EU MRV and IMO DCS Regulations


( In order to reduce emissions from shipping, the European Union (EU) has introduced the shipping Monitoring, Reporting and Verification (MRV) regulation, which is designed to gather data on CO2 emissions based on ships’ fuel consumption.

It is considered the first step of a staged approach for the inclusion of maritime transport emissions in the EU’s GHG reduction commitment. The MRV regulation entered into force in July 2015.

In parallel, the IMO has introduced a three-step approach, based on collecting and analysing fuel consumption data, before agreeing what further actions may be required to reduce GHG emissions from ships. Through amendments to MARPOL Annex VI, the IMO Data Collection System (DCS) came into effect in March 2018.

Two new sets of regulations, running on two different timescales, present a big challenge for shipowners and operators.

TThe new Regulation 22A of MARPOL Annex VI applies to all ships of 5,000 GT and above engaged on international voyages.

The regulation does not apply to:

  • Ships engaged on domestic voyages;
  • Ships not propelled by mechanical means; and
  • Platforms, including FPSOs, FSUs and drilling rigs.

In case the ship is typically engaged on domestic voyages and exceptionally requires to undertake a single international voyage, an exemption from the Administration shall be issued (refer to the IMO MEPC.1/Circ.863 for guidance).

 As required by the new Regulation 22A of MARPOL Annex VI:

  • From calendar year 2019 (i.e. 01/01/2019 to 31/12/2019), each ship of 5,000 gross tonnage and above shall collect the data in a predefined form, for that and each subsequent calendar year or portion thereof, as appropriate, according to the methodology included in the SEEMP.
  • At the end of each calendar year, the ship shall aggregate the data collected in that calendar year or portion thereof, as appropriate.
  • Within three months after the end of each calendar year, the ship shall report to its Administration or any organization duly authorized by it, the aggregated value for each datum, via electronic communication and using a standardized format.
  • Upon verification of the submitted data, the Administration or any organization duly authorized by it will issue to the ship by 31st of May a Statement of Compliance related to fuel oil consumption.
  • Finally, the Administration will submit aggregated data to the IMO, which will maintain an anonymized IMO Ship Fuel Oil Consumption Database.

In order to collect the required data a new SEEMP Part II has to be developed to outline the methodology used to collect fuel oil consumption data.  The SEEMP Part II shall include information of fuel oil consumption by the main engines, auxiliary engines, gas turbines, boilers and inert gas generator, for each type of fuel oil consumed, regardless of whether a ship is underway or not.

Methods for collecting data on annual fuel oil consumption in metric tonnes include:

  • Method 1: using bunker delivery notes (BDNs)
  • Method 2: using flow meters
  • Method 3: using bunker fuel oil tank monitoring on board
  • Method 4: direct CO2 emissions measurement (is not required by Regulation 22A of MARPOL Annex VI but may be used).

In addition SEEMP Part II shall include methods to measure distance travelled, hours underway, process that will be used to report the data to the Administration and other information.

SEEMP Part II must be developed following the IMO MEPC.282(70) that includes guidelines for the development of a data collection plan.

Finally, it is recommended that maritime companies upgrade their available IT tools to ensure data is collected for all ships worldwide consistently.

One common platform / data collection process should result in two separate reports:

  1. EU MRV Emissions Report, and
  2. IMO DCS Fuel Data Report.

Comparison of EU MRV and IMO-DCS

Timelines of EU MRV and IMO-DCS


Click below to download the relevant Guidance available from LR.

  1. LR Guidance on the EU MRV regulation and the IMO DCS for shipowners and operators

Source: IMO, EU, Lloyd's Register


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  1. Unless I have missed something measuring fuel consumed and using a formula to ascertain emissions is the basis of the Regulators.

    This method may provide an indication of the state of the ship’s engine but it does not tell you what other gases are being emitted.

    In terms of cars & lorries, we have all seen those polluters pumping out black smoke. If we used fuel consumption as a measure of emissions, what would it tell us. In Dutch cities they have land based monitors for cars & lorries entering cities, perhaps a more accurate method.

    There are companies that produce emissions monitors placed on ships that transmit the data to the ship owners, which can be shared with the Regulators. A much more accurate method.