COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2015/757 in order to take appropriate account of the global data collection system for ship fuel oil consumption data
Date: 2019-02-04
Institutions: Directorate-General for Climate Action, European Commission
Subjects: International Maritime Organisation, climate change, consumption, data collection, environmental monitoring, greenhouse gas, marine fuel, maritime transport, pollution from ships, reduction of gas emissions

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 4.2.2019 SWD(2019) 10 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT  Accompanying the document PROPOSAL FOR A REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL amending Regulation (EU) 2015/757 in order to take appropriate account of the global data collection system for ship fuel oil consumption data {COM(2019) 38 final} - {SEC(2019) 20 final} - {SWD(2019) 11 final}  
 
 
Contents 

GLOSSARY ....................................................................................................................... 4 

1. 

INTRODUCTION ..................................................................................................... 5 

1.1.  Policy and legal context ................................................................................... 6 

2.  PROBLEM ANALYSIS .......................................................................................... 11 

2.1.   The problem to be addressed ........................................................................ 11 

2.2.  Design differences between the EU MRV Regulation and the IMO 

DCS ................................................................................................................. 12 

2.3.  Most affected stakeholders ........................................................................... 17 

2.4.  Was a fitness check carried out? .................................................................. 18 

3.  WHY SHOULD THE EU ACT? ............................................................................ 19 

3.1.  Legal basis ...................................................................................................... 19 

3.2.  Subsidiarity .................................................................................................... 19 

4.  WHAT SHOULD BE ACHIEVED – OBJECTIVES .......................................... 20 

4.1.  Strategic objectives ........................................................................................ 20 

4.2.  Operational objective .................................................................................... 20 

4.3.  Stakeholders views ......................................................................................... 21 

5.  POLICY OPTIONS ................................................................................................ 22 

6.  WHAT ARE THE IMPACTS AND WHO WILL BE AFFECTED? ................ 25 

6.1.  Scope ............................................................................................................... 25 

6.2.  Definitions ...................................................................................................... 27 

6.3.  Monitoring parameters ................................................................................. 27 

6.4.  Monitoring plans and templates ................................................................... 29 

6.5.  Verification ..................................................................................................... 29 

6.6.  Transparency ................................................................................................. 30 

6.7.  Impacts on SMEs ........................................................................................... 31 

7.  HOW DO THE OPTIONS COMPARE? .............................................................. 32 

7.1.  Comparison of options .................................................................................. 32 

7.2.  Preferred option ............................................................................................. 33 

8.  MONITORING AND EVALUATION .................................................................. 37 

ANNEX 1: PROCEDURAL INFORMATION............................................................. 39 

ANNEX 2: SYNOPSIS REPORT .................................................................................. 42 

2 

 
ANNEX 3: WHO IS AFFECTED .................................................................................. 49 

ANNEX 4: MODELLING .............................................................................................. 52 

ANNEX 5: COMPARING THE EU MRV AND THE IMO DCS .............................. 53 

3 

 
 
 
 
GLOSSARY 

EEA 

EEDI 

European Economic Area  

Energy Efficiency Design Index 

EMSA 

European Maritime Safety Agency 

ETS 

GT 

GHG 

IMO 

Emission Trading System 

Gross tonnage  

Greenhouse gas 

International Maritime Organization  

IMO DCS 

International Maritime Organization Data Collection System 

ISO 

International Organization for Standardization 

MARPOL 

International Convention on MARitime POLlution 

MEPC 

MRV 

Mt 

NAB 

NGO 

SEEMP 

SOLAS 

Maritime Environmental Protection Committee 

Monitoring, reporting and verification of emissions 

Metric tonne 

National Accreditation Body 

Non-governmental organisation  

Ship Energy Efficiency Management Plan 

International Convention for Safety Of Life At Seas  

4 

 
 
 
1. 

INTRODUCTION 

Following up on the 2011 EU White paper on transport, the Commission adopted in 2013 
a strategy on the decarbonisation of shipping, calling for a gradual approach in the EU, 
starting with  an EU monitoring, reporting and verification (MRV) scheme. As a  result, 
the  European  Parliament  and  the  Council  adopted  in  April  2015  the  Regulation  (EU) 
2015/757 on the monitoring, reporting and verification of carbon dioxide emissions from 
maritime  transport  ("the  EU  MRV  Regulation”).  This  EU  regulation  is  an  important 
milestone  to  collect  robust  and  verified  CO2  emission  data  from  ships  operating  in  the 
European  Economic  Area  (EEA)  and  thereby  supporting  future  policy-making  and  the 
implementation  of  policy  tools.  It  also  provides  the  necessary  level  of  transparency  to 
stimulate  and  encourage  the  up-take  of  new  technologies  and  operational  measures  to 
make ships greener.  

In 2016, following the entry into force of the Paris Agreement and the adoption of the EU 
MRV Regulation, the International Maritime Organisation (IMO) adopted a global data 
collection system (IMO DCS) for fuel oil consumption of ships as well as specific IMO 
data collection guidelines in 2016-2017. As a result, from 2019, ships calling into EEA 
ports will have to report under both the EU MRV Regulation and the IMO DCS. 

Article  22  of  the  EU  MRV  Regulation  anticipated  this  situation  as  it  foresees  that  the 
Commission should, in the event of an international agreement on a global MRV system 
for shipping emissions, review the regulation and, if appropriate, propose amendments to 
ensure alignment with that international agreement. 

Accordingly,  while  this  impact  assessment  considers  different  alignment  options,  the 
objective  is  not  to  replace  the  EU  MRV  Regulation  by  the  IMO  DCS.  This  document 
builds  on  the  inception  impact  assessment  published  in  June  2017  and  the  public 
consultation concluded in December 2017.  

5 

 
 
 
Background  

GHG  emissions  from  the  maritime  sector  are  substantial  and  are  likely  to  increase 
significantly in the future if nothing is done. 

Due to the considerable consumption of fossil fuels, shipping emits significant amounts 
of greenhouse gases and therefore contributes to climate change.  

Greenhouse gas (GHG) emissions from international maritime transport are estimated to 
amount to 940 million tonnes of CO2 per year, representing approximately 2 - 3 percent 
of total global GHG emissions. This is more than the emissions of any EU state. If the 
shipping sector were a country, it would rank sixth in emission in the world. The impact 
of  the  sector  at  EU  level  is  equally  considerable  as  it  represented  in  2015  13%  of  the 
overall EU greenhouse gas emissions from the transport sector1. 

In  the  future,  these  emissions  are  projected  to  increase  significantly  if  mitigation 
measures are not put in place swiftly. According to an IMO study2, depending on future 
economic and energy developments, shipping emissions could grow by between 50% and 
250%  by  2050.  Another  study3  projects  that  emissions  could  increase  by  20-120% 
compared to 2012 levels over the same period for global temperature rise scenarios less 
than 2°C.  

At  the  EU  level  (i.e.  for  ships  calling  at  EU  ports),  CO2  emissions  from  maritime 
transport increased by 48% between 1990 and 2008, and are expected to increase by 86% 
above  1990  levels  by  2050;  and  this  despite  domestic  emissions,  already  addressed  by 
national measures, have decreased 34% compared to 1990, levels. This clearly shows the 
need  for  enhanced  action  on  shipping  emissions.  The  projected  increase  in  GHG 
emissions  is  due  to  the  expected  growth  of  the  world  economy  and  the  associated 
transport  demand  from  world  trade.  Today,  more  than  90%  of  EU  external  trade  is 
seaborne. 

1.1.  Policy and legal context 

Climate change is a challenge that requires urgent and meaningful action from all States 
and  all  emitting  sectors.  The  growing  GHG  emissions  from  the  maritime  sector  are  a 
concern  that  needs  to  be  tackled  both  globally  and  domestically,  and  included  in  the 
National Determined Contributions (NDC) to the UNFCCC4 that are due to cover all the 
sectors  of  the  economy.  However,  maritime  shipping  remains  the  only  means  of 
transportation not expressly addressed in the EU's commitment to reduce greenhouse gas 
emissions  and  the  initial  strategy  adopted  in  2018  at  the  international  level  to  reduce 
GHG emissions from ships is yet to be implemented. 

1  https://www.eea.europa.eu/data-and-maps/indicators/transport-emissions-of-greenhouse-

gases/transport-emissions-of-greenhouse-gases-10. 

2  http://www.imo.org/en/OurWork/Environment/PollutionPrevention/AirPollution/Pages/Greenhouse-

Gas-Studies-2014.aspx. 

3  https://www.cedelft.eu/en/publications/download/2446. 

4  https://unfccc.int/index.php/process-and-meetings/the-paris-agreement/nationally-determined-

contributions-ndcs. 

6 

 
 
 
 
                                                 
As  GHG  emissions  from  ships  are  likely  to  continue  to  grow,  it  risks  undermining  the 
objectives  of  the  Paris  Agreement  (which  entered  into  force  in  2016  and  is  the  first 
universal,  legally  binding  global  climate  agreement)  and  the  efforts  deployed  by  other 
sectors. The Paris Agreement stresses the need for global GHG emissions to peak as soon 
as possible and emphasizes the importance to reduce GHG emissions need in all sectors 
of the economy with a view to limit global temperature increase well below 2° Celsius. 

European context 

While at the EU level, shipping remains the only transport mode not explicitly addressed 
by  a  specific  emission  reduction  objective  for  2030,  their  GHG  emissions  are  likely  to 
grow and represent an important challenge ahead. 

Following up on the 2011 EU White paper on transport, the Commission adopted in 2013 
a  Communication5  (COM(2013)  479  final)  setting  out  a  strategy  for  progressively 
integrating  maritime  emissions  into  the  EU's  Climate  policy  consisting  of  three 
consecutive steps: 

•  Monitoring, reporting and verification of CO2 emissions from large ships calling at 

EEA ports; 

• 

• 

Greenhouse gas reduction targets for the maritime transport sector; 

Further measures, including market-based measures, in the medium to long term. 

As  a  result,  the  European  Parliament  and  the  Council  adopted  in  April  2015  the 
Regulation  (EU)  2015/757  on  the  monitoring,  reporting  and  verification  of  carbon 
dioxide  emissions  from  maritime  transport.  This  regulation  was  adopted  following  a 
broad  stakeholder  consultation  and  it  has  been  duly  complemented  by  the  adoption  of 
four delegated and implementing acts in 2016.  

The EU MRV Regulation aims at various policy objectives: 

1)  Collect  robust  and  verified  CO2  emission  data  for  all  ships  calling  at  European 

Economic Area (EEA) ports, including CO2 emissions from these ships in ports;  

2) 

3) 

Provide  the  necessary  transparency  concerning  data  to  stimulate  the  up-take  of 
green ships and of energy efficient behaviours from shipping operators; 

Provide robust information to support future policy discussions and implementation 
of  policy  tools,  as  well  as  for  the  implementation  of  international  objectives  or 
measures (e.g. on energy efficiency). 

The main objective of the EU MRV Regulation is to contribute directly and indirectly to 
GHG  emission  reductions  from  EU  related  ships,  including  from  purely  domestic 
shipping (within a state), which should lead to potential energy/costs savings. According 
to  the  analytical  and  preparatory  work  done  for  the  EU  MRV  Regulation  concluded  in 
20136, the EU MRV could lead to annual reductions in fuel consumption and emissions 
of  around  2%  by  increasing  transparency  and  awareness  about  GHG  emissions  from 
shipping. 

5  https://ec.europa.eu/clima/sites/clima/files/transport/shipping/docs/com_2013_479_en.pdf. 

6  SWD(2013) 

https://ec.europa.eu/clima/sites/clima/files/transport/shipping/docs/swd_2013_236_en.pdf. 

236 

7 

final, 

 
 
                                                 
With the full regulatory framework now in place, this allowed the implementation to start 
as  required  by  the  EU  MRV  Regulation  with  the  preparation  of  monitoring  plans  that 
were completed by shipping companies by August 2017. 

In practice, the EU MRV Regulation requires companies operating large ships (above 5 
000 gross tonnes) to monitor fuel consumption, and by proxy the CO2 emissions and the 
energy efficiency of their ships on voyages to and from EEA7 ports on an annual basis. 
As  a  first  step,  all  companies  were  required  to  submit,  by  31  August  2017,  their 
monitoring  plan  for  each  of  their  ships  indicating  the  method  chosen  to  monitor  and 
report  CO2  emissions  and  other  relevant  information.  Starting  from  January  2018, 
companies had to start monitoring their CO2 emissions on an annual basis, and as from 
2019,  companies  have  to  submit  an  emission  report  to  the  Commission  and  to  the 
authorities  of  the  flag  States  report  by  30  April  of  each  year.  Both  the  conformity 
assessment of the monitoring plan and verification of the emissions reports, are carried 
out by independent duly accredited verifiers. Based on this verified data, the Commission 
shall publish the reported information on CO2 emissions and produce an annual report on 
CO2  emissions  and  other  relevant  information  from  maritime  transport  covered  by  the 
scope of the EU MRV Regulation. 

