As a result of Brexit, EU MRV no longer applies to ships visiting UK ports. More specifically, the UK Government, on 17 September, released guidance on the application of its own scheme for monitoring, reporting and verifying (UK MRV) carbon dioxide (CO2) emissions.
The type of vessels within scope of the UK MRV regime and type of emissions data for collection are the same as those under the EU MRV regime.
According to UK MCA, in order to avoid duplication of the collection of CO2 emissions data, voyages between the UK and EEA ports, and vice versa, will not be expected to be reported under the UK MRV regime. Data on these voyages should continue to be submitted to the European Commission under the EU MRV regime.
Furthermore, 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 and Jersey), or vice versa, are considered to be a voyage to or from a non-EEA port and the associated data would be included within the UK scheme.
Although the legislation underpinning the UK MRV regime envisages data being collected from 2021, the Department recognises it would not be possible for ship operators and verifiers to comply with these obligations without further preparation
says the UK MCA.
Consequently, UK MCA asks operators and verifiers to use this year to prepare their systems and procedures to begin collecting emissions data for the 2022 reporting period.
We do not expect any emissions data to be collected or reported for the 2021 reporting year whilst preparations are being finalised. Therefore, no enforcement action will be taken by the MCA until 2023
Key legal requirements under the UK MRV regime
- Ships over 5,000 gross tonnes, transporting cargo and/or passengers for commercial purposes to and from UK ports, between UK ports or within UK ports (including while at berth), are subject to the UK MRV regime.
- The 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.
- 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.
- A DoC issued under the EU MRV regime and which covers voyages between the UK and European Economic Area (EEA) ports is recognised as a UK DoC equivalent for those voyages only.
- There are requirements on the Administration to make MRV data available and report annually on the findings.
Approach to practical establishment of the UK MRV scheme
Although the UK is no longer part of the EU MRV regime, it has retained and amended EU legislation, so that it establishes a UK MRV regime to monitor, report and verify emissions data from ships calling at UK ports.
The main elements in the establishment of the new regime which stakeholders should be aware of are that:
- Ship operators should begin collecting emissions data for their ships under the UK MRV regime from 1 January 2022.
- 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.
- The type of vessel within scope of the UK MRV regime and type of emissions data for collection will be the same as those under the EU MRV regime.
- To avoid duplication, we will not be expecting data for voyages between UK and EEA ports, and vice-versa, to be reported under the UK MRV regime. Data on these voyages should continue to be submitted to the European Commission under the EU MRV regime.
- Emissions data for voyages between UK ports, between UK and non-EEA ports, and vice-versa, and from vessels at berth in a UK port will need to be included in the UK MRV emissions report.
- From 30 June 2023, a separate DoC will be needed by ship operators to cover voyages to and from UK ports, made in the previous reporting period, which fall outside the scope of the EU MRV.
- From 1 January 2023, all verifiers must be accredited by the United Kingdom Accreditation Service (UKAS) – ship owners should check the status of their verifier(s).
- An assessed UK MRV monitoring plan needs to be in place by 31st December 2021. If a ship already uses a monitoring plan under the EU MRV regime, the ship operator should confirm with the verifier if this is suitable for the UK MRV regime, or if changes are needed.
- 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.
From 1 July 2021, ships which used a UK or EEA port in 2020, should now carry a DoC for emissions data collected during the 2020 reporting period, to comply with the EU MRV regime.
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