Carbon dioxide emissions from maritime transport: global data collection system for ship fuel oil consumption data

1) With regard to the data submission after verification, it is suggested to align the requirements of MRV regulations with IMO DCS, i.e. the verifier could submit the emission report to the EU through data exchange, rather than by the company itself, so as to reduce the burden on the companies.

The European Community Shipowners’ Associations (ECSA) and the International Chamber of Shipping (ICS) welcome the revision of Regulation (EU) 2015/757, thereafter the MRV Regulation, attempting to align the EU MRV with the global IMO Data Collection System (IMO DCS). ECSA nonetheless regrets that the European Commission did not opt for a full alignment with the IMO DCS.

EMISA, as a representative of the independent manufacturers and suppliers in the marine diesel industry, welcomes the revision of the MRV Regulation with the aim of providing a more harmonised and effective global approach to the monitoring and reporting of CO2 emissions.

A.P. Moller – Maersk welcomes the opportunity to comment on the proposed revision of Regulation (EU) 2015/757 on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport. In general, A.P. Moller – Maersk welcomes the efforts from the European Commission to harmonize the MRV Regulation with some of the technical aspects of the IMO Data Collection System. However, A.P.

Comments from the Bahamas Shipowners Association on the Revision of Regulation of the European Parliament and the Council amending Regulation (EU) 2015/757 on monitoring, reporting and verification of carbon dioxide emissions from maritime transport, in view of an alignment with the IMO data collection system The Bahamas Shipowners Association (BSA) welcomes initiatives on the reduction of GHG emissions from…

The Japanese Shipowners’ Association would welcome the European Commission to revise EU MRV regulation. Recital 34 of the EU MRV Regulation states that a global MRV system is preferable as it could be regarded as more effective due to its broader scope and that where an agreement on a global MRV system is reached the Commission should review the regulation with a view to aligning it to the global MRV system.

We are happy to see the process initiated for alignment of EU MRV Regulations with IMO CO2 Data Collection System. A global system will be able to deliver far greater reduction in GHG emission than a regional one. It will also greatly reduce the administrative burden, time and cost on shipowners / operators and their seafarers of reporting different sets of data under two different regimes.

Oil Companies International Marine Forum (OCIMF) would like to thank the Commission for the opportunity to comment on the ‘Revision of the Shipping MRV Regulation’. OCIMF supports and welcomes this step to fully align the EU scheme with the IMO. OCIMF was a member of the ESSF MRV working group and in this forum highlighted key concerns regarding the lack of alignment between the EU and IMO system.

ICS welcomes revising the EU Shipping MRV Regulation in order align the EU MRV with the global IMO Data Collection System (DCS). The shipping industry is encouraged by the positive statements from the European Commission acknowledging the significant progress made by IMO Member States towards addressing GHG emissions from international shipping.

Prime Tanker Management Inc. considers that as the EU MRV of shipping emissions and the Data Collection System of International Maritime Organization are developed based on the same principles of the shipping sector and their technical scope is common in monitoring, reporting, verifying and finally reducing the emissions of CO2, the Full alignment between them is the only way that can assure feasibility, cost…

Maritime transport, which is the major transport mode in terms of volume transported, emits around 1000 million tonnes of CO2 annually and is responsible for about 2.5% of global greenhouse gas emissions. Shipping emissions are predicted to increase between 50% and 250% by 2050 – depending on future economic and energy developments.

On behalf of the Certification Committee of the European co-operation for Accreditation: Alignment of the EU MRV with a global system, IMO system, should focus on ensuring a harmonized and robust approach for verification of the requested data as well as to ensure the validity of the data. In that respect third party verification of the data is considered a must.

T&D Europe, the European Association of the Electricity Transmission and Distribution Equipment and Services Industry, welcomes the opportunity to respond to the inception impact assessment initiative in the context of the forthcoming revision of the Shipping MRV Regulation.

The International Parcel Tankers Association welcomes progress made at the International Maritime Organization in developing a strategy for addressing Greenhouse Gas emissions from shipping, and in particular the adoption in 2016 of the MARPOL amendments to introduce the Data Collection System. IPTA further welcomes the initiative to review the EU MRV regulation in accordance with Article 22 of the regulation.

EU shipping MRV has 3 main objectives: 1. Provide accurate and transparent bottom-up ship emissions data 2. Address market barriers for uptake of efficient ships 3. Incentivise operational efficiency ships by providing clear metrics for real transport work By moving first, the adoption of the EU MRV incentivised the IMO to start work on a global Data Collection System (DCS) and as such, this clear leadership by the…

Comments structured around the inception impact assessment document: A. Context, problem definition and subsidiarity check We agree that the administrative burden of possible double reporting requirements for the EU and IMO schemes is a concern if it does not bring any notable benefit in understanding and control of CO2 emissions.

The Swedish Shipowners Association is positive to the intent ofEU MRV, i.e. to determine the amount of CO₂ stemming from ships. We believe a data system is an important step to provide the necessary data as a basis for further actions to reduce absolute CO₂emissions.

The shipping industry is encouraged by the positive statements from the European Commission which acknowledge the significant progress made by IMO Member States towards addressing GHG emissions from international shipping. With the full support of the industry, IMO Member States have agreed inter alia to develop a comprehensive strategy for the further reduction of GHG emissions from shipping.

Extract from the attached joint position paper: The European Community Shipowners’ Associations and the International Chamber of Shipping - in conjunction with the Asian Shipowners’ Association, BIMCO, INTERCARGO INTERFERRY, INTERTANKO and the World Shipping Council welcome the revision of the EU Shipping MRV Regulation undertaken for the purpose to align the EU MRV with the global IMO Data Collection System (IMO…

Dear European Commission, Dear Lady/Sir, Thank you very much for sending me the roadmap. I have read the roadmap and propose the following proposals for further development of the living and living environment protection of the marine environment. Protection of the marine environment naturally affects the social and economic environment as well.

Mandatory fuel consumption data collection is scheduled for 2019 under Regulation 22A. In this regard, the International Maritime Organization (IMO) has adopted a mandatory fuel consumption data collection system for international shipping, requiring ships above 5,000 gross tonnage to start collecting and reporting data to an IMO database from the start of 2019.