In  general,  the  role  and  contribution  of  the  shipping  sector  to  emission  reductions 
consistent with the temperature goals of the Paris Agreement remains an important issue 
in the EU, with the European Parliament consistently raising the need to address shipping 
alongside all other sectors of the EU economy.  As a result, the recent amendment to the 
EU  Emissions  Trading  System  (ETS)  Directive,  by  Directive  (EU)  2018/410  of  the 
European Parliament and the Council, emphasises the need to act on shipping emissions 
as well as all other sectors of the economy. The Directive also states that the Commission 
should keep IMO action under regular review, calls for action from the IMO or the EU to 
start from 20238, including preparatory work and stakeholder consultation.  

International context 

Although  there  is  a  need  to  set  and  implement  a  global  approach  to  address  GHG 
emissions from international shipping, progress at IMO has been relatively slow.  

IMO started working on the reduction of GHG emissions in 1997. In 2011, IMO adopted  
the Energy Efficiency Design Index (EEDI) for new ships and the requirement to carry a 
Ship Energy Efficiency Management Plan (SEEMP) on board of all ships. The SEEMP 
urges  ship  owners  and  operators  to  consider  new  technologies  and  practices  when 
seeking to optimise the performance of a ship. However, as the measures described in the 
SEEMP are not mandatory, the impact of SEEMP remains uncertain. 

Following the adoption of the EU MRV Regulation, and, inspired by it, the IMO started 
negotiations concerning the setting up of a data collection system. In 2016, the Maritime 
Environmental  Protection  Committee  (MEPC)  established  the  legal  framework  for  an 
IMO  Data  Collection  System  (IMO  DCS)9  where  owners  of  large  ships  (above  5000 
gross  tonnes)  engaged  in  international  shipping  have  to  report  information  on  fuel 
consumption of their ships to the States in which those ships are registered ('flag States'). 

7  The  European  Economic  Area  (EEA)  brings  together  the  EU  Member  States  with  Iceland, 

Liechtenstein and Norway. 

8  See, in particular, recital 4 of Directive (EU) 2018/410. 

9  http://www.imo.org/en/OurWork/Environment/PollutionPrevention/AirPollution/Pages/Data-

Collection-System.aspx. 

8 

 
 
                                                 
The aggregated data is then to be reported by flag States to the IMO, which shall produce 
an annual report to the Marine Environment Protection Committee summarising the data 
collected.  Details  and  implementing  modalities  of  the  system  were  agreed  in  IMO 
through  guidelines10  adopted  by  MEPC  70  in  October  2016  and  by  MEPC  71  in  July 
2017.  The  IMO  DCS  entered  into  force  in  March  2018.  The  collection  of  fuel 
consumption data under the IMO system is due to start on 1 January 2019. 

It  should  be  noted  that  the  IMO  DCS  is  part  of  the  MARPOL  Convention's  Annex  VI 
that  has  been  ratified  by  many  States,  but  around  40  States  have  still  to  do  so.  An 
overview of the status of ratification can be found at the IMO website11. 

In  addition,  and  following  two  years  of  negotiations,  which  started  in  the  wake  of  the 
Paris  Agreement,  IMO  adopted  in  April  2018  an  Initial  strategy  on  reduction  of  GHG 
emissions  from  ships.  The  strategy  includes  a  GHG  emission  reduction  objective  of  at 
least 50% by 2050 (compared to 2008 levels) and aims to full decarbonisation as soon as 
possible in this century. However, short-, mid- and long-term further measures, including 
Research and Innovation, necessary to achieve this objective remain to be developed and 
agreed. 

10  2016  Guidelines  for  the  development  of  a  Ship  Energy  Efficiency  Management  Plan  (SEEMP) 
(resolution  MEPC.282(70));  2017  Guidelines  for  Administration  verification  of  ship  fuel  oil 
consumption data (resolution MEPC.292(71)); 2017 Guidelines for the development and management 
of  the  IMO  Ship  Fuel  Oil  Consumption  Database  (resolution  MEPC.293(71));  MEPC  circular  on 
submission of data to the IMO data collection system of fuel oil consumption of ships from a State not 
party  to  MARPOL  Annex  VI  (MEPC.1/Circ.871);  and  sample  format  for  the  confirmation  of 
compliance pursuant to regulation 5.4.5 of MARPOL Annex VI (MEPC.1/Circ.876). 

11  http://www.imo.org/en/About/Conventions/StatusOfConventions/Pages/Default.aspx. 

9 

 
 
 
                                                 
Background: Paris Agreement and EU strategy on maritime emissions 

The  Paris  Agreement  aims  at  limiting  global  temperature  increase  well  below  2°C 
compared  to  pre-industrial  levels,  and  pursue  efforts  towards  1,5°C,  based  on  adequate 
emission  reductions  from  all  Countries  and  all  emitting  sectors.  The  Paris  Agreement 
states  that  developed  countries  should  continue  to  undertake  economy-wide  absolute 
emissions reductions while developing countries should move towards an economy wide 
approach over time. 

The  EU  committed  to  an  economy-wide  GHG  emission  reduction  of  at  least  40%  by 
2030 below 1990 levels  (without the use of international credits), which constitutes the 
EU economy-wide commitment under the Paris Agreement12. 

The  European  Parliament  has  placed  a  strong  emphasis  on  all  sectors  of  the  economy 
contributing to emission reductions, which was reflected in Directive 2009/29/EC of the 
European  Parliament  and  Council  and  Decision  No  406/2009/EC  of  the  European 
Parliament  and  Council,  calling  for  contributions  from  all  sectors  of  the  economy  to 
achieve  emission reductions, including the shipping sector. The most recent  revision to 
the  EU  emissions  trading  system,  Directive  (EU)  2018/410,  also  emphasises  that  all 
sectors must contribute to emission reductions13. 

In  2011,  the  Commission  White  Paper  on  Transport  Policy  already  indicated  that  EU 
shipping CO2 emissions should be reduced by at least 40% (50% if feasible) by 205014. 
The EU's CO2 emissions from domestic shipping emissions have, by 2016, been reduced 
by 33.1% below 1990 levels15, but international shipping emissions "related" to the EU 
(i.e. from ships calling to EEA ports from third countries and ships sailing between 2 or 
more  EU  Member  States)  have  continued  to  increase,  and  are  currently  around  32.5% 
above 1990 levels. 
Following  this,  the  European  Commission  adopted  in  2013  a  Communication16 
(COM(2013)  479  final)  setting  out  a  strategy  for  progressively  integrating  maritime 
emissions 
the
Climate 
monitoring, reporting and verification of CO2 emissions from large ships calling at EEA 
ports.  A  robust  MRV  system  is  indeed  a  key  element  for  climate  policies,  and  for 
possible additional policy measures building on it, be it at EU or global level.  

starting 

policy 

EU's 

with 

into 

the 

The  present  EU  basic  legislative  climate  framework,  namely  the  Effort  Sharing 
Regulation (ESR) and the Emissions Trading System (ETS) cover most of the economy, 
including aviation, but not shipping, which remains the only means of transportation not 
included in the Union’s commitment to reduce GHG emissions17.  

12  http://www4.unfccc.int/ndcregistry/PublishedDocuments/European%20Union%20First/LV-03-06-

EU%20INDC.pdf. 

13  See, in particular, recital 4. 

14  See COM(2011)144, paragraph 29, http://eur-lex.europa.eu/legal-

content/EN/ALL/?uri=CELEX:52011DC0144. 

15  See  http://www.eea.europa.eu/data-and-maps/data/data-viewers/greenhouse-gases-viewer.  It  should  be 
noted that 'domestic' emissions are considered for the purposes of UNFCCC reporting to be emissions 
internal to each Member State, as no decision on the allocation of other emissions has yet taken place. 

16  https://ec.europa.eu/clima/sites/clima/files/transport/shipping/docs/com_2013_479_en.pdf. 

17  Recital 3 of Regulation (EU) 2015/757. 

10 

 
                                                 
2.  PROBLEM ANALYSIS 

2.1.   The problem to be addressed 

After  the  adoption  of  the  IMO  DCS,  ships  calling  into  EEA  ports  will  have  to  report 
under both the IMO and the EU systems from January 2019. In accordance with Article 
22  of  the  EU  MRV  Regulation,  it  has  not  been  considered  to  replace  the  EU  MRV 
Regulation by the IMO DCS in its entirety. In this context, the main challenge is to find 
appropriate ways to help market actors implement both schemes while streamlining and 
reducing administrative burden as possible, and while preserving the objectives of the EU 
MRV Regulation.  

The two MRV systems show some important differences (see 2.2. below). For instance, 
while  the  EU  MRV  Regulation  provides  the  necessary  transparency  and  information  at 
individual ship level  to stimulate the up-take of more energy efficient technologies and 
behaviours, data from the IMO DCS are not available at ship level and not accessible by 
all market actors. In addition, the scope are different. The EU MRV Regulation aims to 
collect  data on CO2  emissions from  purely domestic activities, international  voyages  to 
and from an EEA ports  and from ships at berth or moving within an EEA port. On the 
other hand, the IMO DCS aims to gather global data on fuel consumption by States from 
their  ships  engaged  in  international  shipping,  and  does  not  cover  domestic  maritime 
transport as well CO2 emissions within ports. There is also a fundamental difference on 
the  reporting  entity.  In  the  EU  MRV  Regulation,  the  obligation  lies  with  the  shipping 
company while in the IMO DCS the responsibility has been assigned to the flag States. 

Nevertheless,  the  schemes  also  present  many  similarities.  Both  schemes  have  been 
designed with the objective to inform and feed future policy-makers’ decisions. They are 
both  based  on  data  already  available  on  ships  (required  by  international  maritime 
legislation,  to  be  available  on  board  of  ships)  and  they  both  require  ships  above  5000 
gross  tonnes  to  collect  and  report  their  data  annually  to  the  relevant  authorities,  and  to 
carry on board a document to demonstrate compliance. 

2.1.1.  The reporting obligations under two systems  

Under the EU MRV  Regulation framework, shipping  companies have the obligation to 
monitor their CO2 emissions as described in their monitoring plan (MP) and report their 
emissions in their emissions report (ER). The reporting obligation is to the Commission 
and to the authorities of the flag States concerned (EU Member States), and with EMSA 
managing  the  database  (THETIS-MRV).  The  first  monitoring  period  for  the  shipping 
company started 1 January 2018 and first ERs are due by 30 April 2019. 

Under  the  IMO  DCS,  according  to  Regulation  22A  of  IMO  MARPOL  Annex  VI,  the 
reporting is split into two steps: from the shipping company to the flag State and from the 
flag  State  to  the  IMO.  The  first  monitoring  period  for  the  shipping  company  will  start 
1January 2019 and first aggregated data are due by the end of March 2020. 

Considering the obligations under these two systems, ships calling into EEA ports would 
have  to  report  under  both  the  IMO  and  the  EU  systems.  This  will  require  additional 
administrative  effort  for  shipping  companies,  even  more  so  when  parameters  are  not 
aligned. The EU MRV Regulation anticipated this situation and included in its Article 22 
the  obligation  for  the  Commission  to  review  the  Regulation,  if  appropriate,  once  the 

11 

 
 
 
international  agreement  is  in  place,  in  order  to  ensure  alignment  with  that  international 
agreement. 

2.1.2.  The  need  to  preserve  the  objectives  of  the  EU  MRV  Regulation:  obtaining 
reliable  data  on  GHG  emissions  from  maritime  transport  and  overcoming 
market barriers to the uptake of GHG emissions reduction measures 

The alignment of the EU MRV Regulation with the IMO DCS should aim at preserving 
the objectives pursued by the EU system, namely the projected positive impact of the EU 
MRV  Regulation  in  terms  of  gathering  reliable  data  and  addressing  market  barriers 
currently  preventing  the  adoption  of  energy  efficiency  measures,  while  reducing  the 
administrative effort resulting from the compliance with the two systems. 

