The club previously published guidance related to reporting emissions data into the IMO Data Collection System (IMO-DCS) and EU Monitoring, Reporting and Verification (EU-MRV) regimes.
Following withdrawal from the European Union, the United Kingdom has retained and amended EU legislation to establish a UK-MRV regime to monitor, report and verify emissions data from ships > 5000GT calling at UK ports.
Marine information note (MIN 669 (M+F)) ‘Reporting Emissions Data into the UK-MRV Regime’ provides advice on the legal and practical considerations for the introduction of the new system, some of which are summarised below.
• UK-MRV requirement will be applicable to ships > 5000 GT, irrespective of their flag, calling at UK ports.
• Similar exemptions apply to vessels under the UK-MRV regime that apply under the EU-MRV regime, ie warships, naval auxiliaries, fish-catching or fish-processing ships, ships not propelled by mechanical means, and government ships used for non-commercial purposes.
• Emissions data for the following voyages will need to be included in the UK-MRV emissions report:
– Voyages between UK ports
– Voyages between UK and non-EEA port
– Emissions generated at a UK port for the above voyages
– Voyages between UK and UK overseas territories or Crown dependencies – such as the Falkland Islands, Gibraltar, Isle of Man, Jersey.
However, voyages between two Crown dependencies or overseas territories should not be included. Likewise, a voyage from a port in an overseas territory or Crown dependency to a non-UK port should not be included.
Voyages between the UK and EEA (ports under EU-MRV regime) do not have to be reported under UK-MRV because they are already being reported under the EU-MRV regime.
The UK-MRV regime is expected to be fully in place by the end of 2021. Members will be expected to begin collecting data for voyages for the UK-MRV regime from 1 January 2022 onwards, for the 2022 reporting period. No enforcement action will be taken until 2023.
From 1 July 2021, ships which used a UK or EEA port in 2020, should be carrying a Document of Compliance (DoC) for emissions data collected during the 2020 reporting period, to comply with the EU-MRV regime. A DoC issued under the EU-MRV regime, and which covers voyages between the UK and EEA ports is recognised as a UK DoC equivalent for those voyages.
From 31 December 2021, an assessed UK-MRV monitoring plan will need to be in place. If a ship already uses a monitoring plan under the EU-MRV regime, member will need to confirm with the verifier if this is suitable for the UK-MRV regime, or if changes are needed.
The assessment of the monitoring plan and the verification of the annual emission report for each ship needs to be done by an accredited verifier. From 1 January 2023, all verifiers must be accredited by the United Kingdom Accreditation Service (UKAS) – members should check the status of their verifier(s).
From 30 June 2023, a separate DoC will be needed to cover voyages to and from UK ports, made in the previous reporting period, which fall outside the scope of the EU-MRV.
Templates for the monitoring plan, the emissions report and the document of compliance will be made available in due course by the UK government.
Members with ships calling at UK ports are recommended to take note of above and ensure compliance with the upcoming UK-MRV regulations.