanation of the steps the ship operator is taking to address the failure.*An Exhaust Gas Cleaning System (EGCS) malfunction is:- any condition that leads to an emission exceedance, with the exception of the short-term temporary emission exceedance cases described in sections 7 and 8 of MEPC.1/Circ.883/Rev.1, or- an interim indication of ongoing compliance in the case of sensor failure described in sections 9 to 11 of MEPC.1/Circ.883.For both cases, i.e. EGCS breakdown or sensor failure that lasts more than one hour or repetitive malfunctions, shipowners are requested to provide Recognised Organisation (RO) with - information on the malfunction (record book indicating the date/position and description of malfunction) and,- the implementation of the action plan, with an explanation of the steps the ship operator is taking to address the failure, in accordance with the approved statutory document (ETM, OMM, SECP) / the provisions MEPC.1/Circ.883/Rev.1 para. 4, 5, 6 and 11 as applicable.in order to assess the technical option to the Flag about the compliance or not to MARPOL Annex VI.

Bunker delivery notes

(See Bunker delivery note (BDN))

The Surveyor may review at random the log entries for the dates and place of bunkering operations and the corresponding Bunker delivery notes for the use of the pertinent sulphur content fuel for the area of operation or for the use of EGCS and verify that the changeover to and from low sulphur fuel during transit through a SECA are duly recorded. When not prescribed by the Administration, this information could be contained in the engine-room log-book, the deck log-book, the official log-book, the oil record book or a separate log-book solely for this purpose.

Recording compliance with sulphur content requirements in SECA

1. The means retained to comply with sulphur content requirements in SECA (fuel oil with a sulphur content as documented by bunker delivery notes or an equivalent arrangement approved in accordance with regulation 4.1 of MARPOL Annex VI) is entered in paragraph 2.3.2 of the Supplement to the IAPP Certificate / Document of Compliance (Record of construction and equipment).

   A note on Marine Fuel Oil is displayed in Sulfur content in Marine Fuel Oil on which the minimum sulfure content of marine fuel is given according to ISO 8217 – 2005.

2. At the point of entry into a SECA, if ships do not have a system in place to reduce emissions, they must already be using fuel with a sulphur content not exceeding 0.10% m/m on and after 1 January 2015. To achieve this, procedures should be in place so that the change-over from high-sulphur fuel to low-sulphur fuel is completed before entry into the SECA.

   The information recorded should be along these following lines, when any fuel oil changeover operation is completed prior to the entry into an emission control area or commenced after exit from such an area:

   • Tanks used

   • Volume of low-sulphur fuel oils in each tank (less than or equal to 0.10% m/m sulphur on and after 1 January 2015)

   • Date when any fuel oil changeover

   • Time

   • Position of ship

   The above should be recorded, either in a separate or existing logbook (as prescribed by the Administration), kept and maintained for any third party inspections and for ease of use.

   These details should only be recorded once it is determined that the fuel oil with a sulphur content of less than or equal to 0.10% m/m (on and after 1 January 2015) is being burned .

   This process should be completed before the vessel enters the SECA or commenced after exit from such an area.

   Procedures and/or instructions should be placed onboard to this effect for the use of the personnel involved in this function.

Frequently asked questions

See Annex Sulphure oxydes (SOx)

Volatile organic compounds (VOCs)

(Reg.VI/15)

Untitled

A country which is a Party to the Convention may designate ports or terminal under its jurisdiction as areas in which the emissions of volatile organic compounds from cargo tanks of oil tankers are controlled. The Party shall advise the IMO and the notification shall include information of the size of the tankers to be controlled and on cargoes requiring vapour emission control systems. The Party shall ensure that vapour emission control system are operated safely and so as to avoid any delay to the ship.

Untitled

The tankers subjected to vapour emission control in such ports and terminals shall be equipped with a vapour emission control system approved by the administration taking into account the standard developed by the IMO.

Untitled

Where a vapour control emission system is provided on board, the Surveyor makes sure that it has been approved by the Administration or on its behalf by a recognized oganization with regard to MSC/Circ.585 Standard for Vapour Emission Control System. The Surveyor conducts an examination of the system to ensure, as far as practicable, that the piping is in satisfactory condition and the associated equipment such as alarms, gauging system, overflow control system, are in working condition.

Untitled

Where a vapour emission control system is fitted, it is entered in paragraph 2.4 of the Supplement to the IAPP Certificate / Document of Compliance (Record of construction and equipment).

Associated document : Circular MSC/Circ.585 (‘Standard for Vapour Emission Control System’).

Untitled

Revised Marpol Annex VI - Reg.15.6 - Tankers carrying crude-oil shall have onboard and implement of VOC management plan approved by the Administration.

Such plans are approved by DA-SAFE.

Frequently asked questions

See Annex Volatile organic compounds (VOCs)

Incinerators - Shipboard incineration

(Reg.VI/16)

Untitled

1. Incinerators installed on board a ship as from 1 January 2000 shall :

   • comply with provisions of appendix IV (The Appendix IV to the Annex provides for Type Approval and Operating Limits of Shipboard Incinerators),

   • be approved by the administration against provisions of resolution MEPC.76(40) as amended by resolution MEPC.93(45) or resolution MEPC.244(66).

2. An operating manual shall be provided by the manufacturer.

   The personnel responsible for the operation of the incinerator shall be trained and capable of implementing the guidance provided in the manual.

3. The Surveyor makes sure that a copy of the certificate of type approval of the incinerator and an operating manual prepared by the manufacturer, are available on board. He conducts an external examination to ensure, as far as practicable, that the incinerator, its alarms and associated equipment are in satisfactory and working condition.

4. Incinerators which have been installed before 1 January 2000 are not subjected to certification and inspection within the scope of the MARPOL Annex VI.

   They can, of course, still be used provided that they are operated within the limits specified by Reg.VI/16 (See Prohibition of incineration of several substances).

5. Where an Incinerator is fitted, it is entered in paragraph 2.5 of the of the Supplement to the IAPP Certificate/Document of Compliance (Record of construction and equipment).

Prohibition of incineration of several substances

1. As from the entry into force of the Annex, the incineration of the following substances is prohibited :

   • residues from Marpol Annex I, II and III cargoes (and related packed materials),

   • polychlorinated biphenils (PCBs),

   • garbage (defined in MARPOL, Annex V) containing trace of heavy metals,

   • refined petroleum products containing halogen compounds.

2. Incineration of polyvinyl chlorides (PVCs) is prohibited, except in incinerators issued with an IMO Type Approval Certificate (as per reg.VI/16).

3. Incineration of sewage sludge and sludge oil generated during the normal operation of the ship may also take place in the main or auxiliary plant or boilers outside ports, harbours and estuaries.

4. The prohibition does, of course, stand whether or not the ship is operating an approved incinerator.

   In any case, where an incinerator is fitted or incineration takes place in boilers, the Surveyor confirms, from the records, as far as practicable, that no prohibited substance is incinerated.