The availability of robust and reliable data on GHG emissions from shipping activities is 
a prerequisite for any further policy action and the development and implementation of 
effective  measures,  be  it  at  EU  or  global  level.  The  2013  EU  MRV  impact  assessment 
concluded that the lack of accurate, comparable and standardised information about fuel 
consumption  is  one  of  the  barriers  to  cost  effective  GHG  emission  reductions  in  the 
maritime  sector  and  therefore  to  a  reduction  of  fuel  cost.  Removing  this  barrier  would 
trigger  an  improvement  in  energy  efficiency  of  the  ships  and  therefore  enhance 
innovation and research due to a better understanding of the fuel consumption. Aggregate 
data were not considered to provide the necessary detailing for this.  

This  is  relevant  for  future  policy  developments  in  the  EU  in  accordance  with  the  2013 
strategy on shipping and for the development of relevant innovative technologies and is 
also  relevant  in  the  context  of  the  implementation  of  the  recently  agreed  IMO  initial 
GHG emission reduction strategy. In addition, the availability of robust and accurate data 
is a key tool for shipping actors to monitor and gradually improve their energy efficiency 
and was identified as a priority under the 2013 Impact Assessment.   

Furthermore, as indicated in the 2013 IA, many of the relevant technical and operational 
measures, such as slow steaming, weather routing, contra-rotating propellers, propulsion 
efficiency devices, etc. can be cost effective  i.e. they deliver more fuel savings than the 
investment required. However, their uptake on a large scale is hampered by the existence 
of market barriers, including lack of information and awareness on energy efficiency of 
ships, split incentives to improve efficiency (different incentives for actors in the supply 
chain, e.g. a ship-owner does not necessarily benefit from the reduction in fuel costs due 
to improved efficiency, however the ship operator does), or the lack of access to finance 
(e.g.  for  a  ship  operator).  All  these  barriers  discourage  the  uptake  of  GHG  emissions 
reduction measures. 

2.2.  Design differences between the EU MRV Regulation and the IMO DCS 

The two systems have a different design in some important aspects, due to differences in 
the  objectives  pursued,  notably  as  regards  transparency  and  the  public  availability  of 
data, as well as their scope. 

The  EU  MRV  Regulation  pursues  the  objective  of  encouraging  the  uptake  of  GHG 
emissions  reduction  measures  through  the  publication  of  data  on  a  per  ship  basis.  By 
providing  comparable  and  reliable  information  on  fuel  consumption  and  energy 
efficiency  of  individual  ships,  the  uptake  of  measures  that  reduce  GHG  emissions  is 
incentivised.  As  estimated  in  the  2013  IA,  this  is  expected  to  result  in  GHG  emission 
reductions  of  up  to  2%  compared  to  business-as-usual  and  net  costs  reduction  of  up  to 

12 

 
 
 
€1.2 billion in 2030. On the contrary, while the IMO DCS will also collect annual per-
ship data (but anonymised with individual ships not being identifiable), this anonymised 
data will  not be made publicly available. 

As  a  result  of  this  divergence  in  objectives,  even  though  the  two  systems  bear  many 
similarities, a number of design differences exist between the EU MRV Regulation and 
the IMO DCS that open up alignment possibilities: 

  Governance:  Under  the  IMO  DCS,  companies  report  to  their  flag  State  (e.g.  for  a 
ship  sailing  between  EEA  states  under  Panama’s  flag,  the  company  will  report  to 
Panama),  whereas  under  the  EU  MRV  Regulation  all  ships  calling  at  EEA  ports, 
irrespective  of  their  flag,  are  obliged  to  report  to  the  Commission  (via  the  EMSA 
database)  and  to  the  EU  flag  States.  This  means  that  under  the  IMO  DCS  a  very 
significant  part  of  EU  (EEA)  related  emissions  would  not  be  reported  to  the 
Commission as it is estimated that half of the EEA related emissions are caused by 
ships  sailing  under  non-EU  flags18.  Furthermore,  under  the  IMO  DCS,  emissions 
related  to  the  EEA  could  not  be  identified  as  they  are  part  of  the  annual  values 
covering all voyages of that year reported. 

  Scope (ships, voyages and activities covered): The IMO DCS applies only to ships 
engaged in international shipping while the EU MRV Regulation additionally covers 
domestic (internal to a Member State) maritime transport. The EU MRV Regulation 
does not include maritime sector activities other than transport of passengers or cargo 
for  commercial  purposes  while  IMO  includes  all  ship  types  above  5000  GT 
performing international voyages including for instance fish catching and processing 
ships.  Another  major  difference  is  that  the  EU  MRV  Regulation  requires 
differentiated monitoring  and reporting of  emissions and fuel  consumption of intra-
EU voyages, incoming and outgoing voyages and in port emissions/ consumption. 

  Definitions:  The  definitions  of  some  concepts  (“company”,  “reporting  period”)  are 
to  a  different  attribution  of 

different 
responsibilities and to different timelines for complying with reporting obligations. 

in  both  systems,  potentially 

leading 

  Monitoring parameters: Monitoring parameters in the EU MRV Regulation and the 
IMO DCS present similarities and differences (see table 2.2). The main divergence is 
that  the  EU  MRV  Regulation  includes  the  actual  cargo  carried  as  one  of  the 
parameters used to calculate individual ships' average operational energy efficiency19, 
whereas  the  IMO  DCS  includes  the  cargo  carrying  capacity  of  ships.  Furthermore, 
the two systems use slightly different definitions of the parameters 'distance travelled' 
and 'time spent at sea'/ 'hours underway'.  

  Monitoring & reporting  plans and templates: The EU MRV Regulation  requires 
the use of a mandatory template for the monitoring plan whereas in  the  IMO DCS, 
only a recommended template is provided. Under both the EU MRV Regulation and 
the IMO DCS, the shipping company is responsible for monitoring and reporting.  

  Verification:  The  EU  MRV  Regulation  applies  in  a  non-discriminatory  way  to  all 
ships  calling  at  ports  in  the  EEA  and  requires  third  party  verification  in  order  to 
ensure  the  accuracy  of  the  data  submitted.  It  uses  a  specific  verification  system 
similar (though simplified) to  the one applied in  the EU Emissions Trading System 

18  About 33% of EEA port calls are made by non EEA flags, mainly by large ships and on long voyages, 

leading to a share of EEA related emissions of roughly 50%. 

19  As defined in the EU MRV Regulation (Section B of Annex II). 

13 

 
                                                 
 
(ETS),  based  on  internationally  agreed  ISO  standards  and  EU  specific  verification 
rules.  Furthermore,  EU  MRV  verifiers  are  subject  to  supervision  by  National 
Accreditation  Bodies  (NABs)20.  In  the  IMO  DCS,  flag  Administrations  shall  verify 
data according to national rules, taking into account IMO guidelines. Within the IMO 
system, the verification that flag States fulfil their international obligations is carried 
out via regulatory IMO audits. In case flag States decide to delegate certain tasks to a 
Recognized  Organization  (RO),  such  organization  is  also  subject  to  a  regular 
supervision in accordance with the RO Code. 

  Demonstration  of  compliance:  Both  systems  use  documents  of  compliance  to 
enable  ships  to  demonstrate  that  they  are  in  compliance  with  the  respective 
regulations.  For  the  EU  MRV  Regulation,  the  third  party  verifiers  issue  the 
documents of compliance whereas this is ensured by the flag State authorities or any 
Recognized Organization (RO) working on their behalf under the IMO DCS.  

  Transparency:  Similar  to  other  sectors,  the  EU  MRV  Regulation  includes  the 
publication  by  the  Commission  of  annually  reported  data  on  a  "per  ship"  basis, 
aggregated  for  all  voyages.  This  provides  stakeholders  and  the  general  public 
information on the CO2 emissions and the energy efficiency of individual ships. The 
IMO central database will contain anonymised per-ship data and will be managed by 
the  IMO  Secretariat.  It  will  only  be  accessible  to  IMO  Member  States  and  not  be 
made available to the public. 

20  Operational  (energy  and  CO2)  efficiency  of  a  ship  expresses  its  efficiency  in  its  daily  operation  and 

relates energy consumption/ CO2 to the cargo carried over distance. 

14 

 
 
 
                                                 
Table 2.1. Comparison of EU MRV Regulation and IMO DCS features 

Features 
candidate for alignment 

and 

possible 

Governance 

Scope 

EU MRV Regulation 

IMO DCS 

to  EEA 
All  ships  calling 
ports 
the 
to 
Commission and the EU flag 
States 

report 

Includes 
emissions. 

domestic 

ship 

cargo 

Does  not  include  ships  not 
transporting 
or 
passengers  for  commercial 
purposes  (e.g.  dredgers,  fish 
catching 
processing 
and 
ships) 

Ships  report  to  their  “flag 
State” and flag State to IMO  

Does  not  include  domestic 
ship emissions. 

Includes  all  types  of  ships 
within the scope of Chapter 4 
of MARPOL Annex VI. 

Definitions 

Some  concepts  are  defined  differently 
“reporting period”) 

(“company”, 

Monitoring parameters 

see table 2.2 

Granularity of parameters 

Total  EEA-related, 
intra-EEA, 
voyages, 
voyages, total in ports 

total 
total 

total 
incoming 
outgoing 

Only global figures 

Monitoring  and  reporting 
plans and templates 

EU  monitoring  templates  are 
used 

IMO templates recommended  

Verification 

Mandatory  verification  by 
accredited  verifiers  based  on 
internationally  agreed 
ISO 
standards  and  EU  specific 
verification rules  

Issuance  of  document  of 
compliance 

by accredited verifiers 

Transparency 

published 
Information 
including  the  identity  of  the 
ship  (albeit  not  in  all  the 
granularity collected) 

Mandatory  verification  by 
national  authorities  of  flag 
States  or  by  duly  authorised 
ROs,  according  to  national 
rules, and taking into account 
IMO guidelines 

by national authorities of flag 
States or duly authorised ROs 
on their behalf 

Information  available to  Flag 
States only and not published 

15 

 
 
 
 
 
 
 
Table 2.2. EU MRV Regulation monitoring parameters21. Differences with IMO DCS. 

EU MRV  

IMO DCS 

Port of departure and arrival 

Not  required.  Aggregated  reporting.  No 
obligation to monitor per journey. 

Amount  and  emission  factor  for  each  type 
of fuel 

Required. Similar. 

CO2 emitted 

Distance travelled 

Time spent at sea 

Cargo carried 

Not  required  (although  it  can  be  obtained 
without further monitoring with the data on 
fuels and emission factors) 

Required. Different definition. 

Required.  Different  definition 
“hours underway”). 

(called 

Different  parameter  (deadweight,  which 
refers to cargo capacity). 

Transport work 

Not required 

Further detailing on differences and synergies are provided in Annex 5. 

21  The monitoring parameters of the EU MRV are listed in Article 9 (1) of the EU MRV Regulation. 

16 

 
 
 
                                                 
2.3.  Most affected stakeholders 

The  following  groups  are  affected  by  the  problem  of  growing  CO2  emissions  from 
shipping and by the existence of the two parallel systems of data collection: 

 

 

 

 

 

 

 

 

 

Citizens/General public:  have an interest in governments taking effective action 
to  avoid  dangerous  climate  change,  and  in  measures  enabling  to  collect  robust 
data  on  maritime  CO2  emissions  and  other  relevant  information,  including  the 
carbon footprint of shipping, as these affect their quality of life and that of future 
generations.  They  have  also  an  interest  as  customers  of  maritime  transport 
services and consumers of goods transported by ships. 

The shipping industry (ship-owners as well as other parties having assumed the 
responsibility  for  the  operation  of  the  ship  and  their  European  and  global 
associations)  are  directly  affected  by  the  development  of  measures  aligning  the 
IMO  DCS  and  the  EU  MRV  Regulation.  Ships  over  5000  Gross  tons  calling  at 
EEA ports after 1st January 2018 are covered by the EU MRV Regulation and will 
also be directly affected by the IMO DCS (high interest). 

EU MRV shipping verifiers are directly affected by the revision as they will need 
to adapt their activities to the newly formulated scheme. 

EEA  Member  States:  National  governments  have,  by  definition,  a  major  role  in 
the  design  and  implementation  of  measures  aiming  at  tackling  maritime 
emissions, both at European level on the EU MRV (as flag States responsible for 
the  compliance  with  EU  laws  of  the  ships  flying  their  flag  and  as  port  States 
responsible  for  verifying  compliance  with  EU  laws  of  ships  calling  into  their 
ports)  and  at  international  level  on  the  IMO  DCS  (responsible  directly  for 
verifying  and  reporting  to  the  IMO  data  collected  by  the  ships  flying  their  flag 
while  verifying  compliance  of  ships  not  flying  their  flag  calling  into  their  ports 
through Port State Control). 

Third countries: acting as flag States and IMO are involved in the implementation 
of  the  IMO  DCS.  Third  country  flag  States  will  see  their  ships  calling  at  EEA 
ports covered by the EU MRV Shipping.  

