The European Union’s Monitoring, Reporting and Verification Regulation (EU MRV regulation) was revised in 2023 to allow shipping to be included in the EU Emissions Trading System (EU ETS).
According to Lloyd’s Register (LR) the revision included the provision that offshore ships of 400GT and above, and general cargo ships of 400GT and above, but less than 5,000GT, will be included within the scope of EU MRV from 1 January 2025.
As such, Monitoring Plans for relevant ships must be developed and verified by 31 December 2024.
Scope of MRV
For voyages regulated by EU MRV – i.e. to and from EEA Member States (the EU plus Norway and Iceland), as well as within EEA ports – ships’ greenhouse gas emissions (CO₂, CH₄ and N₂O) are required to be monitored and reported each calendar year and verified by an accredited verifier. Please see EU ETS and EU MRV for more information.
Definition of general cargo ships under EU MRV
A general cargo ship is defined in Regulation (EU) 2016/1928 as “a ship with a multi-deck or single-deck hull designed primarily for the carriage of general cargo excluding specialised dry cargo ships, which are not included in the calculation of reference lines for general cargo ships, namely livestock carrier, barge carrier, heavy load carrier, yacht carrier, nuclear fuel carrier”.
Definition of offshore ships and requirements under EU MRV
Clarification on the inclusion of offshore ships in MRV has been provided by the European Commission in a delegated act.
Based on the delegated act the following ships – other than icebreakers – designated or certified to perform service activities offshore or at offshore installations, are considered as an offshore ship:
(a) anchor handling tug supply vessel;
(b) offshore supply ship;
(c) crew/supply vessel;
(d) pipe carrier;
(e) platform supply ship;
(f) drilling ship;
(g) floating production storage and offloading (FPSO), oil;
(h) gas processing vessel;
(i) floating storage and offloading (FSO), gas;
(j) FSO, oil;
(k) accommodation ship;
(l) diving support vessel;
(m) offshore construction vessel;
(n) offshore support vessel;
(o) pipe burying vessel;
(p) pipe layer;
(q) pipe layer crane vessel;
(r) production testing vessel;
(s) standby safety vessel;
(t) trenching support vessel;
(u) well stimulation vessel;
(v) cable layer;
(w) cable repair ship;
(x) mining vessel;
(y) wind turbine installation vessel;
(z) commissioning service operation vessel;
(aa) service operation vessel;
(ab) work/repair vessel;
(ac) research survey vessel;
(ad) dredger;
(ae) hopper dredger.
The regulation stipulates that the ship’s statutory certification or any other relevant documentation, including class notations, should be considered when determining whether the ship is designed or certified to perform service activities offshore or at offshore installations. It is anticipated that further guidance from the European Commission will follow to support the implementation of offshore ships into EU MRV.
Future inclusion of larger offshore ships into EU ETS
From 1 January 2027, offshore ships of 5,000GT and above will also fall in scope of the EU ETS requirements. As such, by 20 September 2028, sufficient EU emissions allowances (EUAs) must be surrendered to cover the 2027 emissions at the company level.
Next steps required
For any general cargo ships or offshore ships which are now in scope of MRV requirements, the shipowners or ship managers designated as responsible for compliance with MRV will need to take the following steps:
Develop a Monitoring Plan and get it verified
By 31 December 2024, a Monitoring Plan must be developed for each ship now in scope of MRV, ensuring that provisions for monitoring of CO₂, CH₄ and N₂O are included. These monitoring plans should also be verified by an accredited verifier by this date.
Submit the Monitoring Plan
No later than three months after the ship’s first port of call to the EEA (thereby bringing it in scope of MRV requirements), a verified Monitoring Plan must be submitted to your relevant Administering Authority for approval. As an example, for a ship that first visits the EEA on the 15 February 2025, the Monitoring Plan submission should be no later than three months after this date.
Start emissions data collection
From 1 January 2025, emissions data collection, as per the monitoring plan requirements, should begin.
Verify data collected
No later than 30 March 2026, data collected in 2025 should be verified by your appointed verifier.
Open a MOHA
For ships falling in scope of ETS reporting requirements, it is recommended that a Marine Operator Holding Account (MOHA) is opened as soon as possible during the year of data collection. The MOHA is required to enable verified company level emissions to be reported and corresponding EU Allowances (EUAs) surrendered, thereby maintaining compliance with ETS requirements.