Fuel oil quality - Bunker delivery note - Local suppliers of oil fuel

(Reg.VI/18)

Fuel oil used on board ships

The fuel oil used on board ships shall meet the provisions of Regulation 18.3 which includes among others the following criteria :

• is blends of hydrocarbons deriving from petroleum refinings,

• is free from inorganic oils,

• does not include added substances or chemical wastes,

• does not exceed the applicable sulphur content set forth in regulation 14,

• doe not cause an engine to exceed the NOx emission limits set forth in regulation 13,

• does not contain inorganic acid,

• does not jeopardize the safety of the ship or does not affect the performance of the machinery,

• is not harmfull to the personnel,

• does not contribute to additional air pollution.

Bunker delivery note (BDN)

1. Application

   As per regulation 18.5.1, each ship subject to regulation 5 and 6 (i.e. surveys and certification) is required to record details of fuel oil delivered to and used on board by means of a bunker delivery notes.IACS UI MPC29 and MEPC.1/Circ.795/Rev.3 give the following interpretation:For the application of these regulations, they should be interpreted as being applicable to all ships of 400 gross tonnage or above and, at the Administration's discretion, to ships of less than 400 gross tonnage.

   As per regulation 18.5.2 as amended by resolution MEPC.385(81) and which enters into force on 1 August 2025, it is clarified that BDN for low-flashpoint fuel or gas fuel shall comply with a number of information in respect to those included in Appendix V of MARPOL Annex VI (i.e. items 1 to 6 + density + declaration by fuel supplier + sulphur content).

2. The details of fuel to be used on board for combustion purposes delivered to and used on board are recorded through a bunker delivery note.

   The bunker delivery note contains information as required by Appendix V of MARPOL Annex VI.

   Amendments to the information in the bunker delivery note (BDN) – resolution MEPC.286(71). From 1st January 2019, bunker delivery notes must include a new entry (selection box) for the “purchaser’s specified limit value” of the sulphur content of the fuel oil supplied. The amendments to Appendix V of MARPOL Annex VI are intended to address situations where the fuel oil supplied does not meet low sulphur requirements, but has been supplied to a ship which is using an alternative compliance method permitted under regulation 4 of MARPOL Annex VI (“Equivalents” e.g. EGCS refer to para. Exhaust gas cleaning system (EGCS)) to reduce the sulphur oxide emissions of the ship in order to comply with MARPOL requirements.

   Amendments to the information in the bunker delivery note (BDN) – MEPC.362(79). From 1st May 2024, bunker delivery notes must include a new item to require the flashpoint of fuel oil or a statement that the flashpoint has been measured at or above 70ºC.

3. The bunker delivery note is:

   • prepared by the fuel oil supplier and handed over to the ship's Master or his representative.

   • include a declaration signed and certified by the fuel oil supplier's representative that the fuel oil supplied is in conformity with regulation 18.3 (i.e. Fuel Oil Quality) of MARPOL Annex VI and that the sulphur content of the fuel oil supplied does not exceed the relevant provisions

   • kept on board for a period of 3 years after the date of delivery and is made readily available for inspection.

   • accompanied by a sample of the delivered fuel oil drawn in accordance with IMO Guidelines for the sampling of fuel oil for determination of compliance with MARPOL Annex VI and SOLAS chapter II-2 (MSC-MEPC.2/Circ.18, which revokes resolution MEPC.182(59)).

   The sample is sealed and signed by the fuel oil supplier’s representative and the Master or officer in charge of bunker operations on completion of the bunkering operation. The retained sample is kept on board until the fuel oil is substantially consumed but for not less than 12 months from the delivery date.

4. Application of regulation 18.3 for biofuel and synthetic fuel

   IMO approved the UI of regulation 18.3 of MARPOL Annex VI in general and specifically to its paragraph 18.3.2.2, to facilitate harmonized application of MARPOL Annex VI and the NTC with respect to the potential impacts on regulation 13 of MARPOL Annex VI NOX emissions of using biofuels and synthetic fuels. The updated consolidated text is set out in circular MEPC.1/Circ.795/Rev.7.

5. The Surveyor makes sure that bunker delivery notes and associated fuel oil sample are kept on board, as requested as from the delivery dates.

Local fuel oil suppliers

Fuel oil suppliers shall be recorded on a register maintained by the local "appropriate authorities".

In other words, a supplier which is not registered should not provide fuel oils to a ship flying the flag of a country which is a party to the MARPOL Annex VI.

Fuel oil suppliers are required to:

• provide bunker delivery note and sample of fuel oil,

• keep copy of the bunker delivery note for three years.

In order to assist fuel oil purchasers/users in assuring the quality of fuel oil delivered to, and used on board ships, with respect to both compliance with the MARPOL requirements and the safe and efficient operation of the ship, IMO published MEPC.1/Circ.875 - “Guidance on best practice for fuel oil purchasers/users for assuring the quality of fuel oil used on board ships”.

IAPP certification and survey

The following ships and unit are subjected to certification (IAPP Certificate) :

• Ships of 400 GT and above, engaged in voyages to ports or offshore terminals under the jurisdiction of other parties,

• Platforms and drilling rigs, engaged in voyages to ports or offshore terminals under the jurisdiction of other parties.

Ships constructed before 1 January 2000

Ships constructed before 1 January 2000 shall be issued with an International Air Pollution Prevention Certificate (IAPP), not later than the first scheduled dry-docking after 19 May 2005 but not later than 19 May 2008.

They are subjected to the same scope of certification than the new ships with the exceptions of NOx emissions from diesel engines (MARPOL VI/13) and the approval of the incinerator under resolution MEPC.76(40), unless they are modified.

Such ships will hold an International Air Pollution Certificate (IAPP).

Ships constructed on/after 1 January 2000 and before 19 May 2005

Ships constructed before 19 May 2005 shall be issued with an International Air Pollution Prevention Certificate (IAPP), not later than the first scheduled dry-docking after 19 May 2005 but not later than 19 May 2008.

They are subjected to the same scope of certification than the new ships, including provisions of MARPOL VI/13 (NOx emissions from diesel engines). In principle, all their diesel engines, whether MP or auxilliary engines (GE) should have been pre-certified within the scope of the NOx Technical Code.

Such ships will hold an International Air Pollution Certificate (IAPP) and as much EIAPP Certificates as they are fitted with diesel engines of an output above 130 kW.

Ships constructed on/after 19 May 2005 (New ships)

Ships constructed on/after 19 May 2005 shall be issued with an International Air Pollution Prevention Certificate (IAPP) upon their delivery.

Such ships are certified with regard to :

• ozone-depleting substances (ODS) (reg.VI/12),

• nitrogen oxide (NOx) emissions from diesel engines (reg. VI/13),

• sulphur dioxide (SOx) emissions from ships (reg.VI/14),

• volatile organic compound (VOCs) emissions from cargo tanks of oil tankers (reg.VI/15),

• shipboard incineration of waste (reg.VI/16),

• fuel oil quality (reg.VI/18).

Such ships hold an International Air Pollution Certificate (IAPP) and as much EIAPP Certificates as they are fitted with diesel engines of an output above 130kW (See Definitions).

Validity of the International International Air Pollution Prevention Certificate

Annex VI, under its revised form, falls under the harmonized certification scheme : whatever is the ship’s flag, the International Air Pollution Prevention Certificate (IAPP) is issued with a validity of 5 years as applicable to class and other statutory certificates.

The IAPP Certificate is renewed and extended in accordance with the standard provisions of the harmonized certification scheme.