Other actors of the shipping sector (such as; ship builders and marine equipment 
manufacturers,  cargo  owners,  logistics  companies  and  ports)  are  increasingly 
concerned  to  reduce  their  carbon  footprint  through  improved  technology  and 
operations and to use the data to stimulate improvements to the energy efficiency 
of ships.  

National  accreditation  bodies  responsible  for  providing  accreditation  under  the 
MRV shipping regulation.  

Civil  society  groups  addressing  the  environmental  impact  of  maritime  transport 
e.g.  research  community,  think  tanks,  environmental  NGOs,  shipping  emission 
players  (developers  of  solutions  related  to  CO2  emissions  and  energy  efficiency 
for shipping).  

International organisations: dealing with transport and climate change e.g. various 
United Nations bodies (and in particular the IMO), World Bank, Organisation for 
Economic Co-operation and Development, International Energy Agency. 

17 

 
 
 
 
 
 
 
 
 
2.4.  Was a fitness check carried out? 

A  specific  retrospective  evaluation  for  the  EU  MRV  Regulation  is  not  feasible  at  this 
stage, as the MRV requirements for  ships only entered into force in 2018 with the first 
emissions  reports  covering  2018  emissions  becoming  available  in  April  2019.  This 
impact  assessment, focussing on the differences  between the EU MRV and  IMO DCS’ 
design, is considered adequate in terms of the obligation put on the Commission by the 
co-legislators as stipulated in Article 22 of the EU MRV Regulation. 

18 

 
 
 
 
3.  WHY SHOULD THE EU ACT? 

Article 22 of the EU MRV Regulation  contains  a review clause for the  Commission in 
the event of an international agreement on a global monitoring, reporting and verification 
system,  to  review  the  regulation  and,  if  appropriate,  propose  amendments  to  the 
Regulation.  

EU monitoring  and verification rules have been in place since 2015, as  adopted by the 
European Parliament and the Council. The co-existence of reporting obligations for ships 
calling at EEA ports leads to the question whether changes should be proposed to the EU 
MRV Regulation to align more closely with the IMO system.   

While  conducting  this  assessment,  maintaining  an  effective  monitoring  system  and  the 
achievement  of  the  original  objectives  of  the  EU  MRV  Regulation  (as  described  in 
section 1) remain the starting points. The availability of robust and reliable data on GHG 
emissions from maritime transport is a prerequisite to assess the progress of the maritime 
transport’s  contribution  towards  achieving  climate  objectives  and,  if  necessary,  for  the 
development  of  any  mitigation  measures  in  the  maritime  transport  sector.  At  the  same 
time,  unnecessary  duplication  should  be  avoided  whenever  possible.  Methodological 
differences that are not functional to the objectives of the EU MRV Regulation should be 
eliminated or altered. Reporting obligations should be reviewed so as to enable both ship 
owners  and  EU  flag  States  to  fulfil  their  obligations  under  both  systems  in  a  way  that 
would  avoid  unnecessary  divergences.  The  EU  should  therefore  continue  to  collect 
reliable EU-related emissions data from maritime transport and incentivize the uptake of 
emission reduction measures through the publication of emissions data, whilst taking into 
account and facilitating the implementation of the recently agreed IMO DCS.  

3.1.  Legal basis  

The legal basis for acting  at  the EU level  is  the  environmental legal  basis enshrined in 
Article  192  of  the  Treaty  on  the  Functioning  of  the  European  Union,  as  the  principal 
objective  of  the  measure  is  the  protection  of  the  environment  through  the  reduction  of 
GHGs and as used as legal basis for the EU MRV Regulation adopted in 2015. 

3.2.  Subsidiarity  

As the basis of the proposal  is  EU legislation, any amendments  need to  be done at  EU 
level with the agreement of the European Parliament and of the Council. 

Collecting  and  publishing  data  of  ships'  emissions  and  energy  efficiency  based  on  a 
mandatory  set  of  requirements  has  the  advantage  that  the  results  are  fully  comparable. 
This comparability contributes to the removal of the market barrier on lack and scattered 
information. 

Collecting data at  national  level  instead of at  EU level  would significantly  increase the 
administrative  effort  for  industry  and  ships  using  ports  as  all  the  EU  Member  States 
would need to individually monitor, verify and report data. 

19 

 
 
 
 
 
4.  WHAT SHOULD BE ACHIEVED – OBJECTIVES 

4.1.  Strategic objectives 

a) 

 Addressing GHG emission from ships and ports 

The first objective is to tackle maritime’s emissions growth. Continued emissions growth 
from the shipping sector is incompatible with the climate goals of the Paris Agreement. 
The  EU  has  policies  in  place  (EU  MRV  Regulation)  that  address  these  emissions;  in 
accordance with the Paris Agreement principles, the EU should not backslide on climate 
action. The IMO is also taking steps in the same direction through the IMO DCS and its 
initial strategy recently agreed. This too should contribute to achieving the goals of the 
Paris Agreement, but for this to materialise concrete measures are yet to be agreed. 

b) 

Improving cost-effectiveness of ships by increasing their energy efficiency and 
minimising administrative burden 

The  second  strategic  objective  should  be  enhancing  the  cost-effectiveness  of  ships. 
Climate  measures  should  entail  improvements  in  energy  efficiency,  lower  fuel 
consumption,  shifting  to  renewable  fuel  solutions  and  a  reduction  of  costs  for  shipping 
companies. Minimising the administrative burden for companies, notably in the context 
of  the  co-existence  between  the  EU  MRV  Regulation  and  the  IMO  DCS,  should  also 
contribute to reducing costs. 

4.2.  Operational objective 

Facilitating  the  harmonious  and  complementary  implementation  of  the  systems  by  EU 
Member States while preserving the objectives of the EU MRV Regulation: 

With  the  entry  into  force  of  the  IMO  DCS  in  2018,  shipping  companies  will  have  to 
collect  relevant  information  on  fuel  consumption  and  other  related  data  relating  to  the 
international activities of their ships of and above 5000 GT from 2019 onwards with first 
reports due in 2020. This reporting obligation cumulates to the existing obligations under 
the  EU  MRV  Regulation  to  collect  EEA-related  CO2  emissions  and  energy  efficiency 
indicators  from  2018  onwards  with  first  reports  due  in  2019.  Alongside  preserving  the 
strategic  objective,  the  operational  objective  is  to  facilitate  the  complementary  and 
streamlined  implementation  of  the  two  systems  by  EU  Member  states,  with  the  aim  of 
reducing the administrative burden for companies obliged to report under both. 

In doing so, the original EU MRV Regulation objectives have to be preserved, i.e.: 

  Collect robust and verified CO2 emission data for EEA related shipping; 

The objective of the EU MRV Regulation is to ensure the accurate monitoring, 
reporting  and  verification  of  CO2  emissions  and  other  climate  relevant 
information from ships arriving at, staying in or departing from ports under the 
jurisdiction  of  a  Member  State,  in  order  to  promote  the  reduction  of  CO2 
emissions  from  maritime  transport  in  a  cost  effective  manner.  This  objective 
should be maintained. 

 

Prepare for future policy discussions on the need and type of further actions; 

20 

 
 
 
 
 

The  collection  and  public  availability  of  robust  information  on  CO2  emissions 
on EEA related voyages is key to inform policy-makers’ decisions on the need 
and type of further action. 

Stimulate  the  up-take  of  new  technologies  and  operational  measures  making 
ships greener; 
Monitoring  fuel,  emissions and other relevant  data at  individual ship  level  and 
providing  transparency  on  them  should  contribute  to  raising  awareness  on  the 
potential for cost-effective improvement of ship energy efficiency. It should also 
lead  to  the  delivery  of  robust  information  on  fuel  consumption  and  energy 
efficiency  of  EEA-related  shipping  to  relevant  markets.  Both  elements  are 
important  for the environmental  effectiveness  of the EU MRV Regulation, but 
also for the economic benefits associated with higher efficiency. The legislation 
impede 
should  contribute 
undertaking efficiency measures. Those measures should lead to the reduction of 
fuel consumption and, consequently, to cost savings. 

to  overcoming  existing  market  barriers 

that 

  Level playing field. 

It  is  essential  to  maintain  equal  treatment  in  order  to  avoid  distortions  of 
competition  and  to  enable  moving  to  the  later  stages  of  the  EU  strategy  at  the 
appropriate  time.  The  same  rules  should  apply  to  all  EEA-related  shipping 
activity, so a level playing field is maintained for ships competing on the same 
routes, irrespective of their flag. 

4.3. 

 Stakeholders views 

These objectives are widely in line with the interests expressed by stakeholders on their 
replies to the online public consultation and the targeted e-survey (see synopsis report in 
Annex 2). Civil society organisations, national accreditation bodies, research institutions 
and  citizens/individuals  widely  support  that  some  important  objectives  need  to  be 
preserved when amending the EU MRV Regulation. These include raising awareness on 
emission reduction, providing robust information to market players on fuel consumption 
and  energy  efficiency  and  collecting  data  for  an  informed  policy  making.  For  the 
shipping  sector  the  main  priority  is,  however,  reducing  administrative  burden.  EEA 
Member  States  and  EU  MRV  Regulation  verifiers  widely  support  these  objectives  too, 
notably  the  collection  of  reliable  data  to  develop  future  policies  and  minimising  the 
administrative burden. 

21 

 
 
 
 
5. 

POLICY OPTIONS 

Different  policy  options  have  been  considered  to  identify  the  features  of  the  EU  MRV 
Regulation  that  might  be  possibly  align  with  the  IMO  DCS.  These  alignment  options 
have been assessed based on their ability to streamline and reduce administrative burdens 
for companies and administrations, as well as their ability to guarantee the preservation 
of the objectives, integrity and robustness of the EU MRV Regulation. 

Discarded candidates for alignment 

Considering the further-reaching philosophy of the EU MRV Regulation compared to the 
IMO DCS, it would be inappropriate to align the following key elements of the EU MRV 
Regulation design: 

Governance  

Aligning the “governance” aspects of the EU MRV Regulation to the IMO DCS has been 
discarded, despite some representatives of the shipping sector have expressed support for 
relying solely on the IMO system to address EU shipping emissions. Adopting the IMO 
DCS  governance  approach  would  entail  that  the  EU  and  its  Member  States  can  only 
collect  data  concerning  emissions  from  EU-flagged  ships,  leaving  aside  the  CO2 
emissions  emitted  by  non  EU-flagged  ships  as  part  of  voyages  involving  EEAs.  This 
would prevent the gathering of complete information on EEA related shipping emissions. 
This approach would not allow meeting the objectives the legislation is pursuing, as the 
EU and its Member States would only have access to part of the EEA-related data. This 
would  not  only  limit  immediate  EU  climate  action,  but  would  also  impede  the 
development  of  any  further  measures  to  tackle  shipping  emissions,  as  required  by  the 
2013  EU  strategy.  Maintaining  the  EU  MRV  Regulation  approach  on  governance  also 
requires that reporting is done per voyage, in order to obtain emissions data, specifically, 
from  voyages  to  and  from  EEA  ports.  Therefore,  alignment  on  this  aspect  to  the  IMO 
DCS, where reporting is done in an aggregated manner, must also be discarded. 

CO2 reporting 

The possibility that ships do not report CO2 emissions data, as is the case under the IMO 
DCS, where only fuel consumption is mandatory for reporting, has also been discarded. 
This  would  be  fully  inconsistent  with  the  very  objective  of  the  EU  MRV  Regulation, 
which is related to the CO2 emissions performance of ships and their climate impact. 

Bearing in mind these limitations, three policy options have been considered: 

  Baseline Scenario (option 1) 

The baseline scenario reflects  what  would happen if action is  not taken, i.e., if none of 
the features of the EU MRV Regulation are harmonised with the IMO DCS ones. Under 
the  baseline  scenario,  the  EU  MRV  Regulation  would  remain  unchanged.  This  would 
mean that the current parameters for monitoring, reporting and verification of data under 
the  EU  MRV  Regulation  would  continue  to  apply  irrespective  of  the  existence  of 
additional IMO requirements. Ships of above 5000 GT transporting passengers or cargo 
for  commercial  purposes  using  the  European  Economic  Area  (EEA)  ports  that  have  to 
monitor and report their GHG emissions from international maritime transport activities 
related  to  the  EU  under  both  systems  would  therefore  have  to  comply  with  partially 
different rules. 

22 

 
 
 
 
  Streamlining (option 2) 

Under  this  scenario,  an  assessment  should  be  made  on  which  of  the  EU  MRV 
Regulation’s design elements could be harmonised with those of the IMO DCS in order 
to facilitate compliance and reduce costs for those shipping companies having to report 
under both systems, in a way that preserves the objectives of the EU MRV.    

