(www.MaritimeCyprus.com) In October 2016, the International Maritime Organization’s (IMO) Marine Environmental Protection Committee, at its 70th session (MEPC 70) adopted, by resolution MEPC.278(70), the IMO ship fuel oil consumption system (IMO DCS), which consists of requirements for ships to record and report their fuel oil consumption with a view to inform further IMO measures to reduce GHG emissions from ships.
Starting from 1 January 2019, ships of 5,000 GT and above (which produce approximately 85% of the total CO2 emissions from international shipping ) are required to collect and report annually the:
- Fuel oil consumption by type
- Distance travelled
- Hours under way
- Other specified operational data
By March 31st of each following year, the above data must be submitted to the ship’s flag State or the DCS Verifier. After the DCS Verifier received and verified the data it will issue a Statement of Compliance to the ship by the 31st of May the same year. The data is then forwarded to the IMO Ship Fuel Oil Consumption Database within a month or by the 30th of June; completing the annual reporting cycle under the IMO Data Collection System.
Since 2023, the data collected under the IMO Data Collection System has been used to calculate the Carbon Intensity Indicator (CII), which assesses a ship’s operational efficiency. To maintain confidentiality, the IMO publishes anonymized annual reports . All data is managed through the Global Integrated Shipping Information System (GISIS), which is accessible to member States . The system’s implementation is supported by several MEPC resolutions, including MEPC.395(82) for SEEMP development, MEPC.389(91) for verification procedures, and MEPC.349(78) for database management, to help ensure consistency and transparency across the reporting process.
In March 2024, MEPC 81 adopted amendments to Appendix IX of MARPOL Annex VI (resolution MEPC.385(81)), introducing increased data granularity requirements, including the reporting of fuel consumption by fuel oil type per consumer type and data on transport work. These amendments were initially intended to enter into force on 1 August 2025, but parties could submit an their applications early beginning 1 January 2025. Noting the fact that the amendments would enter into force halfway through a calendar year , which would result in two distinct levels of granularity for the data gathered in that calendar year , the IMO approved Circular MEPC.1/Circ.913, providing the following guidance on the timeline for the application of those amendments:
- For ships flying the flag of an Administration that implements the amendments early (1 January 2025):
Revise the SEEMP in accordance with the 2024 SEEMP Guidelines (Resolution MEPC.395(82)) prior to 1 January 2025 and collect data with increased granularity throughout the entire year of 2025 and beyond - For ships with flags that implement the amendments on the entry into force date (1 August 2025):
A revised SEEMP Part II, in accordance with the 2024 SEEMP Guidelines, as amended, and the new Confirmation of Compliance, must be onboard by 1 January 2026.
Data must be collected with the existing level of granularity throughout 2025. From 1 January 2026, data must be collected with the enhanced level of granularity. - For ships delivered on or after 1 August 2025:
A SEEMP Part II in accordance with the 2024 SEEMP Guidelines, as amended, and the associated Confirmation of Compliance must be onboard from the date of delivery.
Data must be collected with the enhanced level of granularity from the date of delivery.
New Requirements for Enhanced Granularity Reporting
In addition to the existing DCS parameters, shipowners and operators are now required to document, report and submit for verification the following:
1. Fuel oil consumption per consumer type.
A new requirement to split fuel consumption per consumer type was introduced. Consumer types include main and auxiliary engines, fired boilers and others.
To comply, shipowners must implement one of the following methods for measuring fuel consumption per consumer type, and update accordingly the SEEMP Part II:
1. Method using flow meters
The flow meters should be located so as to measure all fuel oil consumption for each consumer type. Each flow meter and its link to a specific consumer type must be clearly identified in the SEEMP Part II. Any individual consumer not monitored by a flow meter should also be explicitly listed, and an alternative fuel oil consumption measurement method should be included.
2. Method using bunker fuel oil tank monitoring on board
Tank readings, which are carried out by appropriate methods such as automated systems, soundings, and dip tapes, should normally
occur daily when the ship is at sea and each time the ship is bunkering or de-bunkering.