Where a IAPP Certificate/Document of Compliance is issued to a ship in service, its validity date is the same as the validity of the classification certificate, whatever is the duration of the remaining classification term.

Survey Regime : Initial, annual, intermediate and renewal surveys

The initial survey is a complete survey of the diesel engines, equipment, systems, arrangement and material falling under the scope of Annex VI so as to make sure that all these items are in compliance with the applicable requirements and are in line with the Technical File, where applicable. The Record of Equipment related to Ozone Depleting Substances and Nitrogene Oxides (NOx), Form AdWE1318, is completed.

The IAPP Certificate / Document of Compliance is issued (Refer to Statutory surveys - General, sections 1 and 2, in force).

The Supplement to the IAPP Certificate / Document of Compliance (Record of construction and equipment) is completed.

The annual survey is a survey of the diesel engines, equipment, systems, arrangement and material falling under the scope of Annex VI, so as to make sure that all these items are maintained in compliance with the applicable requirements and with the Technical File, where applicable.

The intermediate survey is a survey of the diesel engines, equipment, systems, arrangement and material falling under the scope of Annex VI, so as to make sure that all these items are maintained in compliance with the applicable requirements and with the Technical File, where applicable.

The renewal survey covers same items as the initial survey so as to make sure that compliance with the applicable requirements are maintained.

The renewal survey is conducted at intervals not exceeding 5 years.

Ships of less than 400 GT

MARPOL, Annex VI, applies to all ships. However, ships subjected to surveys are those of 400 GT and above as per MARPOL Annex VI Reg. VI / 5(1).

In other words, ships of less than 400 GT are not requested to be surveyed unless instructions are received from the Flag Administration or applicable provisions are entered in the Agreement signed between Recognised Organisation (RO) and the Adminstration. If a surveyor notes that a engine of more than 130 kW without EIAPP / Technical file is installed on board a ship of less than 400 GT flying the Flag of a State party to MARPOL Annex VI, he shall advise the Master / Managers / Owners that the ship is not in a regular situation against MARPOL Annex VI.

International Air Pollution Prevention Exemption Certificate for Unmanned Non-self-propelled (UNSP) Barges

Refer to Unmanned Non-Self-Propelled (UNSP) Barges – Exemption from Certain Survey and Certification Requirements under the MARPOL Convention

Energy efficiency for ships - Chapter 4

Untitled

In 2011, IMO adopted mandatory technical and operational energy efficiency measures which are expected to reduce the amount of CO2 emissions from international shipping (resolution MEPC.203(62)). These mandatory measures (EEDI/SEEMP), included in a new Chapter 4 of MARPOL Annex VI, entered into force on January 1, 2013.

In addition in 2016, IMO adopted amendments on Data collection system for fuel oil consumption of ships, (resolution MEPC.278(70)). These mandatory measures (SEEMP Part II / DCS), entered into force on 1 March 2018.

Revised Chapter 4 – Reduction of the carbon intensity of international shipping - Resolution MEPC.328(76)

Renumbering of regulations - 2021 REVISED MARPOL ANNEX VI - resolution MEPC.328(76)

Below Figure provide correlation of regulation numbers in chapter 4 (Regulations on the carbon intensity of international shipping) between the previous MARPOL Annex VI and the 2021 Revised MARPOL Annex VI (circular. MEPC.1/Circ.897)

Application (reg.19)

Chapter 4 applies to all ships of 400 gross tonnage and above engaged in international voyages. Provisions of this chapter shall not apply to ships not propelled by mechanical means, and platforms including FPSOs and FSUs and drilling rigs, regardless of their propulsion.

As per regulation 19.3:

• Regulations 22 (i.e. attained EEDI), 23 (i.e. attained EEXI), 24 (i.e. required EEDI) and 25 (i.e. required EEXI) shall not apply to ships which have non-conventional propulsion, except:

  a. Regulations 22 (i.e. attained EEDI) and 24 (i.e. required EEDI) shall apply to cruise passenger ships having non-conventional propulsion and LNG carriers having conventional or non-conventional propulsion, delivered on or after 1 September 2019;b. Regulations 23 (i.e. attained EEXI) and 25 (i.e. required EEXI) shall apply to cruise passenger ships having non-conventional propulsion and LNG carriers having conventional or non-conventional propulsion.

• Regulations 22 (i.e. attained EEDI), 23 (i.e. attained EEXI), 24 (i.e. required EEDI), 25 (i.e. required EEXI) and 28 (CII) shall not apply to category A ships as defined in the Polar Code

Goal (reg.20)

Chapter 4 applies to all ships of 400 gross tonnage and above engaged in international voyages. Provisions of this chapter shall not apply to ships not propelled by mechanical means, and platforms including FPSOs and FSUs and drilling rigs, regardless of their propulsion.

As per regulation 19.3:

• Regulations 22 (i.e. attained EEDI), 23 (i.e. attained EEXI), 24 (i.e. required EEDI) and 25 (i.e. required EEXI) shall not apply to ships which have non-conventional propulsion, except:

  a. Regulations 22 (i.e. attained EEDI) and 24 (i.e. required EEDI) shall apply to cruise passenger ships having non-conventional propulsion and LNG carriers having conventional or non-conventional propulsion, delivered on or after 1 September 2019;b. Regulations 23 (i.e. attained EEXI) and 25 (i.e. required EEXI) shall apply to cruise passenger ships having non-conventional propulsion and LNG carriers having conventional or non-conventional propulsion.

• Regulations 22 (i.e. attained EEDI), 23 (i.e. attained EEXI), 24 (i.e. required EEDI), 25 (i.e. required EEXI) and 28 (CII) shall not apply to category A ships as defined in the Polar Code

Functional requirements (reg.21)

A ship to which the chapter 4 applies shall comply, as applicable, with the following functional requirements to reduce its carbon intensity (see Figure):

1. the technical carbon intensity requirements in accordance with:

   • regulation 22 - Attained Energy Efficiency Design Index (attained EEDI),• regulation 23 - Attained Energy Efficiency Existing Ship Index (attained EEXI),• regulation 24 - Required EEDI,• regulation 25 - Required EEXI;

2. the operational carbon intensity requirements in accordance with:

   • regulation 26 - Ship Energy Efficiency Management Plan (SEEMP)• regulation 27 - Collection and reporting of ship fuel oil consumption data• regulation 28 - Operational carbon intensity

Technical carbon intensity requirements (reg.22, 23, 24 and 25)

Energy Efficiency Design Index (EEDI) - (reg.22 and 24)

The attained Energy Efficiency Design Index (Attained EEDI) is a measure of ships energy efficiency (g/ t*nm)The Attained EEDI provisions applies to each ships (new and ship which has undergone a major conversion*) of 400 gross tonnage and above which falls into one or more of the ship categories in regulations 2.2.5, 2.2.7, 2.2.9, 2.2.11, 2.2.14 to 2.2.16, 2.2.20, 2.2.22, and 2.2.26 to 2.2.29.For those ships, the Attained EEDI shall be calculated and be accompanied by the EEDI Technical File that contains the information necessary for the calculation of the attained EEDI and that shows the process of calculation. The attained EEDI shall be verified based on the EEDI Technical File. Refer to 2014 Guidelines on survey and certification of the Energy Efficiency Design Index (EEDI) (resolution MEPC.254(67), as amended by resolution MEPC.261(68)). A revised consolidated text of the Guidelines is set out in circular MEPC.1/Circ.855/Rev.2The EEDI technical file shall be reviewed by DA-MACH or LPO.For the required EEDI, please refer to regulation 24 of MARPOL, Annex VI* each new ship which has undergone a major conversion; and each new or existing ship which has undergone a major conversion that is so extensive that the ship is regarded by the Administration as a newly constructed ship

