At its 81st session (18-22 March 2024), the Marine Environment Protection Committee (MEPC) adopted amendments to Appendix IX of MARPOL Annex VI under Resolution MEPC.385(81). These amendments enhance the reporting requirements for the IMO Ship Fuel Oil Consumption Database (IMO DCS) by mandating the collection of more detailed fuel consumption and transport work data. The amendments also introduce new data points, including a more granular breakdown of fuel consumption and the reporting of transport work, which is vital for the International Maritime Organization's (IMO) decarbonization and greenhouse gas (GHG) reduction objectives.

Amendments Overview

The key amendments to Appendix IX of MARPOL Annex VI, as specified in MEPC.385(81), require ships to report the following:

1. Fuel Oil Consumption Breakdown:
   • Consumption per consumer type, including main engines, auxiliary engines, oil-fired boilers, and others.
   • Fuel oil consumption when the ship is not underway.
2. Energy Supply Information:
   • Total amount of onshore power supplied to the ship, expressed in kilowatt-hours (kWh).
3. Transport Work Reporting:
   • Ships to which Regulation 28 of MARPOL Annex VI applies will also report transport work data using tonne-mile, TEU-mile, and/or passenger-mile, with containerships required to report both tonne-mile and TEU-mile data.
4. Innovative Technology:
   • A new voluntary entry for the installation of innovative energy efficiency technologies, aligned with the 2021 IMO guidance on the treatment of such technologies for EEDI and EEXI calculations (MEPC.1/Circ.896).

Early Implementation of Amendments

Although the amendments to Appendix IX of MARPOL Annex VI are set to officially enter into force on 1st August 2025, MEPC has invited Administrations to adopt these changes early from 1st January 2025. Early implementation will help generate more complete and detailed data to support the review of the Carbon Intensity Indicator (CII) framework.

As part of the early implementation, the following actions are required:

• SEEMP Updates: Ships to which Regulation 27 applies must update their Ship Energy Efficiency Management Plan (SEEMP) to align with the revised reporting requirements. The SEEMP updates should be completed by 1st January 2025 for those adopting early implementation. For vessels opting out of early implementation, the SEEMP update deadline is 1st January 2026.
• Reporting Enhancements: Beginning 1st January 2025, data must be collected and reported with an enhanced level of granularity, including the new data points required under MEPC.385(81). This includes detailed fuel consumption per consumer type, onshore power supplied, and the reporting of transport work metrics.
• Verification and Retrofits: For ships opting for early implementation, retrofits (such as the installation of flow meters) and necessary verifications should be completed before 1st January 2025. Ships delivered on or after this date must ensure that their systems and processes comply with the enhanced reporting requirements from the outset.

SEEMP Revisions and Guidance (MEPC.1/Circ.913)

The Guidance on the application of the amendments (MEPC.1/Circ.913) was approved at MEPC's 82nd session (30 September-4 October 2024) and provides detailed instructions on implementing the revised granularity of data and reporting requirements. Key points from the guidance include:

1. Uniform Data Granularity:
   Data must be reported at a uniform level of granularity within the same calendar year, in line with the "portion thereof" principle outlined in Regulations 27.1 and 27.2 of MARPOL Annex VI.
2. SEEMP Revisions:
   Before beginning data collection, vessels subject to Regulation 27 must revise their SEEMP to comply with Regulation 26.2, reflecting the updated SEEMP Guidelines (MEPC.395(82)).

3. Implementation Timelines:
   • Early Implementation (1st January 2025): Ships flying the flag of Administrations opting for early implementation must complete SEEMP revisions, verifications, and any planned retrofits by 1st January 2025. Data will be collected and reported with the enhanced granularity for the full year of 2025 and beyond.
   • Entry-Into-Force (1st August 2025): For ships under Administrations that implement the amendments on 1st August 2025, SEEMP revisions, verifications, and retrofits must be completed by 1st January 2026. Granular data reporting will begin on 1st January 2026 for these vessels, with a transition period in 2025.

Conclusion

The early implementation of the amendments to Appendix IX of MARPOL Annex VI is an important step toward improving the accuracy and comprehensiveness of fuel oil consumption and transport work data reported to the IMO. Ship owners, operators, and other stakeholders are encouraged to begin the necessary updates to their SEEMP and reporting systems to ensure full compliance by the specified deadlines.

For further details, please refer to MEPC.1/Circ.913 for guidance on the application of these amendments and consult the official IMO resolutions for additional information.

For any queries or assistance, please contact mes@phrs.gr

PHRS Marine Environmental Sustainability Dept.