To  this  end,  the  streamlining  of  the  elements  for  which  there  is  a  design  difference 
between the EU MRV Regulation and the IMO DCS should be assessed.  This includes 
the  different  alignment  candidates  (except  governance  &  CO2  monitoring)  identified  in 
section 2.2.: 

 

Scope.  

  Definitions.  

  Monitoring parameters.  

  Monitoring plans and templates.   

  Verification. 

  Transparency.  

  High Convergence (option 3) 

Under  this  option,  the  EU  MRV  Regulation  would  be  amended  to  harmonise  all  its 
technical  aspects  with  the  IMO  DCS,  at  the  risk  of  undermining  its  expected  market 
impact  and  its  key  policy  objectives.  The  EU  MRV  Regulation  would  adopt  the  IMO 
DCS’s requirements  on monitoring, reporting and verification. The same data collected 
for the purpose of the IMO DCS would be used for the EU MRV Regulation, subject to 
similar rules. This means that the data would not be verified by independent third parties 
but  checked  in  accordance  with  the  IMO  guidelines  instead.  Regarding  the  scope, 
information  on voyages  from  or to  an EU port  would still be collected,  independent  of 
flag State, but domestic and in-port emissions would no longer be covered. The reporting 
of voyage EU port information is not covered under IMO DCS, as there the reporting is 
based  on  flag  State.  Hence,  some  monitoring  parameters  would  remain  as  now  being 
recorded under the EU MRV Regulation, to be able to track this type of information. 

The next table provides a visual overview of the alignment options considered:  

23 

 
 
 
 
 
Summary table: features to be aligned to IMO DCS rules under each option (in yellow, 
elements  not  to  be  aligned;  in  green,  features  to  be  aligned,  in  light  green  partially 
aligned) 

OPTIONS 

GOVER-
NANCE & 
CO2 reporting  

SCOPE  MONITO-

RING PLANS 
& 
TEMPLATES  

DEFI-
NITIONS 

MONI-
TORING 
PARA-
METERS 

VERIFI-
CATION  

TRANSPA-
RENCY  

BASELINE 
(Option 1) 

STREAM-
LINING  
(Option 2) 

HIGH 
CONVER-
GENCE  
(Option 3) 

24 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
6.  WHAT ARE THE IMPACTS AND WHO WILL BE AFFECTED? 

This section will assess the impact of the different policy options. It is important to note 
that  the  impact  assessment  carried  out  for  the  adoption  of  the  2013  EU MRV  proposal 
went  into  an  in-depth  analysis  of  the  environmental,  economic  and  social  impacts  of 
several  alternatives,  including  the  one  finally  resulting  in  the  current  EU  MRV 
Regulation.  The  options  to  be  assessed  now  only  represent  technical  variations  to  the 
existing approach. Therefore, the previous impact assessment is still an important source 
of  data  in  order  to  assess  the  impact  of  the  different  options.  AEA  Technology,  who 
provided  support  for  that  impact  assessment,  developed  a  model  based  on  the  TIMES 
architecture, building on a representation of shipping activity, a representation of vessels 
and cost assumptions. 

Furthermore,  new  information  from  the  implementation  of  the  EU  MRV  Regulation  is 
not  available  yet,  as  the  system  has  only  started  to  be  applied  in  2018  (with  reporting 
obligations starting in 2019). 

On  that  basis,  a  qualitative  analysis  of  the  technical  changes  that  the  different  policy 
options represent is undertaken in this section.  In some cases, this is complemented by a 
quantitative  assessment  of  the  impacts,  which  relies  on  the  2013  impact  assessment 
information.   

The  options  2  and  3  differ  from  the  baseline  option  on  whether  certain  features  of  the 
current EU MRV Regulation are aligned with the IMO DCS or not, with Option 3 (High 
Convergence)  aiming  at  a  higher  harmonisation  while  Option  2  (Streamlining)  is  more 
selective  on  which  parameters  should  be  aligned.  For  that  reason,  the  following 
assessment will first consider each of these features and the impact of aligning them or 
not. This aims at obtaining a specific assessment of each individual element, which can 
help define the preferred option.  

6.1. 

 Scope 

Scope considerations refer to two different aspects: 

On  the  one  hand,  as  regards  the  geographical  scope,  the  IMO  DCS  applies  to  ships 
engaged  in  international  shipping  while  the  EU  MRV  Regulation  additionally  covers 
domestic (internal to a Member State) maritime transport. The geographical coverage of 
the EU MRV Regulation allows a more complete monitoring of the CO2 emissions from 
maritime transport in the EEA. 

Another important difference is that ships’ CO2 emissions within EEA ports are covered 
by the EU MRV Regulation and monitored and reported separately so as to incentivise 
the reduction of CO2 emissions within EEA ports and to substantially reinforce existing 
awareness  of  shipping  emissions  impacts  in  EEA  ports  and  coastal  areas.  These 
emissions are not considered by the IMO DCS. 

On the other hand, as regards the type of ships affected, both systems are already very 
much aligned. Both address emissions of ships above 5000 GT. The only difference with 
respect to the type of ships is that the EU MRV Regulation, contrary to the IMO DCS, 
does not include maritime sector activities other than transport of passengers or cargo for 
commercial purposes due to proportionality reasons.  

Aligning  the  EU  MRV  Regulation  to  the  IMO  DCS  on  scope  may  have  a  negative 
environmental  impact.  If  the  scope  of  the  EU  system  remains  unchanged,  it  would 

25 

 
 
 
continue contributing to the achievement of the projected 2% decrease in emissions that 
should deliver a cumulative emission reduction of 55.9 MtCO2 up to 2030 (as estimated 
in the 2013 impact assessment). The related reduction in fuel consumption would result 
also in a reduction of other pollutants (SOx, NOx, particulate matter) beyond current EU 
legislation, which are particularly relevant to improve air quality at local level22. 

On  the  contrary,  if  the  systems  are  aligned,  the  EU  MRV  would  not  address  domestic 
shipping  emissions23  (from  shipping  activity  between  a  State’s  ports)  and  ships’ 
emissions  in  ports.  Data  corresponding  both  to  domestic  emissions  and  to  in-port 
emissions are relevant for Member States to be able to design coherent and cost-effective 
climate, energy and environment policies, including addressing air quality at local level 
(especially  in  cities  with  large  ports  and  in  coastal  areas).  Renouncing  to  collect  those 
data would create barriers to the development of future measures to further address these 
emissions. As already mentioned, for different categories of stakeholders, and notably for 
EEA  States  authorities,  collecting  relevant  and  accurate  data  to  assess  the  evolution  of 
ship  emission  and  ensure  well-informed  policymaking  is  particularly  important,  as  the 
outcome of the public consultation shows. 

On the other hand, the extension of EU MRV requirement to fish catching and processing 
ships, wooden ships of a primitive build, and ships not propelled by mechanical means 
does  not  bring  significant  benefits,  as  the  emissions  by  these  ships  are  small.  In  fact, 
those  types  of  vessels  were  not  included  in  the  EU  MRV  scope  due  to  proportionality 
reasons24.  Also,  considerable  efforts  are  being  made  to  the  greening  of  the  EU  fishing 
fleet.  The  European  Maritime  and  Fisheries  Fund  (EMFF)  supports  fishermen  in  the 
transition  to  sustainable  fishing  by  making  funds  of  4340  million  euro  available  for 
2014/2020. 

From  a  social  point  of  view,  the  main  impacts  of  shipping  emissions  identified  in  the 
2013 impact assessment where those on human health, linked to reduction of emissions 
of pollutants such as NOx, SOx and PM (particulate matter). For the reasons explained 
above,  the  alignment  to  the  scope  of  IMO  could  have  negative  effects,  especially  as 
regards the emission reduction in ports. 

Finally, from an economic perspective, the scope of the EU MRV Regulation is expected 
to contribute to a decrease of fuel consumption of 2%. These improvements in efficiency 
would  mean  €9.4  billion  up  to  2030,  in  accordance  with  the  2013  impact  assessment. 
These gains would not change significantly in case the scope of types of ships is aligned; 
conversely, in order to maximize the efficiency improvements, it is preferable to account 
also for in-ports and domestic emissions. 

22  The  Commission  report  (COM/2018/188  final)  on  the  implementation  of  directive  (EU)  2016/802 
regulating the sulphur content of marine fuels is an example of existing efforts and legislation in this 
area. 

23  The data on the share of domestic or in-port emission is currently not available, albeit it is estimated 
that about 100 ships above 5000 GT are engaged solely in domestic trade in the EU Member States. 

24  As assessed in the 2013 Impact Assessment  for the current EU MRV  Regulation, the same  measure 
was considered not be proportionate  for certain vessels. The effect of the exclusion of certain vessel 
types  and  smaller  ship  categories  was  analysed.  Excluding  the  5  least  relevant  ship  types  (yacht, 
offshore, service, fishing and miscellaneous) as these types have the lowest average annual emission 
per ship, the number of ships was reduced by about 2000. The 13 remaining main ship types included 
tankers, bulkers, general cargo ships, other dry, container ships, vehicle carriers, roll-on/roll-off ships 
(RoRo), ferries and cruise ships. These 13 main ship types and vessels of at least 5000 GT represent 
about  11,000  ships  (56%  of  the  total  number)  representing  160  Mt  CO2  emitted  (90%  of  the  total 
amount) to and from EU ports. Further, consideration was given to the public consultation carried out 
for the 2013 IA. 

26 

 
                                                 
6.2.  Definitions 

The alignment on some key definitions such as the concept of “company” or “reporting 
period” do not have significant environmental, social or economic impacts.   

In  the  EU  MRV  Regulation,  the  owner  on  the  last  day  of  year  is  responsible  for 
emissions  in  the  calendar  year  whereas  in  the  IMO  system  responsibility  moves  to  the 
new owner from the date the ship is sold.  

Harmonising these concepts reduces the administrative burden of complying with the two 
systems.  An alignment on the attribution of monitoring and reporting obligations in case 
of “changes of companies” would ensure that the same legal entity monitors and reports 
emissions  data  for  both  the  EU  MRV  Regulation  and  the  IMO  DCS.  In  parallel,  the 
harmonisation of the “reporting period” makes possible that the monitoring and reporting 
activity takes into account similarly calculated reporting periods. Despite not having data 
available yet (reporting under the EU MRV Regulation and IMO DCS will only start in 
2019  and  2020  respectively),  it  can  be  presumed  that  if  these  parameters  were  not 
aligned, the administrative burden would be higher. 

6.3.  Monitoring parameters 

In  the  light  of  the  feedback  from  the  online  public  consultation,  streamlining  the 
parameters is a priority for the shipping sector.   

The two systems use slightly different definitions of some parameters such as “distance 
travelled” and “time spent at sea” or “hours underway”, which can be easily harmonised. 
Alignment  on  these  definitions  would  have  no  significant  environmental,  social  or 
economic impacts. It would simply facilitate convergence between the systems, resulting 
in  reducing  the  administrative  burden.  Several  stakeholders  favour  streamlining 
monitoring parameters such as “distance travelled” or “hours underway”. 

Nevertheless,  one  key  parameter  in  the  EU  MRV  Regulation  differs  from  the  one 
required by the  IMO DCS. The EU MRV Regulation  requires monitoring  actual cargo 
carried  in  order  to  obtain  accurate  information  on  individual  ship’s  operational  energy 
efficiency.  The  IMO  DCS,  instead,  uses  a  proxy  (deadweight),  which  refers  to  the 
carrying capacity of the ships.  

The alignment of this parameter is firmly supported by the shipping sector, which prefers 
reporting  cargo  capacity  for  reasons  of  simplification  and  confidentiality,  whereas  civil 
society  organisations  and  some  EEA  States,  oppose  replacing  “cargo  carried”  by 
“deadweight”  because  the  former  provides  more  accurate  data  on  ships’  individual 
energy efficiency, and, in their view, should not pose confidentiality problems due to the 
aggregated nature of the publication of data. Those opposing the alignment of the "cargo" 
parameter  (i.e.,  NGOs)  are  of  the  view  that,  when  using  deadweight  as  a  parameter,  a 
ship's  operational  efficiency  metric  does  not  differentiate  an  empty  ship  from  a  more 
efficient one and thus there will be no incentive towards higher operational efficiency of 
individual ships.  

