Main decisions from the 81st session of the IMO MEPC published by RINA

RINA has published a report from the 81st session of the IMO Marine Environment Protection Committee (MEPC 81) that was held from 18 to 22 March 2024.

RINA is a founding member of IACS (International Association of Classification Societies) and operates on behalf of 122 flag authorities. In addition to the provision of classification and statutory certification, RINA delivers value-added services to the shipping industry and is rated among the top-performing classification societies.

The main decisions taken are summarized below on the basis of the information obtained while following the debate:

MEASURES TO REDUCE GHG EMISSIONS FROM SHIPS

Progress on mid-term measures

Based on the discussions during the Intersessional Working Group on GHG (ISWG-GHG16) and MEPC 81, agreement has been reached to develop, as part of mid-term measures basket, the following:

• a goal-based marine fuel standard based on the well-to-wake GHG emissions of marine fuels and including flexible compliance mechanisms (e.g. transaction of over-compliance units, the cancellation of remedial units, and pooling); and
• an economic element, based on a GHG emissions pricing mechanism to effectively promote the energy transition and provide the world fleet a needed incentive while contributing to a level playing field and a just and equitable transition.

Additional work on the above will be carried out intersessionally before MEPC 82 (October 2024) and during the two-day expert workshop (GHG-EW 5) and intersessional Working Group on GHG (ISWG-GHG17).

Guidelines on life cycle GHG intensity of marine fuels (LCA Guidelines)

The LCA Guidelines are modified (Res. MEPC.391(81)) to introduce – inter alia – the following:

• parameters related to biofuel production, evaluation of carbon GHG intensity of electricity and the tank-to-wake methodologies for actual/onboard emission factors (sections 4, 5, 9 and 10, and Appendix 3);
• the “Template for well-to-tank default emission factor submission” (Appendix 4) and new “Template for tank-to-wake emission factors” (Appendix 5).

The remaining LCA-related issues (e.g. certification, accounting of CO2 captured), will be further intersessionally addressed and the scientific and technical issue by the GESAMP Working Group on Life Cycle GHG Intensity of Marine Fuels.

Onboard Carbon Capture and non-CO2 GHG emissions

The Committee agreed to develop a regulatory framework for the use of onboard Carbon Capture. A CG is established to advance on this issue and on the measurement and verification of non-CO2 GHG emissions (i.e. methane and nitrous oxide emission factors and Cslip value for energy converters).

AMENDMENTS TO MANDATORY INSTRUMENTS

Amendments to MARPOL Annex VI entering into force on 1 August 2025

The amendments to MARPOL Annex VI (Res. MEPC.385(81)) mainly concern:

1. NOx Tier requirement (Reg.13) in case of a marine diesel engine replacing a steam system. In this case, the engine is to be considered as a replacement engine which may be according to Tier II instead of Tier III in those cases foreseen by the “2024 Guidelines in respect of non-identical replacement engines not required to meet the Tier III limit” (Res. MEPC.386(81)). The Administration shall notify the IMO in case of instances where a Tier II rather than a Tier III replacement engine has been installed on or after 1 August 2025;

2. SOx sampling point requirements (Reg.14), clarifying that the sampling point requirements do not apply to systems used for low-flashpoint fuel or gas fuel. Consequential modifications are included in the Form of IAPP Certificate;

3. Bunker Delivery Note requirements of ʺlow-flashpoint fuelʺ (Reg.18), clarifying that BDN shall comply with a limited number of information respect to those included in Appendix V (items 1 to 6);

4. Information to be submitted to the IMO Ship Fuel Oil Consumption Database (App. IX), adding more detailed information, such as

• the distinction of fuel oil consumed (total fuel consumption and fuel consumption when the ship is not underway) per main category of combustion system (i.e. main engine(s), auxiliary engine(s)/generator(s), oil-fired boilers);
• the installation of innovative technologies; and
• the total transport work data, using actual tonne-mile, TEU-mile and/or passenger-mile data.

The Committee agreed to give the possibility to early implement such modifications from 1 January 2025.

Consequential amendments to the 2022 SEEMP Guidelines (Res. MEPC.388(81)) and 2022 Guidelines for Administration verification of ship fuel oil consumption data and operation carbon intensity (Res. MEPC.389(81)) have been adopted. Moreover, pending future policy decisions concerning the application of the LCA Guidelines, biofuel should be reported in DCS with a user defined name and CF factor under the "Other" fuels category.

