UK MRV reporting requirements to be delayed until 2025

Following Brexit, the UK no longer has access to the EU’s THETIS-MRV database. The UK is developing a database that can receive MRV data, but according to ABS, this is not expected to be ready until 2025.

As such, ABS reports that the UK’s Department for Transport (DfT) has taken a decision to delay the requirement for ship operators to report emissions until the digital reporting system is fully operational. However, the legal requirement for ship operators to monitor vessel emissions remains in place.

According to North Club, key legal requirements under the UK MRV regime include:

• The UK MRV applies to ships over 5,000 gross tonnage, irrespective of their Flag State or where the ship operator is registered, transporting cargo and/or passengers for commercial purposes to and from UK ports, between UK ports or within UK ports (including while at berth).
• Categories of ships exempted include warships, naval auxiliaries, fish-catching or fish-processing ships, ships not propelled by mechanical means, and government ships used for non-commercial purposes.
• Some ship movements, such as the extraction and carriage of dredged material, laying or repairing cables and supporting offshore installations are not subject to the UK MRV requirements
• Ship operators must have an assessed monitoring plan in place by 31 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 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).

Reporting obligations

UK authorities will require ship operators to begin collecting emissions data from 1 January 2022. They do not expect any emissions data to be collected or reported for the 2021 reporting year whilst preparations are being finalised.

They request, however, that ship operators and verifiers use 2021 to prepare their systems and procedures.

Therefore, no enforcement action will be taken by the MCA until 2023.

Voyage and emissions data required

According to the North P&I Club, the data to be monitored on a per-voyage basis is the same as that required under the EU MRV scheme. This includes:

• Port of departure and port of arrival
• Date and hour of departure and arrival
• Amount and emission factor for each type of fuel consumed
• CO2 emitted
• Distance travelled
• Time spent at sea
• Cargo carried
• Transport work

Similarly, the UK MRV mirrors the EU MRV with regard to monitoring emissions on an annual basis. These are:

• The amount and emission factor for each type of fuel consumed in total
• Total aggregated CO2 emitted within the scope of the Regulation.
• Aggregated CO2 emissions from all voyages between ports in the UK.
• Aggregated CO2 emissions from voyages which departed from ports in the UK (except those going to a port in the EEA)
• Aggregated CO2 emissions from voyages to ports in the UK (except those originating from a port in the EEA)
• CO2 emissions which occurred within ports in the UK at berth
• Total distance travelled
• Total time spent at sea
• Total transport work
• Average energy efficiency

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