Indeed, using the carrying capacity instead of the cargo that ships actually carry provides 
less  accurate  data  on  average  energy  efficiency.  The  alignment  on  the  parameter  of 
“cargo  carried”  /  “deadweight”  may  therefore  have  environmental  and  economic  and, 
indirectly, social impacts, in particular if the focus is on the improvement of individual 
ships  efficiency.  The  estimated  2%  improvement  in  fuel  consumption  of  the  EU  MRV 

27 

 
 
 
depends  on  a  better  knowledge  of  the  ship’s  real  efficiency,  which  should  trigger 
measures  resulting  in  less  energy  use.  In  this  regard,  both  the  estimated  cumulative 
emission reduction of 55.9 MtCO2 up to 2030 and the estimated economic benefits linked 
to improving efficiency (€9.4 billion up to 2030) may not be maximized.  

On the other hand, several operational energy efficiency indicators that do not use cargo 
carried  as  a  parameter  have  shown  encouraging  results25.  The  reason  being  that  when 
using  deadweight  instead  of  actual  cargo  data  to  calculate  energy  efficiency  of  ships, 
there is significantly less spread or scatter in the attained values and therefore, it is easier 
to define a reference line and monitor the trends in energy efficiency.  

Therefore, using 'deadweight' as a proxy for 'cargo carried' could still provide a basis for 
analysis and information about the energy efficiency of ships, as it takes into account its 
size and cargo carrying capacity. The use of such a proxy could already provide useful 
information for the purpose of defining future policies and measures.  

Consideration  should  also  be  given  to  the  administrative  burden  for  collecting  and 
reporting  cargo  carried  information.  Having  the  same  monitoring  parameters  reported 
under the two systems would significantly lower the administrative burden for the parties 
having to collect such data.   

It  can  be  concluded  that  aligning  the  EU  MRV  Regulation  with  the  IMO  DCS  on  this 
particular  feature  may  limit,  to  a  certain  extent,  the  beneficial  impacts  of  the  current 
approach  particularly  in  terms  of  triggering  efficiency  improvements  at  ship  level. 
However, the  IMO  DCS parameter “deadweight” can still provide relevant  information 
for the design of future measures aiming at improving ships’ operational performance. 

It should be noted that, once companies have started monitoring cargo carried, some may 
chose continuing doing so on voluntary basis.  In fact,  part of the shipping industry has 
shown interest to continue collecting those data and submitting them in order to set the 
basis for efficiency improvements. Apart  from  “distance travelled”,  “time spent at  sea” 
and “cargo carried”, the streamlining of other parameters does not need to be considered, 
either  because  it  has  been  discarded  (ports  of  departure  and  arrival,  CO2  emitted)  or 
because it is already similar (amount of fuel and emission factors). 

The  table  below  summarizes  the  main  conclusions  on  the  streamlining  of  monitoring 
parameters. 

25  Such  are  the  Individual  Ship  Performance  Indicator  (ISPI)  developed  by  the  EC/EMSA  (MEPC 
submissions at MEPC 66 – MEPC 66/4/6) and the Annual Efficiency Ratio (AER) (proposed by Japan). 
These  parameters  use  fuel  consumption  and  distance,  and  in  the  case  of  AER  deadweight  tonnage 
(DWT). The pertinence of these indicators has been revalidated by an analysis by Norway (submitted to 
MEPC  71  and  the  first  meeting  of  the  intersessional  working  group  on  the  reduction  of  GHG  from 
ships– MEPC 71/7/1 and ISWG-GHG 1/2/1). 

28 

 
 
 
                                                 
Table 6.1 Conclusions on streamlining monitoring parameters. 

EU MRV Regulation  

IMO DCS 

Port  of  departure  and 
arrival 

Not required. Aggregated 
reporting. No obligation to 
monitor per voyage. 

CONCLUSION  ON  STREAMLINING 
OF MONITORING PARAMETERS 

Discarded. Linked to governance. 
Parameter needed in EU MRV Regulation 
to distinguish journeys to and from EEA 
ports. 

Amount  and  emission 
factor  for  each  type  of 
fuel 

CO2 emitted 

Distance travelled 

Time spent at sea 

Cargo carried 

Required. Similar. 

Alignment not needed. Already similar. 

Not required (although it 
can be obtained without 
further monitoring with 
the data on fuels and 
emission factors) 

Required. Different 
definition. 

Required. Different 
definition. 

Different parameter 
(deadweight, which refers 
to cargo capacity). 

Discarded. Essential parameter for the EU 
MRV Regulation 

Alignment can be easily achieved. 

Alignment can be easily achieved. 

Actual cargo date would be missed, but 
deadweight also provides useful 
information. Alignment would reduce 
administrative burden, and it is considered 
beneficial.  

Transport work 

Not required 

Linked to cargo.  

6.4.  Monitoring plans and templates 

The  alignment  of  monitoring  plans  and  templates  would  be  a  measure  of  formal  / 
administrative  nature  that  would  have  no  environmental,  social  or  economic  impacts.  
However, it would importantly reduce the administrative burden for companies obliged 
to report under both the EU MRV Regulation and the IMO DCS, as it would allow using 
the same approach and similar documents for both, when alignment is possible.  

6.5.  Verification 

The EU MRV Regulation requires mandatory third party verification in order to ensure 
the  accuracy  of  the  data  submitted.  It  uses  a  specific  verification  system  based  on 
internationally agreed ISO standards and EU specific verification rules. Furthermore, EU 
MRV  verifiers  are  accredited  and  subject  to  supervision  by  National  Accreditation 
Bodies.  This  regime  is  common  to  other  economic  sectors  in  the  EU  subject  to  MRV 
requirements, including the power sector, the industry, aviation, it is already in place and 
being  applied in the EU (including to  shipping through the EU MRV Regulation). The 
mandatory verification also ensures consistency across States on the quality of the checks 
carried out on the data and is therefore key to ensure the collection of robust data.  

In the IMO DCS there is no specific verification system for this data collection.  Instead, 
flag Administrations shall verify the data according to national rules, taking into account 

29 

 
 
 
IMO  guidelines.  Flag  States  can  outsource  those  tasks  to  “Recognised  Organizations” 
(RO), subject to verifications and audits under the RO Code. However, ROs do not need 
to be accredited by National Accreditation Bodies. Note that, in accordance with the EU 
legislation,  EU  MS  have  to  use  only  EU  recognised  organisations  in  order  to  comply 
with their reporting obligations under IMO DCS. 

The alignment of this feature of the EU MRV Regulation with the IMO DCS rules would 
mean  that  the  EU  verification  system  would  be  replaced  by  a  system  based  on  less 
harmonised rules and departing from the concept of third party verification. 

Such a change could potentially  affect the accuracy and reliability of the MRV system, 
entailing,  possibly,  a  negative  impact  in  terms  of  the  environmental  and  economic 
performance  of  the  scheme.  It  could  also  negatively  affect  the  development  of  future 
climate policies, which should rely on solid data.   

It  should  be  noted  that  verification  cost  turned  out  to  be  significantly  lower  than 
estimated in the 2013 impact assessment (€4500), in the order of below €1000 (according 
to industry sources, albeit the estimates vary). This is similar to the costs of about 1 or 2 
tons shipping fuel. 

The outcome of the online public consultation shows that almost  all stakeholders agree 
with the need to ensure high quality data and a level playing field.  Representatives of the 
shipping  sector  showed  concerns  about  the  cost  of  verification;  although  aligning 
verification rules with the IMO DCS ones seems not to be a priority for the sector.  

6.6.  Transparency 

Similar  to  other  sectors,  the  EU  MRV  Regulation  includes  the  publication  by  the 
Commission  of  annually  reported  aggregated  data  on  a  "per  ship"  basis  (without 
differentiating between journeys). This level of transparency was considered one of the 
key  objectives  of  the  EU  MRV  Regulation.  In  contrast,  the  IMO  central  database  will 
only include anonymous datasets without the possibility to identify individual ships and 
will  only  be  accessible  to  IMO  Member  States26  strictly  for  their  analysis  and 
consideration . The data will not necessarily be made available to the public. 

The  alignment  in  this  case  would  mean  that  the  data  reported  under  the  EU  MRV 
Regulation, i.e. information on the CO2 emissions and the energy efficiency of individual 
ships, would not be available to stakeholders and to the public. 

The  2013  impact  assessment  found  that  disclosure  of  "per  ship"  aggregated  energy-
efficiency information  and robustness  of comparable over time data would  be the most 
important  elements  under  the  EU  MRV  Regulation  to  address  the  market  failures 
hampering energy efficiency improvements in the sector. 

As said,  the regular publication of per-ship  energy  efficiency information was  found to 
be  one  of  the  key  elements  to  overcome  market  barriers  and  reach  the  estimated  2% 
improvement in fuel consumption (bringing  positive environmental impacts in terms of  
CO2  emission  reductions  (cumulative  55.9  Mt  up  to  2030),  black  carbon  emissions 
(which  are  important  short-lived  climate  forcers)  and  air  pollutants  such  as  SOx,  NOx 
and particulate matter (impacting human health). To this end, both the collection of data 
on  a  per  ship  basis  and  their  publication  in  a  transparent  form  are  instrumental  to  the 
objectives  being  pursued.  Removing  transparency  would  remove  incentives  to  enhance 

26  Parties to MARPOL Annex VI. 

30 

 
 
                                                 
efficiency  and  reduce  fuel  use,  loosing,  at  least  partially,  the  social,  environmental  and 
economic benefits of the EU MRV Regulation.   

Furthermore, the harmonization with the IMO DCS on transparency would not mean any 
gain in terms of reducing the administrative burden, as the publication does not affect the 
monitoring and reporting obligations.     

Keeping  the  EU  MRV  levels  of  transparency  is  fundamental  for  most  categories  of 
stakeholders  (citizens,  NGOs,  academia,  verifiers,  etc.),  with  the  shipping  sector  being 
more sceptical about its usefulness. In any case, harmonising this feature of the EU MRV 
is not a priority for the sector (especially in the case if actual cargo carried is not to be 
reported).  

6.7.  Impacts on SMEs 

The  EU  MRV  Regulation  applies  to  ships  above  5000GT.  This  threshold  excludes 
around 99% of maritime transport SMEs from the scope of the regulation, as estimated 
by the 2013 impact assessment.  

31 

 
 
 
 
7.  HOW DO THE OPTIONS COMPARE? 

7.1.  Comparison of options 

As seen in the previous section, some features of the EU MRV Regulation can be aligned 
with  those  of  the  IMO  DCS  ones  without  compromising  the  environmental,  social  and 
economic benefits  to  be  delivered by the  existing EU legislation. Aligning some of the 
features  would  have  a  positive  impact  in  terms  of  reducing  the  administrative  burden 
linked to the existence of the two systems. However, aligning some other features would 
reduce  the  improvement  in  energy  efficiency  of  the  shipping  sector  that  the  EU  MRV 
Regulation  is  expected  to  deliver  and  undermine  its  main  objectives.  That  would  mean 
that  less  CO2  emission  reductions  would  be  achieved,  and  lower  economic  gains 
associated with lower fuel consumption would be attained.  

When comparing the options we can conclude that: 

  Under Option 1 (Baseline) the positive environmental and social impacts identified 
by  the  2013  impact  assessment  are  maintained.  The  2%  reduction  in  fuel 
consumption results in the cumulative avoidance of 55.9 Mt CO2 by 2030. In parallel, 
there  is  a  reduction  in  emissions  of  air  pollutants  such  as  SOx,  NOx  and  particular 
matter, which results in social benefits is terms of a reduced impact on human health. 
Finally,  the  expected  economic  impact  of  saving  €9.4  billion  up  to  2030  as  a 
consequence of lower fuel consumption would also be delivered. This option would 
meet  the  operational  objectives  related  to  reducing  shipping  emissions,  enhancing 
cost-effectiveness  and  maintaining  a  level  playing  field.  However,  it  would  fail  on 
achieving  a  streamlined  implementation  of  the  two  systems.  It  would  result  in  a 
somewhat  higher  administrative  burden27,  related  to  the  definition  of  some  basic 
parameters such as “distance travelled” and “time spent at sea” or “hours underway). 

  Under  Option  2  (Streamlining),  the  positive  impacts  of  the  current  EU  MRV 
Regulation can be maintained if some key features are kept unchanged. In the light of 
the assessment in section 6, “scope”, “verification” and “transparency” are the three 
key alignment candidates that most impact the effectiveness of the scheme. Aligning 
on those elements would risk jeopardising the objectives of the EU MRV Regulation. 
On  the  other  hand,  streamlining  the  definitions,  monitoring  parameters  and 
monitoring plans and templates reduces the administrative burden associated with the 
co-existence with the IMO DCS without putting at risk the estimated positive impacts 
of  the  current  legislation.  While  the  alignment  of  the  monitoring  parameter  “cargo 
carried” / “deadweight” could result in lower efficiency gains, it has benefits in terms 
of  reducing  administrative  burden  for  companies  although  MRV  costs  are  already 
considered  very  low.  Based  on  these  different  elements,  the  alignment  of  this 
parameter has been proposed. 