Attained and required Energy Efficiency Existing Ship Index (EEXI) - (reg. 23 and 25)

Application

EEXI provisions applies to each ships (new and existing) of 400 gross tonnage and above which falls into one or more of the ship categories in regulations 2.2.5, 2.2.7, 2.2.9, 2.2.11, 2.2.14 to 2.2.16, 2.2.22, and 2.2.26 to 2.2.29 (see below ) and to which chapter 4 of MARPOL Annex VI is applicable (refer to Application (reg.19))

EEDI compliant ships – Application of regulation 23.3

For each ship to which regulation 22 applies (new ship as specified in regulation 2.2.18 or ship which has undergone a major conversion as prescribed in regulation 22.1) and where the verified attained EEDI is less than or equal to the required EEXI in accordance with regulation 25, the EEDI Technical File serves the same purpose as an EEXI Technical File. In this case, the attained EEXI shall be verified based on the EEDI Technical File.Pre-EEDI ships, even if a voluntary EEDI Technical File is available, do not fall under the category “ship to which regulation 22 of this Annex applies” of regulation 23.3, since regulation 22 of MARPOL Annex VI applies to new ships and existing ships which have undergone a major conversion, that is so extensive that the ship is regarded by the Administration as a newly-constructed ship. Therefore, unless otherwise instructed by the flag, an EEXI Technical File needs to be prepared and submitted for approval (although it is possible that values of Attained EEXI and Attained EEDI may be same for such ships).

Ship type

1. Ship definition in regulation 2.2

   The scope of EEDI application is provided by regulations 2, 20 and 21 of MARPOL Annex VI. IMO (MEPC 76/15 para.5.24 and MEPC 76/5/1 para. 48) confirmed that the tables in appendix 1 to MEPC.231(65) were not intended to distinguish the applicability of the EEDI (i.e. Ship types from IHSF used or not used for the calculation of reference lines for use with the EEDI) and there is no need to clarify the ship types that are subject to the provisions for "Attained EEDI" and "Required EEDI". Therefore ships falling into the definition in regulation 2.2 are subject, as appropriate, to EEDI requirements and similarly to EEXI requirements.

2. Heavy load carrier

   The IACS REC 170 – “The term of "heavy load carrier" for the application of EEDI/EEXI and CII” is to be used by the MOC in support of case by case applications to the Flag Administration for non-application of EEDI/EEXI and CII, as requested by the Owner, unless the Flag State has issued written different instructions/policy (refer to the related survey procedure) which will prevail.

3. Change from Bulk carrier to General cargo ship

   It shall be handled on a case by case basis, in consultation with the Flag State for final decision per ship case taking into account elements listed in SHIP type - Change from Bulk carrier to General cargo ship

4. LNG carriers which were Gas Carriers for the purposes of verification of the attained EEDI - LNG carriers delivered < 1 September 2019

   The following understanding applies unless otherwise instructed by the flag (IACS - EEXI Implementation Guidelines (Rec. No. 172)):EEXI requirement is applied based on the definitions in regulation 2 as they will stand when EEXI enters into force, i.e. separate definitions and ship categories for gas carriers (regulation 2.2.14) and LNG carriers (regulation 2.2.16).For the purposes of compliance with EEXI, an LNG carrier will be an LNG carrier regardless of when ship has been delivered and the ship type applied when her Attained EEDI was verified.It is recognized that there may be confusion in case ship was delivered before 1 September 2019 with an IEEC stating Gas Carrier as ship type. For all other cases the ship is anyway considered as LNG Carrier.

   Therefore, to clarify the case when an LNG Carrier delivered before 1 September 2019 with an IEEC stating Gas Carrier as ship type, the requirements are shown in the table below as applicable.

Attained & Required EEXI

For each ship:- The attained EEXI shall to be calculated taking into account the 2022 Guidelines on the method of calculation of the attained energy efficiency existing ship index (EEXI) (MEPC.350(78)) as amended;- The attained EEXI shall be accompanied by the EEXI technical file which contains the information necessary for the calculation of the attained EEXI and which shows the process of the calculation;- The attained EEXI shall be verified, based on the EEXI technical file, and - The attained EEXI shall be below the required EEXI, unless the ship does not fall into one of the category for which a EEDI Reference line exist and calculated in accordance with regulations 24.3 and 24.4.In case the ship specific attained EEXI exceeds the required EEXI, the ship shall implement countermeasures, such as limiting shaft / engine power, installing energy saving devices (ESD), etc. to improve the attained EEXI and comply with the required EEXI.

Guidelines for the implementation of the EEXI

Overridable Shaft / Engine Power Limitation System (SHaPoLi/EPL) and associated Onboard Management Manual (OMM)

1. Definitions (resolution MEPC.335(76))

   • Overridable Shaft Power Limitation (SHaPoLi) system means a verified and approved system for the limitation of the maximum shaft power by technical means that can only be overridden by the ship's master or the officer in charge of navigational watch (OICNW) for the purpose of securing the safety of a ship or saving life at sea.

   • Overridable Engine Power Limitation (EPL) system means a verified and approved system for the limitation of the maximum engine power by technical means that can only be overridden by the ship's master or OICNW for the purpose of securing the safety of a ship or saving life at sea.

2. Installation of overridable Shaft / Engine Power limitation system (resolution MEPC.334(76) para. 4.2.9)

   In cases where the overridable Shaft / Engine Power Limitation system is installed, Recognised Organisation (RO) shall confirm that the system is appropriately installed and sealed in accordance with the 2021 Guidelines on the Shaft / Engine Power Limitation system to comply with the EEXI requirements and use of a power reserve (resolution MEPC.335(76)) and that a verified Onboard Management Manual (OMM) for overridable Shaft / Engine Power Limitation is on board the ship.

3. Onboard Management Manual (OMM) for SHaPoLi / EPL

   The SHaPoLi / EPL system shall be accompanied by the OMM for SHaPoLi / EPL that shall be permanently on board the ship for inspection. The Onboard Management Manual shall include:- Design and technical information/documentation on the system installed; and - Company’s operational management procedures for the use of a power reserve by un-limiting the shaft / engine power limitation.Minimum detailed content of the OMM is described in resolution MEPC.335(76) para. 4.3.

4. Installation of SHaPoLi system without controlled feedback as described in IACS REC 172 para 6.6 and revised para. 2.1.1.3 of 2021 Guidelines on the shaft/engine power limitation system to comply with the EEXI requirements and use of a power reserve (resolution MEPC.335(76)), as amended by resolution MEPC.375(80)) and resolution MEPC.390(81).

