IMO: guidance on MARPOL Annex VI fuel data reporting amendments

The International Maritime Organization published MEPC.1/Circ.913 providing guidance on implementing amendments to Appendix IX of MARPOL Annex VI, focusing on enhanced granularity in fuel consumption data collection and reporting under the IMO Ship Fuel Consumption Database (IMO DCS). These amendments, adopted in resolution MEPC.385(81), aim to improve the accuracy and uniformity of data reporting for emissions monitoring and compliance.

Since 2019, ships of 5,000 gross tonnage and above have been required to collect and report annual or partial-year data on fuel consumption, as outlined in their Ship Energy Efficiency Management Plan (SEEMP). The recent amendments emphasize collecting more detailed data on transport work and operational metrics, requiring updates to SEEMP methodologies to ensure compliance. The 2024 Guidelines for SEEMP development (resolution MEPC.395(82)) provide the framework for these updates.

Key Changes and Requirements

Regulations Updates:

Regulations 27.1 and 27.2 of MARPOL Annex VI mandate consistent data collection and reporting at the same level of granularity for each calendar year.
Regulation 26.2 requires the SEEMP to specify how data will be collected and reported.
Regulation 5.4.5 requires flag Administrations to confirm SEEMP compliance before ships begin reporting.

Implementation Timeline:

Early Implementation (1 January 2025):
- SEEMPs must be updated and verified to incorporate enhanced granularity methodologies.
- Ships must retrofit equipment like flow meters, if needed, and begin collecting enhanced granularity data in 2025.
Standard Implementation (1 August 2025):
- SEEMPs must be updated by 1 January 2026.
- Data for 2025 will follow the existing granularity levels, with enhanced granularity required starting in 2026.
- Ships delivered on or after 1 August 2025 must immediately comply with enhanced data requirements.
Stakeholder Actions:
- Administrations: Ensure SEEMP revisions and verify compliance before the implementation deadlines.
- Shipowners and Operators: Update SEEMPs, retrofit equipment, and adjust data collection methodologies as needed.
- Masters and Crew: Implement and follow the revised data collection and reporting processes.