Amendments to Article V of Protocol I of MARPOL Convention entering into force on 1 January 2026

In line with the draft reporting requirements in SOLAS Chapter V on lost freight container approved by MSC 107 (see RINA MNO 200), Article V is amended (Res. MEPC.384(81)) to read: “In case of the loss of freight container(s), the report required by Art. II(1)(b) shall be made in accordance with the requirements on danger messages as provided for in SOLAS Reg.s V/31 and V/32."

Amendments to the BWM Convention entering into force on 1 October 2025

The amendments to the BWM Convention (Res. MEPC.383(81)) modify Reg.s A-1 and B-2, to allow the use of Ballast water record book according to the Guidance for the use of electronic record books under the BWM Convention (Res. MEPC.372(80), as may be amended)

DRAFT AMENDMENTS APPROVED IN VIEW OF THEIR ADOPTION AT MEPC 82 (OCTOBER 2024)

Draft amendments to MARPOL Annex VI

The draft amendments to MARPOL Annex VI modify Reg.s 13, 14 and Appendix VII to designate two new Emission Control Area for the control of nitrogen oxides (NOx), sulphur oxides (SOx) and particulate matter (PM):

1. Norwegian Sea for ships constructed on or after 1 March 2026, meaning ships

• for which the building contract is placed on or after 1 March 2026; or
• in the absence of a building contract, the keel of which is laid or which is at a similar stage of construction on or after 1 September 2026; or
• the delivery of which is on or after 1 March 2030;

2. Arctic water under Canadian sovereignty and jurisdiction for ships constructed on or after 1 January 2025.

RECOMMENDATORY INSTRUMENTS ADOPTED/APPROVED

Unified interpretation of MARPOL Annex VI

The amendments to the Unified interpretation to MARPOL Annex VI (MEPC.1/Circ.795/Rev.9) include:

• specification of the applicable required EEDI of each Phase for: LNG carrier, cruise passenger ship, ro-ro passenger ship, ro-ro cargo ship (vehicle carrier) and ro-ro cargo ship, delivered on or after 1 September 2019; and
• definition of "heavy load carrier”.

Guidance on the temporary storage of treated sewage and/or grey water (TS/GW) in ballast water (BW) tanks

The Guidance (BWM.2/Circ.82) includes a procedure in case of temporary storage of TS/GW in BW tanks to be used as an option in specific ports and areas which restrict the discharge of TS/GW and where the ship does not have dedicated tanks with adequate storage capacity for TS/GW.

The procedure describes the steps to be followed based on the following principles:

• the discharge of BW should be in compliance with BWM Convention;
• the discharge of TS should be in compliance with MARPOL Annex VI and any local relevant requirements;
• the hull strength and stability of the ship should not be compromised;
• In case a ship stores TS/GW temporarily in BW tanks, the ship should make periodic inspections for those BW tanks coatings and take measures to prevent impacts;
• the ship-specific change-over procedure, from BW storage to TS/GW storage and back to BW storage, including pump and piping associated with the dual-purpose BW tanks, with specific details on how the flushing is conducted, should be included in the Ballast Water Management Plan (BWMP);
• the BW tanks to be used for temporary storage of TS/GW should be identified in BWMP;
• the BW Record Book should have an entry made under the appropriate code related to additional operation procedures and general remarks.

Shaft/engine power limitation system to comply with the EEXI requirements and use of a power reserve

The following is agreed:

1. the amendments to the 2021 Guidelines (Res. MEPC.390(81)) including:

• additional technical requirements for the control unit for calculation and limitation of the power transmitted by the shaft to the propeller(s) if it is independent from the engine automation (e.g. alarm on the bridge; automatic data recording in case of deliberate use of power reserve; and maximum 5 minutes inhibition time for the exceedance alarm in case of short-term unintentional exceedance of the power limit the system) (para. 2.1.1.3);
• clarifications on the conditions in which the use of a power reserve would be allowed (i.e. scenario in MARPOL Annex VI Reg. 3, which may endanger safe navigation of the ship) (para.s 2.2.1, 3.1 and 3.3)
• requirement to update of the appendices to "Recommendation on the Provision and Display of Manoeuvring Information on Board Ships” to include the manoeuvring characteristics of the ship when the ship has all shaft and engine power available, and when shaft or engine power has been limited (new para. 6).

2. the reporting procedure to be used by the Administration when annually report the uses of power reserve to the IMO (MEPC.1/Circ.908).

OTHER RESOLUTIONS AND CIRCULARS ADOPTED/APPROVED

• Res. MEPC.387(81) – Interim Guidance on the application of the BWM Convention to ships operating in challenging water quality conditions
• MEPC.1/Circ.909 Recommendations for the carriage of plastic pellets by sea in freight containers
• MEPC.1/Circ.910 Formats for mandatory reports under article 12 of the Hong Kong Convention

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