   Revised Paragraph 2.1.1.3 of 2021 Guidelines on the shaft/engine power limitation system to comply with the EEXI requirements and use of a power reserve (resolution MEPC.335(76)), as amended by resolution MEPC.375(80)) and resolution MEPC.390(81) indicates that:".3 a control unit for calculation and limitation of the power transmitted by the shaft to the propeller(s); if this control unit is independent from the engine automation the following should be satisfied:

   .1 override of limitation is indicated by giving an alarm on the bridge, clearly informing the ship's master or OICNW. Acceptance of this alarm by the master or OICNW is the deliberate action referred to in paragraph 2.2.1;

   .2 in case of exceedance, the ship's master or OICNW to manually reduce the power within the limit;

   .3 in case of deliberate use of power reserve, data recording to commence automatically;

   .4 data recording device as defined in section 2.1.1.2; and

   .5 in case of short-term unintentional exceedance of the power limit the system may inhibit the initiation of the exceedance alarm for up to a maximum of five (5) minutes.”

   However these provisions are now included in the 2021 Guidelines on the shaft/engine power limitation system to comply with the EEXI requirements and use of a power reserve (resolution MEPC.335(76)), as amended by resolution MEPC.375(80)) and resolution MEPC.390(81).These provisions therefore now apply unless otherwise instructed by the Flag.

5. Implementation and application of new section 6 of the 2021 Guidelines on the shaft/engine power limitation system to comply with the EEXI requirements and use of a power reserve (resolution MEPC.335(76)), as amended by resolution MEPC.375(80)) and resolution MEPC.390(81).

   The existing maneuvering booklet, pilot card and wheelhouse poster should be updated in accordance with “Provision and display of manoeuvring information onboard ships “adopted by Resolution A.601(15) to state the limiting power and to provide the Master with the necessary information in the updated characteristics when the ship has all shaft and engine power available, and when shaft or engine power has been limited.

Energy Saving Devices (ESD)

General

2022 Guidelines on the method of calculation of the attained energy efficiency existing ship index (EEXI) (MEPC.350(78)) indicates that in cases where the energy saving device is installed, the effect of the device may be reflected in the ship speed Vref with the approval of the verifier, based on the following methods in accordance with defined quality and technical standards:.1 sea trials after installation of the device; and/or.2 dedicated model tests; and/or.3 numerical calculations.The effect on the attained EEXI of the installation of energy saving device shall be assessed and approved on a case by case basis by DA_MACH taking into account the provisions of the 2021 Guidance on treatment of innovative energy efficiency technologies for calculation and verification of the attained EEDI and EEXI, circular MEPC.1/Circ.896.

Survey and Certification

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An International Energy Efficiency Certificate shall be issued after a survey to any ship of 400 GT, (new and existing) and above to which chapter 4 of MARPOL Annex VI applies, before that ship may engage in voyages to ports or offshore terminals under the jurisdiction of other Parties..

New ship

A new ship is a ship which meets one of the following criteria:

• Building contract is placed on or after 1 January 2013; or in the absence of a building contract, the keel is laid or at a similar stage of construction on or after 1 July 2013; or

• The ship is delivered on or after 1 July 2015

Such Ship is certified with regards to:

• Attained Energy Efficiency Design Index (Attained EEDI) (reg. VI/22),

• Required Energy Efficiency Design Index (Required EEDI) (reg. VI/24),

• Attained Energy Efficiency Existing Ship Index (Attained EEXI) (reg. VI/23),

• Required Energy Efficiency Existing Ship Index (Required EEXI) (reg. VI/25),

• Ship Energy Efficiency Management Plan (SEEMP) (reg. VI/26) *

  * verify that the SEEMP is on board

Existing ship

An existing ships is a ship other than a new ship Such Ship is certified with regards to:

• Attained Energy Efficiency Existing Ship Index (Attained EEXI) (reg. VI/23),

• Required Energy Efficiency Existing Ship Index (Required EEXI) (reg. VI/25),

• Ship Energy Efficiency Management Plan (SEEMP) (reg. VI/26) *

  * verify that the SEEMP is on board

Survey of existing ships for verification of EEXI (MARPOL Annex VI, regulation 5.4.7)

New regulation 5.4.7 of MARPOL Annex VI requires that verification of the ship's attained EEXI, in accordance with the requirements in regulations 23 and 25, shall take place at the first IAPP annual, intermediate or renewal survey or the IEE initial survey, whichever is the first, on or after 1 January 2023.

Revised form of International Energy Efficiency (IEE) Certificate and its supplement.

Amendments to MARPOL Annex VI (2021 Revised MARPOL Annex VI) – Resolution MEPC.328(76) includes in appendix VIII a revised form of IEE Certificate and its supplement. The form has been revised to record compliance for Attained EEXI, Required EEXI and EEXI technical file in addition to provisions for Attained EEDI, Required EEDI, EEDI technical file and SEEMP.This revised form will be available in ASMS Certificate from 1 November 2022 (i.e. Entry Into Force of MARPOL amendments). In accordance with the provisions of MSC-MEPC.5/Circ.6 para.3.2, the revised IEE Certificate and its supplement has to be re-issued for each ship following satisfactory survey as required by new regulation 5.4.7.

Forthcoming process timeline

Each existing ship for which an application for a survey for verification of the ship's EEXI specified in regulation 5 of MARPOL Annex VI has been submitted, shall be subject the below process:

Verifier (i.e. Administration, or organization duly authorized by it)

Recognised Organisation (RO)'s policy is that EEXI verification, survey and certification is to be carried out by the RO classing the ship (i.e. Recognised Organisation (RO) on Recognised Organisation (RO) classed ships), unless otherwise instructed by the ship's flag state, as this is a pure statutory matter. Refer to flag procedures

Procedure for survey and certification of the attained EEXI

1. Verification of attained EEXI

   The Verification of the attained EEXI shall be done taking into account the 2021 Guidelines on survey and certification of the Energy Efficiency Existing Ship Index (EEXI) (resolution MEPC.334(76)). The following diagram (Figure) summarized the different verification steps to be performed when Recognised Organisation (RO) is duly delegated by the ship’s flag, refer to flag procedures and Flag Code.

   

2. Documentary review by the LPO

   An EEXI Technical File containing the necessary information for the verification and other relevant background documents shall be submitted by the owner to Recognised Organisation (RO), unless the attained EEDI of the ship satisfies the required EEXI refer to Application above. In case SHaPoLi/EPL system is planned to be installed, additional review/approval is required, refer the additional instructions in below Survey of existing ships for verification of EEXI (MARPOL Annex VI, regulation 5.4.7) d)

   In case where the speed-power curve is not available or the sea trial report does not contain the EEDI or design load draught condition, the ship speed Vref can be obtained from the in-service performance measurement method for the purpose of the EEXI calculation, in accordance with paragraph 2.2.3.5 of the EEXI Calculation Guidelines, as set out in resolution MEPC.350(78), refer the additional instructions in below Survey of existing ships for verification of EEXI (MARPOL Annex VI, regulation 5.4.7) e)

   Following satisfactory review, the LPO will issue an attestation of verification of EEXI which will later be used by the Surveyor to re-issue the IEE Certificate.

