Due to Brexit, EU MRV no longer applies to ships visiting UK ports. As such, UK is no longer part of the EU MRV regime but it has retained and amended the EU legislation with the establishment of an identical scheme, the UK MRV scheme, to monitor, report and verify emissions data from ships calling at UK ports.
QE MARINE consulting firm has issued circular to provide guidance to ship operators in order to revise the existing verified EU MRV plans and include additional guidance for UK MRV legislation and reporting requirements.
In particular, the UK has released MIN 669 (M+F) Reporting Emissions Data into the UK MRV Regime, to cover the collection and reporting requirements for CO2 emissions. UK Monitoring, Reporting, and Verification (MRV) Regime includes the obligation for ship operators and verifiers to collect and report CO2 emissions data.
Key legal requirements under the UK MRV regime
Subject to the UK MRV regime are the ships over 5,000 gross tn, transporting cargo and/or passengers for commercial purposes during:
- Voyages between two UK ports
- Voyages between a UK and non-EEA port
- Emissions generated at a UK port for the above voyages
Voyages between a port in the UK and a port in one of the UK overseas territories or Crown dependencies – such as the Falkland Islands, Gibraltar, Isle of Man, Jersey – need to be monitored and reported under the UK MRV regime. However, ports in these overseas territories do not count as UK ports under the UK MRV regime. So, voyages between two Crown dependencies or overseas territories – such as between Jersey and Guernsey – should not be included. Likewise, a journey from a port in an overseas territory or Crown dependency to a non-UK port should not be included.
Same exceptions apply to vessels under the UK MRV regime (e.g. for warships), that apply under the EU MRV regime. Ship operators must have in place an assessed monitoring plan before data collection begins. 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. The verifier must be accredited by the United Kingdom Accreditation Service (UKAS). Each ship must have its emissions monitored and its data collected for each reporting period, ready for verification. Ship operators should begin collecting emissions data for their ships under the UK MRV regime from 1 January 2022.
- By 30 April following each reporting period, a verified emissions report must be submitted to the UK Administration covering the previous reporting period.
- By 30 June following each reporting period, a valid Document of Compliance (DoC) must be carried on board each vessel covering the previous reporting period.
No emissions data should be supplied for 2021 for the UK MRV regime, although data for voyages between the UK and countries in the EEA should still be reported to the European Commission under the EU MRV regime. Any emissions data for voyages to and from UK ports in 2020 should have been reported to the European Commission by April 2021. To avoid duplication, data for voyages between UK and EEA ports, and vice-versa, should continue to be submitted to the European Commission under the EU MRV regime. The UK no longer has access to the EU’s THETIS-MRV database. Data reports will be entered into a separate emissions database which is under development.
Ship managers and operators should be aware of the new UK legislation and revise their EU MRV plans to include guidance and reporting requirements for UK ports as below:
- Ensure Verifier already is UKAS-accredited or plans to be UKAS-accredited by 31 Dec 2022.
- Update EU MRV Monitoring Plan to include UK MRV requirements by 31 Dec 2021.