  Under  Option  3  (High  Convergence), 

terms  of  “scope”, 
“verification”  and  “transparency”  would  significantly  undermine  the  expected 
environmental, social and economic benefits of the EU MRV Regulation as shown in 
the analysis of option 2. In short, although this option might lead to more significant 

the  changes 

in 

27  The administrative burden of the EU MRV was, nevertheless, estimated as very low by the 2013 Impact 
Assessment.  In cases  where ship-owners and ship operators do not  yet apply  fuel  monitoring of their 
emissions, it was estimated at €26.1 million per year for ships above 5000 GT. This represents 0.28% 
of the average operational costs (excluding fuel costs). The 2013 Impact Assessment also mentions that 
many  ship-owners  have  already  adopted  highly  sophisticated  MRV  standards  and  will  have  no 
difficulty complying.  

32 

 
 
                                                 
reduction in administrative burden compared to option 2, it would reduce or supress 
the  incentives  to  overcome  market  barriers  and  get  the  efficiency  improvements 
pursued  through  the  EU  MRV  Regulation.  Furthermore,  because  less  detailed  and 
possibly less accurate data would be obtained, the EU and Member States would face 
limitations  to  develop  future  policies  to  address  shipping  emissions.  This  would 
compromise  the  EU  strategy  to  tackle  these  emissions,  based  on  a  progressive 
approach where the EU MRV is only a first step. This option would better deliver on 
the operational objective of ensuring a harmonious implementation of the EU and the 
IMO schemes, but would fail on meeting the objectives related to reducing emissions 
and improving cost-efficiency. 

7.2.  Preferred option 

In the light of the comparison above it can be concluded that an approach where, under 
Option 2 (streamlining), some selected parameters (in relation to definitions, monitoring 
parameters and monitoring plans and templates) are streamlined delivers, largely, on all 
the  aspect  of  the  operational  objective  identified  in  section  4.  This  partial  alignment 
achieves,  where  considered  appropriate,  a  reduction  of  the  administrative  burden  and 
associated costs of an EU MRV Regulation being applied in combination with the IMO 
DCS, while, at the same time, it preserves most of the positive impacts estimated by the 
2013  impact  assessment  by  not  aligning  features  such  as  scope,  verification  and 
transparency. 

Compared to this approach, Option 1 means a higher administrative burden for affected 
entities plus monitoring and reporting of slightly different  data under two separate data 
collection systems, as some definitions are not aligned between IMO DCS and EU MRV 
Regulation.   

As  regards  option  3,  it  clearly  puts  at  risk  the  positive  impacts  of  the  EU  MRV 
Regulation.  On  Option  3  notably,  for  verification  we  would  give  up  data  reported  by 
shipping  companies  to  be  verified  by  a  verifier  accredited  via  Regulation  2016/2072. 
This  independent  verification  system  is  a  well-established  system  in  the  EU  to  ensure 
robust and reliable data, and insisting on ISO standards guarantees the robustness of data, 
a  principle  well-guarded  in  the  larger  Paris  Agreement,  aside  of  the  general  EU 
obligations  to  use  ISO  standards  when  available.  No  independent  standardised 
verification is required under the IMO DCS. 

In  particular,  the  information  on  EU  emissions  from  ships  sailing  under  a  non-EU  flag 
would be missed, which could amount to half of the EEA related emissions. Regarding 
transparency, the foreseen benefit of having energy efficiency data available at ship level 
to incentivise the uptake of such measures, would be lost, as no such data will become 
available  via  the  IMO  DCS  system.  This  was  an  important  part  of  the  considerations 
given  in  the  2013  impact  assessment,  namely  that  ship-owners,  ship  operators  and 
charterers may not be aware of the energy efficiency of a ship, and are therefore not able 
to compare this energy efficiency amongst other ships or are not aware of technologies 
delivering  cost-effective  emissions  reductions.  The  political  agreement  between  the 
institutions  confirmed  the  importance  to  retain  this  aspect  with  the  adoption  of  the  EU 
MRV Regulation in 2015. 

Consequently, Option 3 is discarded and Option 2 (streamlining), as described above, is 
considered as the preferred option.   

This is also in line with the priorities expressed by most stakeholders on the online public 
consultation,  where  there  was  wide  consensus  on  aligning  technical  aspects,  with  the 

33 

 
 
streamlining of monitoring parameters being the main priority for the shipping sector. At 
the same time, it keeps the EU MRV approach on verification and transparency, in line 
with  civil  society, academia, citizens and Member States interest  to  collect  and publish 
reliable  data  that  raise  awareness  on  emission  reductions,  contribute  to  address  market 
barriers and improve efficiency and provide a solid basis for informed policymaking.  

The most sensitive element  of this option is the alignment of the monitoring parameter 
“cargo  carried”  /  “deadweight”,  where  also  stakeholders’  views  are  split,  with  civil 
society  organisations  opposing  to  it  and  the  shipping  sector  being  strongly  supportive. 
Aligning  this  element  helps  to  reduce  the  administrative  burden  and  it  is  considerate 
appropriate.  In  any  case,  some  entities  that  had  already  started  reporting  cargo  carried 
under  the  EU  MRV  might  be  interested  in  continuing  reporting  cargo  carried.  This 
should not be prevented. For this reason, it is proposed to allow entities to report cargo 
carried on voluntary basis. 

34 

 
 
 
Table  7.1.  Summary  table:  assessment  of  impacts  from  the  alignment  with  IMO  DCS 
rules per feature 

The  following  table  provides  succinct  conclusions  on  the  impact  (positive,  negative, 
neutral)  of  fully  aligning  the  EU  MRV  rules  to  the  IMO  DCS  rules  on  the  different 
features assessed:  

Scope 

Definitions 

Monitoring 
parameters 

Monitoring 
plans/ 
templates 

Verification 

Transparency 

Alignment with 
IMO  DCS  

Impacts 

Environmental, 
economic 
health impacts 

and 

Negative: 
domestic and 
in-port 
emissions not 
covered  

Neutral: no 
impact on 
the 
effectiveness 
of EU MRV 
regulation 

Slightly 
negative: 
actual 
information 
on ships 
efficiency 
missing 
because 
ships not 
reporting 
cargo 
carried, but a 
useful proxy 
(deadweight) 
is collected 

Positive: 
same 
parameters 
are 
monitored 
under both 
systems 

Neutral: no 
impact on 
the 
effectivene
ss of EU 
MRV 
regulation 

 Negative: less 
harmonised 
verification 
rules departing 
from the 
concept of third 
party 
verification 
could possibly 
lead to less 
reliable data 

Negative:  

lack of public 
information 
reduces 
incentives to 
improve 
efficiency 

Slightly positive: 
double 
verification not 
needed 

Neutral: not 
publishing the 
data does not 
reduce the 
administrative 
burden  

Positive: 
same 
templates 
and plans 
are used to 
report 
under both 
systems 

Administrative 
burden 

Neutral:  more 
ships 
categories to 
report their 
emissions but 
not for 
domestic  
voyages and in 
ports. 

Positive: 
same entities 
report 
according to 
the same 
timelines 
under both 
systems 

Summary:  

The  analysis  that  has  been  undertaken,  as  summarised  in  the  table  above,  shows  that 
streamlining elements like the definitions, the monitoring parameters and the monitoring 
plans  and  templates  contributes  to  reducing  the  administrative  burden  for  shipping 
companies, facilitating compliance with the reporting obligations under the two systems. 

At the same time, this does not jeopardise the objectives pursued by the current EU MRV 
Regulation  and  its  projected  positive  impacts.  Conversely,  aligning  aspects  such  as 
scope, verification or transparency (and governance) would severely affect the objectives 
pursued  by  the  EU  MRV  Regulation,  while  not  contributing  to  reducing  the 
administrative burden (except to some extent in the case of verification). 

35 

 
 
  
 
 
 
 
 
 
 
 
 
 
 
Consequently, Option 2 (Streamlining) should be the preferred option, and elements such 
as definitions, the monitoring parameters and the monitoring plans and templates should 
be aligned as appropriate.  

36 

 
 
 
8.  MONITORING AND EVALUATION 

The Impact Assessment carried out in the context of the Proposal for the 2015 EU MRV 
Regulation proposed five indicators to monitor and evaluate the progress made towards 
the  reduction  of  GHG  emissions  from  maritime  transport.  The  ones  valid  for  this 
alignment proposal are: 

a.  Annual CO2 emissions from maritime transport within the EU scope (on a per 

ship and fuel consumption basis); 

b.  Annual  CO2  emissions  from  maritime  transport  compared  to  the  annual 

maritime transport activity of the EU (in tonnes-nautical miles); 

c.  Annual  turnover  of  European  shipbuilders,  equipment  manufacturers  and 

services providers of the shipping sector; 

d.  Number  and  percentage  of  ships  that  are  monitoring  and  reporting  their 
emissions in line with the regulation compared to the number of ships calling 
into EEA ports. 

It  furthermore  indicated  that  these  indicators  should  be  calculated  on  an  annual  basis 
based on data from relevant European Agencies provided by the Competent Authorities 
and that the functioning of measures for monitoring and reporting of emissions as well as 
for internalisation of climate externalities and any potential revenue recycling should be 
reviewed periodically. 

The first and second indicators are data collected as part of the monitoring and reporting 
requirements. They aim to ensure that the objective to reduce the impact of EU shipping 
emissions on climate through a reduction in CO2 emissions from maritime transport by at 
least 40% by 2050 compared to 2005 levels as put forward in the 2011 White Paper on 
Transport Policy28 is fulfilled. The third indicator aims to ensure the objective to promote 
technological  improvement  of  ships  and  to  improve  the  competitiveness  of  maritime 
supply  chains  of  the  EU  by  supporting  continued  innovation  of  the  European 
shipbuilders, equipment manufacturers and service providers of the shipping sector.   

Regarding  the  fourth  indicator,  the  number  of  ships  that  are  monitoring  and  reporting 
their  emissions  can  be  compared  with  the  number  of  ships  calling  into  EEA  ports  and 
these numbers can be provided by EMSA using the Thetis MRV database. This indicator 
aims to address compliance of the EU regulation by the shipping sector. 

The monitoring and evaluation will be carried out in the context of the reporting of the 
Commission  on  the  implementation  of  the  EU  MRV  Regulation.  The  EU  MRV 
Regulation obliges the Commission to publish by 30 June each year the information on 
CO2  emissions  reported  as  well  as  other  relevant  information  (Article  21).  The 
Commission  is  also  required  to  publish  an  annual  report  on  CO2  emissions  and  other 
relevant information from maritime transport. Furthermore, the Commission is also asked 
to  assess  every  two  years  the  maritime  transport  sector's  overall  impact  on  the  global 
climate including through non-CO2-related emissions or effects.  

As the monitoring and reporting required by the Regulation has only started in January 
2018  and  the  first  reports  are  due  in  June  2019,  the  monitoring  and  evaluation  of 
implementation  of  the  Regulation  is  only  possible  after  this  date.  In  any  case,  the 
monitoring  and  evaluation  of  the  amended  regulation  will  only  be  possible  after  the 

28  Regulation  (EC)  765/2008  setting  out  the  requirements  for  accreditation  and  market  surveillance 

relating to the marketing of products and repealing Regulation (EC) 399/93 

37 

 
                                                 
amended regulation has been adopted by the European Parliament and the Council, and 
has entered into force. 

38 

 
 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

Lead DG Decide Planning internal references  

The  Directorate-General  (DG)  for  Climate  Action  was  leading  the  preparation  of  this 
initiative and the work on the impact assessment in the European Commission. 

Organisation and Timing 

An inter-service steering group (ISG), chaired by DG Climate Action and the Secretariat-
General  was  established  in  May  2017  for  preparing  this  initiative.  The  ISG  met  four 
times  in  the  period  from  May  2017  to  July  2018.  The  following  Directorates-General 
(DGs)  were  invited  to  participate  in  the  work  of  the  group:  Secretariat-General  (SG), 
Legal  Service  (SJ),  EEAS,  DG  GROW,  DG  MOVE,  DG  ENER,  DG  ENV,  RTD,  DG 
REGIO, DG FISMA and DG TRADE. 

An Inception impact assessment was published in June 2017.  

An  online  public  consultation  took  place  from  7  September  to  1  December  2017  (see 
Annex 2). 