3. Survey onboard and re-issuance of IEE Certificate

   Survey onboard shall take place at the first IAPP annual, intermediate or renewal survey (or the IEE initial survey), whichever is the first, on or after 1 January 2023. From 1 November 2022, ASMS Survey code IEEC (with updated checklist) has to be selected.The survey aims to verify that proper documents it available onboard:- Reviewed EEXI technical file (or EEDI technical file in compliance with reg.23.3 refer to Application) along with Recognised Organisation (RO) attestation of verification of EEXI; - Reviewed SEEMP Part II and III (even if the SEEMP is not part of the EEXI review and even if the SEEMP Part II / III review is not done by Recognised Organisation (RO) as verifier).And re-issuance of the revised form of IEE Certificate and its supplement.

   In case SHaPoLi/EPL system is installed, additional survey is required, refer the additional instructions in below Survey of existing ships for verification of EEXI (MARPOL Annex VI, regulation 5.4.7) d)

4. Overridable Shaft / Engine Power Limitation System (SHaPoLi / EPL)

   • The demonstration of compliance of the SHaPoLi / EPL system shall be verified by an appropriate survey for the verification of the ship's EEXI according to regulation 23. The survey shall include the verification and validation of the system by addressing the following items (resolution MEPC.335(76) para. 5.1 as amended):

     .1 the verification of compliance of the system with the OMM for SHaPoLi / EPL;.2 the verification of compliance of the system with the specifications set out in section 2 of 2021 Guidelines on the Shaft / Engine Power Limitation system to comply with the EEXI requirements and use of a power reserve (resolution MEPC.335(76) as amended); and.3 the verification of the OMM for SHaPoLi / EPL that the OMM for SHaPoLi / EPL is in compliance with the specifications set out in section 4 of 2021 Guidelines on the Shaft / Engine Power Limitation system to comply with the EEXI requirements and use of a power reserve (resolution MEPC.335(76) as amended).

   • Recognised Organisation (RO) review and survey process:

     Documentary review and approval by LPO includes:

     .1 Approval of EEXI technical file with provisions for verification of the SHaPoLi / EPL & OMM on board during survey;.2 Approval of Shaft / Engine Power Limitation system;.3 Review that system arrangement documentation are included in the ship’s specific Onboard Management Manuel (OMM); and .4 Prior to survey onboard, verification that company’s operational management procedure for the use and the notification of the use of a power reserve by un-limiting the shaft / engine power limitation, including ship’s flag specific instructions (Refer to flag procedures) are included in the ship’s specific Onboard Management Manuel (OMM)

     Survey onboard includes:

     .1 Verification of the system as described in the Onboard Management Manuel (OMM) .2 Availability of verified ship’s specific Onboard Management Manuel (OMM).3 Verification of correct implementation of operational procedure management procedure for the use and the notification of the use of a power reserve by un-limiting the shaft / engine power limitation, in compliance with the ship’s specific Onboard Management Manuel (OMM).4 Issuance of Recognised Organisation (RO) attestation for satisfactory installation of SHaPoLi / EPLASMS Survey code IEPL has to be selectedUpon owner’s request, the IEPL survey may be carried out, as appropriate, in advance to the first periodical IAPP survey in 2023 and separately from required IEEC survey. Nevertheless IEEC survey will be required to be carried out in 2023, refer to Survey of existing ships for verification of EEXI (MARPOL Annex VI, regulation 5.4.7)

     Following satisfactory survey for SHaPoLi / EPL and OMM, a Recognised Organisation (RO) attestation for satisfactory installation is issued to the ship. Template is available in ASMS Certificate

5. Vref – in-service performance measurements [UNDER PROGRESS]

   In cases where the speed-power curve is not available or the sea trial report does not contain the EEDI or design load draught condition, the ship speed Vref can be obtained from the in-service performance measurement method conducted and verified in accordance with the methods and procedures as specified in the Guidance on methods, procedures and verification of in-service performance measurements (MEPC.1/Circ.901). (para. 2.2.3.5 of 2022 Guidelines on the method of calculation of the attained Energy Efficiency Existing Ship Index (EEXI) (res. MEPC.350(78))The in-service performance measurement is to be witnessed by Recognised Organisation (RO) as verifier.And the in-service measurement report will be part of the EEXI technical file review. For which an attestation will be issued upon satisfactory verification.

Overridable shaft / engine power limitation - Use and reporting of the use of a power reserve & reactivation or replacement of the SHaPoLi / EPL

1. Ships shall use the power reserve by un-limiting the shaft / engine power limitation in accordance with the provisions of para. 3 of 2021 Guidelines on the shaft / engine power limitation system to comply with the EEXI requirements and use of a power reserve (resolution MEPC.335(76) as amended).

2. The process includes 3 distinct steps which can be delegated by a Flag State to Recognised Organisation (RO) as a RO (refer to the related survey procedure):

   • Verification and collection of information on the use of power reserve.

   • Reporting of the use of the power reserve to the Administration and to / IMO

   • Verification of the reactivation or replacement of the SHaPoLi / EPL system

The Figure summarizes the processes to be followed :

ASMS Survey code OEPL is to be selected, as appropriate, for verification and reporting of the use of power reserve and confirmation of the reactivation or replacement of the SHaPoLi / EPL system

Operational carbon intensity - (reg. 26, 27 and 28)

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IMO adopted mandatory operational energy efficiency measures to enhance the energy efficiency of ships. These mandatory measures include requirements for SEEMP (i.e. Part I) which entered into force on 1 January 2013 and requirements for Data collection system for fuel oil consumption of ships which entered into force on 1 March 2018.

Overview of new operational carbon intensity indicator (CII)

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The operational carbon intensity reduction requirements are based on a new operational carbon intensity indicator (CII). Each year from 2023 (first annual reporting on carbon intensity will be completed for the full year 2023, with the first rating given in 2024), every ship needs to calculate and report its attained annual operational CII.Regulation 28 of MARPOL Annex VI states that the attained annual operational CII shall be calculated, using the data collected in accordance with regulation 27 (Fuel Oil Data Collection System).This actual annual operational CII achieved (attained annual operational CII) will be required to be documented and verified against the required annual operational CII. This would enable the operational carbon intensity rating to be determined. Rating will be given on a scale A, B, C, D or E (where A is the best). Note: The required CII, and thus the rating threshold, will be lowered year by year to ensure that, in combination with other relevant requirements of MARPOL Annex VI, the reduction in CO2 emissions per transport work by at least 40% by 2030, compared to 2008, can be achieved as an average across international shipping.To support ship’s performance and objective, a ship operational carbon intensity plan (SEEMP Part III) has to be developed by the manager of the ship and reviewed in accordance with regulation 26.3.1.The below diagram in Figure gives on overview of CII compliance timeline from 2022 to 2024.

Company (definition in regulation 2.2.8)

For the purpose of regulation 26, 27 and 28, “Company” means the owner of the ship or any other organization or person such as the manager, or the bareboat charterer, who has assumed the responsibility for operation of the ship from the owner of the ship and who on assuming such responsibility has agreed to take over all the duties and responsibilities imposed by the International Management Code for the Safe Operation of Ships and for Pollution Prevention, as amended.

Guidelines for the implementation of the operational carbon intensity

Ship Energy Efficiency Management Plan (SEEMP) (reg.26 and reg.28.8)

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There are three parts to a SEEMP:

• Part I is to provide an approach to monitor ship and fleet efficiency performance over time and describe ways to improve the ship's energy efficiency performance and carbon intensity. Part I applies to any ship of 400 GT and above.

