With MEPC 75 taking place these days, there is a lot of talk about what’s the plan to reduce emissions by 2030. Already, the October draft for mandatory regulations to cut the carbon intensity of existing ships, raised a lot of eyebrows among environmental organizations and were immediately criticised. Well, today, without much of a surprise, these draft regulations amendments to MARPOL, were approved.
How do MARPOL regulation amendments work?
MARPOL requires that new draft amendments to be circulated for a minimum 6 months before adoption so don’t expect much for the time being. It is expected that the formal adoption will take place next year, during MEPC 76 session. Only after that they can enter into force, after a minimum 16 months following adoption.
The draft amendments focus on energy efficiency and will add further requirements in MARPOL Annex VI chapter 4 to asses and measure energy efficiency of all ships.
Until now, the existing requirements were the Energy Efficiency Design Index (EEDI), for new build ships and SEEMP, the mandatory Ship Energy Efficiency Management Plan, for all ships. While EEDI required ships to be built and designed with efficiency in mind, the SEEMP helps the ship operators to have a plan in place to improve their energy efficiency through a variety of ship specific measures.
The set of amendments that were approved today by MEPC include a technical requirement to reduce carbon intensity based on an Energy Efficiency Existing Ship Index (EEXI) and the operational carbon intensity reduction requirement based on a new operational carbon intensity indicator (CII). The approach is both technical (what equipement the ship has) and operational (how efficient the ship is opearting)
Let’s have a closer look.
Energy Efficiency Existing Ship Index (EEXI)
The Energy Efficiency Existing Ship Index (EEXI) will be required for ships of 400 gross tonnage and above. By calculating it, in accordance with the different values set for ship types and size categories, the EEXI can indicate the energy efficiency of the ship compared to a baseline.
Ships will be required to meet a specific required Energy Efficiency Existing Ship Index (EEXI).
Carbon Intensity Indicator (CII) and CII Rating
CII will be required to be calculated annually for ships of 5,000 gross tonnage and above and will determine the annual reduction factor needed to ensure continuous improvement of the ship’s operational carbon intensity within a specific rating level.
The actual annual operational CII achieved (attained annual operational CII) would be required to be documented and verified against the required annual operational CII. This would enable the operational carbon intensity rating to be determined. The rating would be given on a scale – operational carbon intensity rating A, B, C, D or E – indicating a major superior, minor superior, moderate, minor inferior, or inferior performance level. The performance level would then be recorded in the ship’s Ship Energy Efficiency Management Plan (SEEMP).
For example, a ship rated D for three consecutive years, or E, would have to submit a corrective action plan, to show how the required index (C or above) would be achieved. Meanwhile a ship rated A or B is more likely to receive different incentives from port authorities and administrations.
A review of the effectiveness of the implementation of the CII and EEXI requirements will be required to be conducted by IMO, by January 1, 2026 at the latest. If necessary, further amendments can be developed and adopted following this review.
In addition to, the MEPC also agreed the terms of reference for assessing their possible impacts on states, particularly developing countries including Small Island Developing States (SIDS) and least developed countries (LDCs).