Applicability: shipowners, ship operators, ship managers and ship masters of vessels 5000gt and ovFurther to Class News 09/2021,

MARPOL Annex VI amendments* which enter into force on 1 November 2022, require operators of applicable ships^# to calculate and report the attained annual operational CII for the ship from 2024 onwards, according to the methodology included in the vessel’s Ship Energy Efficiency Management Plan (SEEMP Part III). The new CII requirements are in addition to the existing MARPOL Annex VI fuel oil consumption data (IMO DCS) requirements. What should shipowners and operators do now?

Operators should submit a ‘SEEMP Part III’ for approval to LR (or Flag). It is strongly recommended the SEEMP Part III is submitted well ahead of the 31 December 2022 deadline, to allow time for review and issuance of the necessary Confirmation of Compliance.

Operators should submit a ‘SEEMP Part III’ to their LR client manager or contact their local office.

A SEEMP Part III template document is available here to assist operators. See also the other guidance available on our CII and DCS pages.

SEEMP Part III (new Reg. 26.3)

Applicable ships^# are required, prior to 1 January 2023, to have a SEEMP Part III onboard that has been verified by LR (or flag Administration). The SEEMP Part III is required to be in compliance with ‘2022 Guidelines for the Development of a Ship Energy Efficiency Management Plan (SEEMP)’ – IMO resolution MEPC.346(78). As part of the verification of the SEEMP Part III, the ship will be issued with a Confirmation of Compliance, that is to be retained onboard.

The ‘SEEMP Part III’ is to include the following:

• a description of the methodology that will be used to calculate and report the ship’s attained annual operational CII;
• the required annual operational CII, for the next three years;
• an implementation plan documenting how the required annual operational CII will be achieved during the next three years; and
• a procedure for self-evaluation and improvement
• Annual operational CIIFrom 1 January 2024 (and after the end of each following calendar year), each applicable ship^# shall calculate the attained annual operational CII over a 12-month period from 1 January to 31 December for the preceding calendar year (starting with the 2023 data), using the fuel oil consumption data collected in accordance with IMO DCS requirements.

  The ship is given a carbon intensity rating based on its attained annual operational CII when compared to the calculated by required annual operational CII. For a ship rated as D for three consecutive years, or rated as E in any one year, the SEEMP Part III is required to be reviewed and reapproved to include a plan of corrective actions to achieve the required annual operational CII in the following calendar year.

  SEEMP Part I and II

  SEEMP Part I has been a requirement since 2013 for all internationally trading ships over 400 GT but is not required to be approved by LR or Flag. SEEMP Part II has been a requirement since 2019, for ships of 5000 GT and above, and relates to the IMO DSC requirements, and is required to be issued with a Confirmation of Compliance. See Class News 25/2018 for further information.

  The changes to the ‘2022 Guidelines for Development of a SEEMP’ IMO resolution MEPC.346(78), which revoked the ‘2016 Guidelines’ IMO resolution MEPC.282(70), may necessitate operators of vessels using cargo as fuel (such as LNG or LPG) to submit an amended SEEMP part II for approval.

  * Resolution MEPC.328(76) – Amendments to Marpol Annex VI (2021 Revised MARPOL Annex VI)
  ^# The CII and SEEMP Part III requirements apply to any ship, of 5000 GT and above, which falls into one or more of the categories: bulk carrier, combination carrier, containership, cruise passenger ship, gas carrier, general cargo ship, LNG carrier, refrigerated cargo carrier, ro-ro cargo ship, ro-ro cargo ship (vehicle carrier), ro-ro passenger ship or tanker, as defined in MARPOL Annex VI.