• Part II is to provide a description of the methodologies that will be used to collect the data required pursuant to regulation 27 of MARPOL Annex VI and the processes that the ship will use to report the data to the ship's Administration or any organization duly authorized by it. Part II applies to any ship of 5,000 GT and above.

• NEW Part III is to provide the methodology the ship will use to calculate the attained annual operational carbon intensity indicator (CII) as required by regulation 28.1 of MARPOL Annex VI and the processes that are to be used to report the data to the ship's Administration or any organization duly authorized by it. Part III applies to any ship of 5,000 GT and above which falls into one or more of the categories described in regulation 26.3 of MARPOL Annex VI (refer to Ship operational carbon intensity plan – SEEMP Part III - Entry into force on 1 November 2022).

Regulation 26 of MARPOL Annex VI, as amended, requires each ship to keep on board a ship specific Ship Energy Efficiency Management Plan (SEEMP). The SEEMP shall be developed and reviewed, taking into account guidelines developed by the IMO.

Ship Energy Efficiency Management Plan (SEEMP) Part I

The purpose of a SEEMP Part I is to establish a mechanism for a company and/or a ship to improve the energy efficiency of a ship's operation.

2016 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) – resolution MEPC.282(70) is intended to assist with the preparation / development of the mandatory Ship Energy Efficiency Management Plan.

The SEEMP should be developed as a ship-specific plan by the company. Many companies already develop, implement and maintain a Safety Management System. In such case, the SEEMP may form part of the ship's Safety Management System.The structure of the SEEMP Part I should contains 4 mains parts (or equivalent) :

1. Measures

2. Monitoring

3. Goal

4. Self-evaluation and improvement

A SEEMP Part I review may be carried out upon owner’s request and according to the related survey procedure. Reference is also made to the additional class notation SEEMP (NR586)

Ship Energy Efficiency Management Plan (SEEMP) Part II

1. Entry into force on 1 March 2018

   Regulation 26.2 (former regulation 22.2) of MARPOL Annex VI as amended by resolution MEPC.328(76) specifies that, "On or before 31 December 2018, in the case of a ship of 5,000 gross tonnage and above, the SEEMP shall include a description of the methodology that will be used to collect the data required by regulation 27.1 of this Annex and the processes that will be used to report the data to the ship's Administration." Part II of the SEEMP, the Ship Fuel Oil Consumption Data Collection Plan shall contain such methodology and processes.

   NB: IMO MEPC.1/Circ.795/Rev.6 clarifies that “Ships that are delivered on or after 1 January 2019 should keep on board both a SEEMP that is in compliance with regulation 26.2 and confirmation of compliance as required by regulation 5.4.5.”

   Pursuant to regulation 5.4.5 of MARPOL Annex VI, the Administration should ensure that each ship's SEEMP complies with regulation 26.2 of MARPOL Annex VI prior to collecting any data.When duly delegated by the Administration, Recognised Organisation (RO) will review the Data Collection Plan and provide a “confirmation of compliance to and retained on board the ship” – PLEASE REFER TO: the related survey procedure IMO DATA COLLECTION SYSTEM (DCS) AND OPERATIONAL CARBON INTENSITY INDICATOR (CII).

   As no template of the Confirmation of Compliance exist in MEPC.278(70), IMO at the MEPC 72 (April 2018) approved a sample format for the Confirmation of compliance pursuant to regulation 5.4.5 of MARPOL Annex VI, as set out in MEPC.1/Circ.876. Confirmation of Compliance is provided in Certificate Editor.

2. 2022 SEEMP Guidelines - Res. MEPC.346(78)

   2022 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) – resolution MEPC.346(78), provide guidance for developing a ship-specific method to collect, aggregate, and report ship data with regard to annual fuel oil consumption, distance travelled, hours underway and other data required by regulation 27 of MARPOL Annex VI to be reported to the Administration.

3. Amendments to 2022 SEEMP Guidelines - Res. MEPC.388(81) & consolidated 2024 SEEMP Guidelines - Res. MEPC.395(82)

   As a consequential aspect of implementing the revised DCS relating to the inclusion of data on transport work and on an enhanced level of granularity (resolution MEPC.385(81)), IMO adopted resolution MEPC.388(81) on amendments to the 2022 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP).

   All SEEMP shall be revised, in a timely manner, to describe the methodology that will be used to collect :- Fuel oil consumption per consumer type- Other additional data (mandatory & voluntary)

   As per IACS UI MPC 131 and IMO circular MEPC.1/Circ.913, the following applies: Prior to collecting data specified in appendix IX of MARPOL Annex VI as amended by resolution MEPC.385(81), each ship to which regulation 27 applies should have their SEEMP revised to ensure compliance with regulation 26.2 of MARPOL Annex VI, taking into account the 2024 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) (resolution MEPC.395(82) (i.e. consolidated version of the guidelines which is to be published).

   In addition IMO circular MEPC.1/Circ.913 clarifies that:For ships flying the flag of the Administration which implements the amendments early (1 January 2025):.1 the SEEMP should undergo revision and verification by the Administration, or its recognized organization, to incorporate a description of the methodology intended for collecting data with enhanced granularity before 1 January 2025 or the delivery date for ships delivered on or after 1 January 2025. Those planning to retrofit flow meters or other methodologies should complete these actions within the same time frame; and[….]For ships flying the flag of the Administration which implements the amendments on the entry-into-force date (1 August 2025):.1 the SEEMP should undergo revision and verification by the Administration, or its recognized organization, to incorporate a description of the methodology intended for collecting data with enhanced granularity before 1 January 2026. Those planning to retrofit flow meters or employ other methodologies should complete these actions within the same time frame;[…..]

4. Amendments to the 2024 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) – Res. MEPC.401(83)

   Amendments include the definition of "under way" referring to existing IMO terminology, with the aim to clarify the distance travelled and the hours underway to be considered.

5. Amendments to the 2024 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) – Res. MEPC.413(84)

   IMO agrees on amendments to the 2024 SEEMP Guidelines to prevent unintended impacts on CII calculations arising from enhanced granularity in the IMO DCS; specifying that total distance travelled for CII purposes should continue to aggregate both "under way" and "not under way" distances to maintain methodological consistency and avoid inequitable impacts across ship types.For sake of clarity the standardized data-reporting format to the Administration (Appendix 4 of 2024 Guidelines) includes 2 new aggregated data: distance travelled “while the ship is under way” and “while the ship is not under way”.

Ship operational carbon intensity plan – SEEMP Part III - Entry into force on 1 November 2022

1. Application

   Regulation 26 (former regulation 22) of MARPOL Annex VI as amended by resolution MEPC.328(76) requires that on or before 1 January 2023, a ship's SEEMP has been developed and complies with regulation 26.3.1 (i.e. includes Ship operational carbon intensity plan – SEEMP Part III).Every ship of 5,000 gross tonnage and above, which falls into one or more of the categories in regulations 2.2.5, 2.2.7, 2.2.9, 2.2.11, 2.2.14 to 2.2.16, 2.2.22, and 2.2.26 to 2.2.29 (see table ) and to which chapter 4 of MARPOL Annex VI is applicable (refer to Application (reg.19)) is required to developed and maintain, as appropriate, an SEEMP Part III.

