Lloyd’s Register (LR) has issued guidance to clarify the implementation and reporting requirements associated with upcoming amendments to MARPOL Annex VI Appendix IX, set to take effect on August 1, 2025.
As explained by LR, these amendments, adopted through IMO Resolution MEPC.385(81), introduce additional data collection requirements for ships, including detailed fuel oil consumption data by consumer type, onshore power usage, laden distance traveled, and more. This additional data includes:
- Fuel oil consumption per consumer type and fuel type (including main engines, auxiliary engines etc)
- Fuel oil consumption while not underway per consumer type and fuel type
- Onshore power supplied to the ship
- Laden distance travelled (on a voluntary basis)
- Installation of innovative technologies
- Total transport work
IMO Resolution MEPC.385(81), which adopted these amendments in March 2024, invited flag States to apply the amendments early (from 1 January 2025) on a voluntary basis.
At the time of adopting these amendments, it was left unclear whether ships collecting the data required by the existing MARPOL Annex VI Appendix IX would need to collect and report the additional data from 1 August 2025 or another date.
Clarification of data collection dates
The IACS has adopted a Unified Interpretation (UI MPC131) which clarifies that additional data should not be collected and reported part way through a calendar year. In addition, the IMO has agreed to the same understanding, which is communicated in MEPC.1/Circ.913 (Guidance on the Application of the Amendments to Appendix IX of MARPOL Annex VI (Resolution MEPC.385(81)).
Collection of data for existing ships after 1 August 2025
Ships that hold a verified Ship Energy Efficiency Management Plan (SEEMP) Part II and are collecting the data within the current MARPOL Annex VI Appendix IX before 1 August 2025, are expected to continue collecting this data after 1 August 2025. This is to ensure the data collected and reported is consistent throughout the calendar year. In this case, Lloyd’s Register (LR) will request that these ships collect the additional data in the Annex to MEPC.385(81) from 1 January 2026.
Collection of data for new ships after 1 August 2025
For ships that enter service and start collecting data on or after 1 August 2025, it is expected that such ships will collect the data (including the additional data) in the Annex to MEPC.385(81) as they had not collected any data before the amendments entered force.
In this case, LR will request these ships to collect the data in the Annex to MEPC.385(81) from the date these ships enter service.
Verification of the SEEMP Part II
In any event, in accordance with MARPOL Annex VI Regulation 5, LR will request that the SEEMP Part II is verified before the subject ship collects the associated data.
- For existing ships: verification will be before 1 January 2026.
- For new ships: verification will be before the ship enters service.
- For any ship that is requested to collect the additional data, the SEEMP will need to be amended to reflect the method(s) that will be used to collect the additional data, taking into account the 2024 Guidelines for the Development of a Ship Energy Efficiency Management Plan (SEEMP) (MEPC.395(82)).
Early Implementation by flag States
Where a ship is registered with a flag State that implements the amendments in MEPC.385(81) before 1 August 2025, the SEEMP Part II is to be amended to reflect the method(s) to which the additional data will be collected and for the SEEMP Part II to be verified before the date set by the flag State for early implementation.