3. Alternative methods
If there is a consumer type for which neither of the above methods can be applied, one of the following methods may be used:
a. Method using subtraction
If fuel consumption for only one of the consumer types is not available, the fuel consumption of this consumer type may be derived by subtracting the consumption of other consumer types from the total annual fuel oil consumption, which is measured according to the established methodologies in the current SEEMP Part II.
b. Method using estimated fuel oil consumption
If none of the above methods can be applied, an alternative method, such as one based on manufacturer data or historical fuel consumption records for a specified period, may be used subject to the satisfaction of the flag Administration or a recognized organization (RO).
Note: Each consumer type may use a different method to measure fuel oil consumption.
2. Fuel oil consumption when the ship is not under way, by fuel oil type per consumer type.
Fuel oil consumption must be reported separately when the ship is not under way, by fuel oil type per consumer type. The methodology for measuring this consumption should be included in SEEMP Part II.
3. Onshore power supplied.
The amount of onshore power supplied should be recorded based on a relevant document from the power supplier, which must be securely stored. The total amount of onshore power supplied should be calculated as the sum of the amount of onshore power supplied in kWh. A relevant methodology should be developed and included in SEEMP Part II.
4. Transport work for ships.
Ships subject to Regulation 28 of MARPOL Annex VI (Carbon Intensity Indicator (CII)) must report the total transport work. This is the annual sum of each voyage's transport work, which is the distance sailed multiplied by the cargo carried during a voyage. Subsequently, for each voyage, operators must also report the cargo carried, specific to the ship type, as outlined below. A corresponding methodology for these calculations should be developed and included in SEEMP Part II.
| Ship type | Transport work metric |
| Bulk carriers | Cargo mass (metric tons) x distance |
| Tankers | Cargo mass (metric tons) x distance |
| Combination carriers | Cargo mass (metric tons) x distance |
| Gas carriers | Cargo mass (metric tons) x distance |
| LNG carriers | Cargo mass (metric tons) x distance |
| General cargo ships | Cargo mass (metric tons) x distance |
| Ro-Ro cargo ships (vehicle carriers) and Ro-Ro cargo ships | Cargo mass (metric tons) x distance |
| Containerships | Number of TEUs, Cargo mass + Container Mass (metric tons) x distance |
| Cruise passenger ships | Number of Passengers x distance |
| Ro-Ro passenger ships | Number of Passengers x distance and Cargo mass (metric tons) x distance |
5. Laden distance (on a voluntary basis).
Laden distance, is calculated as the distance sailed when the ship is loaded, may be reported voluntarily.
6. Installation of any innovative technology.
Ships subject to Regulation 28 of MARPOL Annex VI (Carbon Intensity Indicator (CII)) should report the installation of innovative technology, if applicable. As outlined in MEPC.1/Circ.896, innovative technologies are categorized as follows:
1. Category A: such as low friction coating, rudder resistance, propeller design etc.
2. Category B-1: such as hull air lubrication systems.
3. Category B-2: such as any type of wind assistance (sails, Flettner-Rotors, kites).
4. Category C-1: such as waste heat recovery systems that convert exhaust heat into electric power.
5. Category C-2: such as photovoltaic cells.
SEEMP Parts II and III amendments
Ships must comply with amended SEEMP Parts II and III requirements: SEEMP Part II must include the enhanced granularity information explained above and the revised definitions for the terms “under way” and “not under way” while SEEMP Part III must be revised to reflect the updated Carbon Intensity Indicator (CII) reduction targets for 2026–2028, with completion of verification and issuance of a Confirmation of Compliance by 31 December 2025.
1. Updated Definitions for the terms “under way” and “not under way”.
To improve clarity and consistency in reporting, MEPC 83 adopted amendments to the 2024 SEEMP Guidelines (Resolution MEPC.401(83)), which provide revised definitions for the terms “under way” and “not under way”, that relate to three key reporting parameters: fuel oil consumption, distance travelled, and hours under way.
1. Under way
The period between full ahead on passage (FAOP), where transit to the next port starts, and end of sea passage (EOSP), where the ship decelerates from transit speed.
