Reducing Greenhouse Gas Emissions: A Guide to IMO Regulatory Compliance

Shipping – as one the world’s largest transport sectors – will go through major technical and operational changes to achieve the CO2 reduction targets for 2030 agreed by the UN International Maritime Organization (IMO). This new publication from ICS guides readers through the first step on the route to decarbonisation: preparing for compliance with the IMO regulatory framework, and in particular, the 2021 amendments to MARPOL Annex VI.

Reducing Greenhouse Gas Emissions: A Guide to IMO Regulatory Compliance sets out plainly what the key regulatory changes are for shipowners, operators and managers. Taking account of the IMO implementation guidelines adopted in June 2022, it explains in detail the full range of additional technical and operational requirements which ships must now comply with, including:

Reductions of carbon intensity through the use of the Energy Efficiency Design Index for new ships (EEDI) and the Energy Efficiency Existing Ship Index (EEXI);

Submission of the Ship Energy Efficiency Management Plans (SEEMP) for external audit and statutory certification; and

Use of operational Carbon Intensity Indicators (CIIs) and the collection and submission of operational data, with ships being designated annually with an ‘A to E’ rating.

All technical managers, superintendents and crew of vessels subject to the regulations, particularly MARPOL Annex VI, should read this guide. It will also be valuable to those involved in the design of new ships and modification of existing ships, including naval architects.

Foreword:

At the United Nations Climate Summit in Glasgow, in November 2021, the International Chamber of Shipping (ICS) committed the global shipping sector to achieving net zero carbon emissions by 2050. As part of worldwide efforts to mitigate dangerous climate change, ICS fully supports delivery of the greenhouse gas (GHG) reduction targets for international shipping as agreed by its global regulator, the UN International Maritime Organization (IMO). Individual shipping companies therefore need to prepare for a decarbonised future.

As a consequence of the Initial IMO Strategy on the Reduction of GHG Emissions from Ships, agreed by IMO Member States in 2018, important amendments were adopted in 2021 to Annex VI of the International Convention for the Prevention of Pollution from Ships (MARPOL), the principal IMO instrument addressing air pollution from ships. These 2021 amendments to MARPOL Annex VI are supported by guidelines on implementation agreed by the IMO Marine Environment Protection Committee (MEPC), the most recent having been adopted in June 2022.

These important new IMO regulations on energy efficiency introduce additional technical and operational CO2 reduction measures applicable to the existing fleet with a global entry into force date of 1 November 2022. Shipping companies will need to be ready to comply. But adherence by shipping companies to these new IMO requirements will also be a matter of enlightened self-interest as they will help to further minimise fuel consumption – a shipping company's greatest cost.

This ICS guide is primarily intended for shipping companies and ships’ crews, to help them understand the IMO regulatory framework and its evolutions, including the 2021 amendments to MARPOL Annex VI, and to support decision-making on compliance with the latest mandatory requirements.

The guide is structured in four main chapters:

• Chapter 1 provides an overview of the ship energy efficiency regulatory framework adopted by IMO;

• Chapter 2 focuses on the key technical concepts supporting this framework;

• Chapter 3 covers the new regulations including the 2021 amendments to MARPOL Annex VI (as well as existing IMO regulations on GHG reduction by ships) with detailed guidance on compliance; and

• Chapter 4 contains practical information on efficiency improving solutions, that may help shipping companies achieve compliance with the IMO regulations.

Appendix B contains the long and short titles (used in this ICS guide) of all relevant IMO guidelines as well as other useful guidance documents which are currently available.

In view of the ongoing development and regular changes being made to the IMO regulatory framework for GHG emissions, and to take account of experience gained during the initial implementation of these new requirements, an early revision of this guide is anticipated. If shipping companies or other stakeholders have any comments or suggestions that might help to improve the next edition, please contact ICS: publications@ics-shipping.org.

Acknowledgements

The assistance of Marie Caillerie, NauticalLex, in the production of this guide is gratefully acknowledged.