2. Scope of the SEEMP Part III

   The SEEMP Part III shall be developed taking into account the 2022 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) (resolution MEPC.346(78)) and includes: .1 a description of the methodology that will be used to calculate the ship's attained annual operational CII required by regulation 28 of MARPOL Annex VI;.2 the processes that will be used to report this value to the ship's Administration or any organization duly authorized by it;.3 the required annual operational CII for the next three years;.4 an implementation plan documenting how the required annual operational CII will be achieved during the next three years;.5 a procedure for self-evaluation and improvement; and.6 for ships rated as D for three consecutive years or rated as E, a plan of corrective actions to achieve the required annual operational CII.

3. Verification and company audits

   Pursuant to regulation 26.3.3, the SEEMP Part III shall be subject to verification and company audits taking into account the Guidelines for the verification and company audits by the administration of part iii of the ship energy efficiency management plan (SEEMP) (MEPC.347(78)). See Figure

   Furthermore pursuant to regulation 5.4.6 of MARPOL Annex VI, the Administration should ensure that each ship's SEEMP complies with regulation 26.3.1 prior to 1 January 2023. On satisfactory assessment of the SEEMP Part III, the Administration can issue the Confirmation of Compliance (sample format in the annex to the Guidelines for the verification and company audits by the administration of part iii of the ship energy efficiency management plan (SEEMP) (MEPC.347(78)).

   

   When duly delegated by the Administration, Recognised Organisation (RO) will review the Ship operational carbon intensity plan – SEEMP Part III and provide a “confirmation of compliance retained on board the ship” – PLEASE REFER TO: the related survey procedure IMO DATA COLLECTION SYSTEM (DCS) & AND OPERATIONAL CARBON INTENSITYI INDICATOR (CII).

   When duly delegated by the Administration, Recognised Organisation (RO) will perform SEEMP Part III audits - PLEASE REFER TO: the related survey procedure SEEMP Part III Audits Process.

4. Confirmation of Compliance - SEEMP Part III

   In accordance with regulation 5.4.6 of MARPOL Annex VI, it shall be ensured that for each ship to which regulation 28 applies, the SEEMP complies with regulation 26.2. This shall be done prior to 1 January 2023. Confirmation of compliance shall be provided to and retained on board the ship. The format is provided in the annex of Guidelines for the verification and company audits by the Administration of part III of the Ship Energy Efficiency Management Plan (SEEMP), (MEPC.347(78))- From September 2022, The CoC “not on behalf of the Flag” is available in ASMS 2 Certificate. This CoC may be issued to the ship pending formal entry into force of the revised MARPOL Annex VI (i.e. 1 November 2022)Note : Before 1 January 2023, and when duly delegated by the Flag, the CoC “not on behalf of the Flag” shall be replaced by the CoC “on behalf of the flag”.- From 1 November 2022 (i.e. date of the Entry into force of revised MARPOL Annex VI), The CoC on behalf of the Flag will be available in ASMS 2 Certificate.

5. Periodical verification

   Guidelines for the verification and company audits by the Administration of part III of the Ship Energy Efficiency Management Plan (SEEMP) - RESOLUTION MEPC.347(78) indicates that :“5.5 If any of the elements in regulation 26.3.1 is updated, and in any case every three years, the Administration should perform a periodical verification to ensure the SEEMP complies with regulation 26.3.1 of MARPOL Annex VI in accordance with regulation 5.4.6 of MARPOL Annex VI.”

6. Company Audits periodicity

   - Guidelines for the verification and company audits by the Administration of part III of the Ship Energy Efficiency Management Plan (SEEMP) - RESOLUTION MEPC.347(78) indicates that :

   “5.9 The Administration should, in accordance with regulation 26.3.3, perform periodical company audits to:.1 verify that the SEEMP for which the Confirmation of Compliance has previously been issued complies with regulation 26.3.1 and, in the case of non-compliance, require remedial action;.2 confirm that the ship is being operated in accordance with SEEMP part III, regardless of its rating;.3 verify the progress made in the (corrective) actions to be taken in the execution of the three-year implementation plan and the plan of corrective actions;.4 verify self-assessment and improvement of actions taken; and.5 verify the assignment of responsibilities related to the implementation and monitoring of measures.5.10 The periodical company audits may include annual audits of the company (company audits) and verifications on board the ship (shipboard audits).5.11 These additional shipboard verifications and company audits, if undertaken, should be six months after the issuance of the Statement of Compliance at the latest.”

   - IACS REC 175/Rev.1 para.8.1 “Company audits” para.8.1 indicates that:

   ““Though company audits are mandatory, the periodicity of company audit is not specified in MARPOL Annex VI regulation 26.3.3. A company should be audited every three years”

   - IACS REC 175/Rev.1 para.8.4 “Non-compliance, corrective actions and follow up” indicates that:

   “The follow-up action may include additional company or shipboard audit(s), as appropriate, to verify that corrective actions have been properly implemented.”

   Therefore, unless otherwise instructed by the flag, each company is subject to:- a periodical audit every 3 years; and- in case a plan of corrective actions has been developed for a ship, an annual audit and/or verification onboard the ship (shipboard audits) (to be performed not later than six months after the issuance of the Statement of Compliance at the latest)

Collection and reporting of ship fuel oil consumption data - Entry into force on 1 March 2018 (reg.27, former reg.22A)

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IMO adopted mandatory MARPOL Annex VI requirements for ships of 5,000 gross tonnage and above to record and report their fuel oil consumption.The MEPC 70 adopted the mandatory requirements as amendments to chapter 4 of annex VI of MARPOL (by resolution MEPC.278(70)). They entered into force on 1 March 2018.They add new Regulation 27 (former Regulation 22A) on Collection and reporting of ship fuel oil consumption data and new appendices covering Information to be submitted to the IMO Ship Fuel Oil Consumption Database and form of the Statement of Compliance, which would be issued to the ship once the relevant data had been reported. Other regulations are amended to cater for the new requirement, including those related to certificates, surveys and port State control.

IMO DCS process:

IMO DCS initial implementation timeline - for data collected from calendar year 2019

From calendar year 2019, each ship of 5,000 gross tonnage and above shall collect the data specified in appendix IX to MARPOL Annex VI.

The following graph summarizes the initial implementation timeline of IMO DCS

Updating of SEEMP (including Part II)

From 1 March 2018 (i.e. EIF of MARPOL Amendments related to data collection) and on or before 31 December 2018, ships of 5,000 gross tonnage and above shall have onboard a SEEMP which includes a description of the methodology that will be used to collect the data required by regulation 27.1 (i.e. SEEMP Part II, refer to Ship Energy Efficiency Management Plan (SEEMP) Part II) Review of SEEMP Part II shall be done prior to the beginning of the ship's first reporting period i.e. Calendar year 2019.

Revised DCS - for data collected from calendar year 2023

From calendar year 2023; each ship of 5,000 gross tonnage and above shall collect the data (i.e. expanded dataset) specified in appendix 3 of 2022 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) – resolution MEPC.346(78). Consistently Appendix IX to MARPOL annex VI has been revised (resolution MEPC.362(79)) see Figure