FAOP is commonly referred to as Begin of Sea Passage (BOSP), as defined in the IMO Compendium on facilitation and electronic business (IMO Compendium) under IMO 0597 (Code EV10).
2. Not under way
The period between the end of sea passage (EOSP) and full ahead on passage (FAOP) of the following sea passage. Due to frequent maneuvering, acceleration, and deceleration, the period between Begin Canal Passage (EV08) and End Canal Passage (EV09) is considered not under way.
Consequently, the definitions of “distance travelled” and “hours under way” have been updated based on the term “under way,” replacing the previous term “under its own propulsion."
2. CII reduction targets for 2026–2028
To support the IMO’s objective of achieving at least a 40% reduction in CO₂ emissions per transport work by 2030 compared to 2008, the reduction (Z) factors for the required annual operational CII for the years 2027 to 2030 were adopted by resolution MEPC.400(83), introducing an annual reduction increment of 2.625 percent.
| Year | Reduction factors relative to 2019 |
| 2027 | 13.625% |
| 2028 | 16.25% |
| 2029 | 18.875% |
| 2030 | 21.5% |
In accordance with Regulation 28 of MARPOL Annex VI, ships of 5,000 GT and above (excluding certain exempted types) are required to determine their Required Annual CIIs for the next three years, as benchmarks against the ship’s actual performance (Attained CII). The SEEMP Part III must include:
- The Required Annual Operational CIIs for the next three years.
- An implementation plan detailing how these CIIs will be achieved.
- A self-evaluation and improvement procedure.
Based on this and following the adoption of the CII reduction factors for the years 2027 to 2030, a revised SEEMP Part III should be developed and submitted for review by 31 August 2025 allowing time to complete the review process. The revised SEEMP Part III and the associated Confirmation of Compliance must be on board by 1 January 2026.
Actions for Compliance
Ships delivered on or after 1 August 2025:
- Develop the SEEMP Part II, in accordance with the 2024 SEEMP Guidelines (IMO Resolution MEPC.395(82), as amended by Resolution MEPC.401(83)).
- Develop the SEEMP Part III, to include the Required Annual Operational CIIs for years 2025–2027.
- Submit SEEMP Part II and III for review and issuance of the Confirmations of Compliance (CoC) before the date of delivery.
- Monitor data at the enhanced level of granularity starting from the date of delivery.
- Submit for verification the data collected with enhanced granularity no later than 31 March 2026 and each calendar year, for the issuance of the Statement of Compliance (SoC).
Existing Ships:
- For ships flying the flag of an Administration that implements the amendments early (1 January 2025):
- SEEMP Part II amendments:
- Revision in accordance with the 2024 SEEMP Guidelines (IMO Resolution MEPC.395(82), as amended by Resolution MEPC.401(83)).
- Submit it for review by 31 August 2024 and issuance of the Confirmation of Compliance by 31 December 2024.
- SEEMP Part II amendments:
- For ships flying the flag of an Administration that implements the amendments on the entry into force date (1 August 2025):
- SEEMP Part II amendments:
- Revision in accordance with the 2024 SEEMP Guidelines (IMO Resolution MEPC.395(82), as amended by Resolution MEPC.401(83)).
- Submit it for review by 31 August 2025 and issuance of the Confirmation of Compliance by 31 December 2025 at the latest.
- SEEMP Part III amendments:
- Revision to include the Required Annual Operational CIIs for years 2026–2028. In accordance with the amendments to the 2021 CII reduction factors guidelines G3, adopted by resolution MEPC.400(83).
- Submit it for review by 31 August 2025 and issuance of the Confirmation of Compliance by 31 December 2025 the latest.
- Implement any necessary changes to the equipment, reporting system to enable monitoring at the enhanced level of granularity.
- Start collecting data at the enhanced level of granularity from 1 January 2026.
- Submit the collected data for verification no later than 31 March 2027 and each calendar year, for the issuance of the Statement of Compliance (SoC).
- SEEMP Part II amendments:
You can download below the Frequently Asked Questions which can further clarify:
Source: EU, IMO