Abbreviations

Definitions

Chapter 1

Introduction 13

1.1 Overview

1.2 Air pollution from ships

1.3 Development of the 2018 Initial IMO GHG Strategy

1.4 Content of the Initial IMO GHG Strategy

1.5 Annex VI of MARPOL Convention

1.5.1 History of MARPOL Annex VI

1.5.2 2021 Revised MARPOL Annex VI

1.6 Expected developments

1.6.1 Carbon Intensity Code (CIC)

1.6.2 Lifecycle assessment (LCA) guidelines

1.6.3 GHG fuel standard (GFS) or low carbon fuel standard (LCFS)

Chapter 2

Key concepts 25

2.1 Overview

Timeline to compliance

2.2 Energy Efficiency Design Index (EEDI)

2.2.1 EEDI: Key facts

2.2.2 ‘Attained EEDI’ formula

2.2.3 ‘Attained EEDI’ correction factors

2.2.4 EEDI reduction rates and reference value

2.2.5 EEDI in practice

2.2.6 Ship minimum propulsion power

2.2.7 EEDI database and reporting requirements

2.3 Energy Efficiency Existing Ship Index (EEXI)

2.3.1 EEXI: Key facts

2.3.2 ‘Required EEXI’ reduction rates and reference line

2.3.3 ‘Attained EEXI’ formula

2.3.4 Challenges with some parameters

2.3.5 Compliance with EEXI in practice

2.4 Carbon Intensity Indicators (CII)

2.4.1 CII: Key facts

2.4.2 ‘Attained CII’ calculation

2.4.3 Correction factors and voyage adjustment

2.4.4 ‘Required CII’

2.4.5 CII ratings for ship performance

2.4.6 Compliance with CII framework

2.5 Ship Energy Efficiency Management Plan (SEEMP)

2.6 Data Collection System for Fuel Oil Consumption of Ships (DCS)

2.6.1 Fuel oil consumption

2.6.2 Annual operational CII

Chapter 3

MARPOL ANNEX VI regulations, including the 2021 amendments 67

3.1 Overview

3.2 General provisions in MARPOL Annex VI

3.2.1 General application and definitions

3.2.2 Exemptions

3.3 MARPOL Annex VI, Chapter 4: Regulations on carbon intensity for international shipping

3.3.1 Application

3.3.2 Goal-based regulations

3.3.3 Regulations 22 and 24 – EEDI

3.3.4 Regulations 23 and 25 – EEXI

3.3.5 Regulation 26 – SEEMP

3.3.6 Regulation 27 – Collection and reporting of ship fuel oil consumption data

3.3.7 Regulation 28 – Operational carbon intensity

3.4 Survey, certification and means of control

3.4.1 Introduction to MARPOL Annex VI, Chapter 2 regulations

3.4.2 Steps for the EEXI certification

3.4.3 Documentation and audits under the CII framework

3.4.4 Port State Control (PSC)

Chapter 4

Efficiency improving solutions 107

4.1 Overview

4.2 How to categorise solutions

4.2.1 Improving a ship’s EEDI, EEXI or CII value

4.3 Machinery

4.3.1 Power limitation devices and engine de-rating

4.4 Ship hydrodynamics

4.4.1 Hull

4.4.2 Propellers and rudders

4.5 Other energy saving solutions and assisted propulsion

4.5.1 Retrofitting options

4.5.2 Propulsion assistance

4.6 Operations optimisation (best practices)

4.6.1 Autopilot adjustment and use

4.6.2 Trim optimisation

4.6.3 Ballast operations management

4.6.4 Voyage optimisation

4.6.5 Speed management

4.6.6 ‘Just in time’ arrivals

4.6.7 Hydraulic system management

4.6.8 Main engine performance optimisation

4.6.9 Steam production

4.6.10 Electrical load management

4.6.11 Digital solutions

4.7 Alternative fuels

4.7.1 Fuel lifecycle

4.7.2 Fuel quality

Appendices 131

Appendix A The 2018 Initial IMO GHG Strategy

Appendix B IMO references and useful resources

Appendix C GHG reduction potential of available solutions

Appendix D Checklists for managers

ICS

The International Chamber of Shipping (ICS) is the principal international trade association for the shipping industry, representing shipowners and operators in all sectors and trades. ICS membership comprises national shipowners' associations in Asia, Europe and the Americas whose member shipping companies operate over 80% of the world's merchant tonnage.

Established in 1921, ICS is concerned with all technical, legal, employment affairs and policy issues that may affect international shipping.

ICS represents shipowners with the various intergovernmental regulatory bodies that impact on shipping, including the International Maritime Organization.

ICS also develops best practices and guidance, including a wide range of publications and free resources that are used by ship operators globally.

https://www.ics-shipping.org/about-ics/

Witherbys

Witherbys titles are developed using scripts developed by technical experts that are peer reviewed within work groups. Typically, they seek to improve understanding of the regulations, recommendations and guidelines issued by Industry.

Witherbys staff have significant expertise in the fields of navigation and hazardous cargoes as well as in the presentation of complex subjects in a graphic and easy to understand manner.