Table 1.1.  ISG meeting dates and topics of discussion as well as other consultations 

Date 

10.05.2017 

Topics of discussion 

Context  of 
Regulation 2015/757/EC timeline for adoption; 

the  Commission  proposal  for  a  Regulation  amending 

draft Inception Impact Assessment (IIA), 

draft terms of reference for a study supporting the Impact Assessment, 

draft Consultation strategy. 

20.07.2017 

Overview of the feedback received on the Inception impact Assessment  

Presentation  and  last  discussion  on  the  terms  of  reference  and  the 
consultation strategy  

Discussion on the draft questionnaires for the public online consultation  

07.12.2017 

Overview of participation in the online public consultation.  

06.06.2018 

Presentation  of  the  outline  and  general  sections  of  the  draft  IA:  problem 
definition and objectives of the IA; discussion on main policy options to be 
developed  by  the  consultants  in  the  study  supporting  the  impact 
assessment. 

Update on recent developments and updated work plan; presentation of the 
draft  Impact  Assessment  (SWD),  and  its  annexes  (including  Annex  2  on 
the output of stakeholders' consultation activities). 

39 

 
 
 
 
 
 
 
 
External Expertise 

Analysis  supporting  this  proposal  was  undertaken  via  a  study  commissioned  by  DG 
CLIMA.  

The  Regulatory  Scrutiny  Board  (RSB)  of  the  European  Commission  assessed  a  draft 
version of the present  evaluation  and issued its  positive opinion on Friday, 13th of July 
2018.  The  Board  made  several  recommendations  to  further  improve  the  report.  Those 
were addressed in the revised report as follows: 

RSB recommendations 

Modification of the report 

political 
the 
Clarify 
intention  of  Article  22 
on revision with IMO 

Add further clarification 
on  the  greater  UNFCC 
framework  and  the  role 
of EU MRV 

Add  quantification  on 
impact  of  fishing  boats 
being  outside  of 
the 
scope of MRV   

Add  quantification  on 
emissions relevant to the 
EU  region  that  would 
not  be  covered  in  IMO 
DCS   

Provide 
information 
administrative burden  

more 
the 

on 

explain 

Further 
reporting 
under both systems 

the 
obligations 

Provide  more  details  on 
how  energy  efficiency  is 
covered  in  IMO  versus 
EU MRV 

Explain 
benefits  of 
alignment  

better 

the 
technical 

better 

the 
Explain 
effects  and  benefits  of 
transparency  on  energy 
efficiency of ships  

Text added to the Introduction 

Additional  clarification 
section 1.1 

introduced 

in 

Quantification added to section 6.1 

Quantification added to section 2.2 

Additional  context  provided  in  section 
6.5 

Further details added to section 2.1.1 

Further  details  on  SEEMP  added  to 
introduction,  additional  detailing 
in 
section 2.1.2 and 7.2 

Explanation added to 7.1 and 7.2, and 2.2 

Explanation added to 7.2 

Burden 
information 

and 

from 

cost 
the 

Throughout the document 

40 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
original  2013 
impact 
assessment  should  be 
added 

Interlinkage 
between 
IMO  and  EU  system 
better 
be 
should 
explained 

Importance  of  a  robust 
system 
verification 
should 
further 
clarified 

be 

The 
and 
options 
difference    between  the 
options  should  be  better 
described 

report 

should 
The 
explain  upfront  that  the 
IMO 
cannot 
system 
replace  the  EU  MRV 
without undermining the 
purpose of the MRV 

Figure  added  to  Annex  5,  plus  reference 
in text in 2.2 

Explanation added to 7.2 

An  improved  table  was  added  to  section 
5, plus additional detailing in section 7.1 
and 7.2, and a new table in Annex 3 

Revised introduction 

41 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX 2: SYNOPSIS REPORT 

Stakeholder consultation activities 

INTRODUCTION 

The  Commission  has  actively  engaged  with  stakeholders  throughout  the  impact 
assessment process in line with the consultation strategy. 

This  Annex  provides  a  summary  of  the  outcomes  of  the  stakeholder  consultation 
activities,  analysis  of  the  range  of  stakeholder  groups  that  were  engaged  in  those 
activities  and  a  summary  of  the  main  issues  raised.  The  objectives  of  the  consultation 
activities were to: 

 

 

Enhance  Commission's  understanding  of  stakeholders'  and  wide  public  views 
regarding  the  way  the  global  IMO  DCS  could  be  taken  into  account  under  the 
MRV shipping legal framework  

Gather specialised input (data and factual information, expert views) from private 
and  public  stakeholders'  perspective  so  as  to  help  to  identify  solutions  fitting  the 
MRV shipping objectives. 

CONSULTATION ACTIVITIES AND METHODOLOGY  

The consultation activities included: 

 
 
 

Feedback received in relation to the Inception Impact Assessment. 
A public on-line consultation between 8 September and 1 December 2017. 
A  targeted  e-survey  organised  by  consultants  during  the  period  December  2017  - 
January 2018. 

OVERVIEW OF CONSULTATION ACTIVITIES 

 

FEED BACK TO THE INCEPTION IMPACT ASSESSMENT (IIA) 

The Commission received 19 contributions further to the publication of the IIA in June 
2017. A majority came from the shipping sector (12), which submitted common and, in 
some  cases,  identical  contributions.  Some  NGOs  active  in  transport/environment  (4), 
European  Accreditation  EA  (1),  Class  societies  (1)  and  other  associations  (1)  also 
participated. 

Views on the policy options and related potential impacts can be summarised as follows: 

Full  alignment:  the  shipping  sector  is  the  only  sector  largely  supporting  this  option. 
However  a  thorough  reading  of  their  contributions  indicates  that  they  support  an 
interpretation which amounts "to only IMO DCS should be in place" and that collection 
and  reporting  of  EU  data  has  become  redundant.  Their  main  reasons  are  related  with 
reducing administrative burden and the future global action sparking new behaviours. 

Partial  alignment:  a  majority  of  the  other  respondents  (NGOs,  a  class  society  and 
European  Accreditation)  indicated  that  valuable  shipping  MRV  elements  (metrics  for 
operational efficiency, verification and publication) should be kept. Two NGOs called for 
additional data or insights on likely impacts of these different elements. 

Non alignment: one respondent chose this option invoking the need to ensure monitoring 
and reporting of domestic" emissions and "emissions within EU ports".  

These results  were taken into consideration in  order to  design the questionnaire for the 
on-line public consultation. 

42 

 
 
 
 
 

PUBLIC ON LINE CONSULTATION (OPC) 

Format and participation per stakeholder group 

It  consisted  of  six  closed  questions  covering  general  objectives  and  more  specific 
shipping  MRV  objectives  and  its  relation  with  its  key  aspects.  Two  final  open-ended 
questions enabled further comments or suggestions. Also almost a quarter of respondents 
submitted positions or non- papers summarising their views29. 

Overall,  118  responses  were  submitted,  mainly  from  stakeholders  from  EEA  countries 
(28 EU MS, plus NO and IC). Respondents from Greece (19), Belgium and the United 
Kingdom  (12  each)  formed  the  largest  groups.  Ten  per  cent  of  respondents  (12)  were 
from countries outside of the EEA. 

Participation of stakeholders' groups can be summarised as follows: 

 

Shipping sector: It is the quantitatively prevalent group with slightly over 50 
per cent of respondents from shipping companies or individuals working for 
them  (32),  (most  of  them  from  Greece  have  submitted  very  similar,  if  not 
identical,  answers),  and  from  industry  associations  (28).  A  high  level  of 
coordination has been found in the answers of this group. 

  EEA  States/non-EEA  Flag  administrations:  its  participation  is  also 
significant (14), with 11 EEA national administrations, plus a consortium of 
EEA local and regional public entities and also 2 non-EEA States; 

  Civil society organisations/NGOs (11): includes non-lucrative organisations 
active in environment and transport and also EU /non- EU trade unions; 
  EU  MRV  verifiers  and  Classification  Societies:  (7)  includes  MRV 
independent verifiers, its associations (5) plus classification societies (2) 
Providers  of  monitoring  and  reporting  technology  or  consultancy 
services (7); 

 

  Accreditation Bodies (4): European Accreditation plus two NABs (one not 
providing  accreditation  for  MRV  activities)  and  a  non-EEA  accreditation 
body. 

  Research/academia (4).  
  Citizens  (7):  only  seven  respondents  have  qualified  as  "individual/citizens 
replying in their personal capacity" - the rest given their professional profile 
and in some cases the high level of coordination in their answers in the case 
of the shipping sector, have been considered as part of the above groups. 

  Other actors: 2 respondents represent ports and their associations. 

29  required under Article 21 of Regulation (EU) No 525/2013.  

43 

 
 
 
 
                                                 
Summary of input to OPC 

a)  Policy objectives Sector's contribution to the Paris mitigation objectives 

The  statement  on  a  fair  contribution  of  the  sector  to  the  climate  goals  of  the  Paris  was 
largely supported by majority of the respondents from  all groups.  However a relatively 
important share of the shipping sector and in particular its professional associations (12) 
opted for a "don't know” answer. 

b)  Specific policy objectives to be taken into consideration when assessing MRV 

amendments 

Stakeholders were asked to specify the degree of importance they attached the following 
four objectives, in the view of assessing likely amendments to the EU MRV Regulation: 

1) 

2) 

3) 

4) 

providing  company-internal  tools  raising  awareness  on  emission  reduction 
opportunities and triggering action at company level; 

providing robust information to the markets on ships' fuel consumption and energy 
efficiency; 

collecting transparent data for informed policy making, and 

reducing  administrative  burden  for  ships  performing  EEA-related  maritime 
transport. 

On  the  one  hand,  civil  society  organisations,  Accreditation  bodies  and  Research 
citizens/individuals overwhelmingly support the three-wide ranging objectives (letters a, 
b, and c) while letter d is considered as "not important/somehow important" 

Conversely,  the  shipping  sector  and  non-EEA  Flag  Administrations  consider  reducing 
administrative  burden  as  a  very  important  one  while  the  other  three  wide  ranging 
objectives are considered relatively important objectives. 

As  a  middle  ground,  EEA  MS  and  EU  MRV  verifiers  widely  support  the  three  wide-
ranging  EU  objectives,  (in  particular  EEA  MS  "collecting  transparent  data  for  further 
informed  policy  making"  (letter  c)  appears  as  "very  important").  They  also  support 
"lessening administrative burden," as an important objective, but not to the same extent 
as the shipping sector. 

c)  Ranking key areas for amendment in light of the objectives pursued 

Stakeholders  were  asked  to  rank  five  key  areas  where  amendments  to  the  EU  MRV 
Regulation  could  be  considered:  a)  scope,  b)  monitoring  parameters,  c)  verification 
approach  and  specificity  of  the  rules  applicable;  d)  transparency/  public  access  to  data 
collected and e) monitoring and reporting processes (including templates). 

The  shipping  sector  considered  "Monitoring  parameters"  followed  by  "Monitoring  and 
reporting  processes"  as  their  highest  priority.  Under  this  assumption,  verification, 
transparency and scope ranked lower. 

MRV  verifiers/RO  have  quite  mixed  views:    with  some  of  them  ranking  "Monitoring 
parameters"  and  "monitoring  mechanisms"  and  others  ranking  "Verification"  as  their 
highest priority, probably with a view to ensure mutual recognition of those performing 

44 

 
 
 
verification. In any case, "transparency/publication of data" ranks as their lowest priority 
for amendment.  

EEA  MS/Flag  Administrations  ranked  higher  "scope"  but  limited  to  IMO  DCS 
definitions  followed  by  "Monitoring  processes  (incl.  templates)  while  "per-voyage" 
monitoring  shall  be  maintained,"  Monitoring  parameters",  "verification"  and 
"transparency" rank lower in any case. 

Civil  society  organisations  rank  higher  "Monitoring  processes"  followed  by  "scope", 
"verification"  and  "transparency".  In  their  contributions,  they  objected  to  taking  into 
account "Monitoring parameters" and especially "cargo carried". 

MORE DETAILED VIEWS on the different elements were provided through a number 
of questions.  

  On  operational  energy  efficiency  business  decisions  and  political  decision 

making”/parameters to be monitored and reported 

The  questionnaire  contained  three  statements  and  asked  participants  to  indicate  their 
support for them.  

i) 

“Operational  energy  efficiency  is  relevant  for  business  decisions  and  political 
decision making" 

  Civil society organisations, EU MRV verifiers and other stakeholders groups (in 
particular those working on the policy side) "fully agreed" or "tended to agree" 
with this statement. 

  The  shipping  sector  is  somehow  divided  on  this  issue:  while  industry 
associations  was  more  reticent,  a  relatively  majority  of  ship  owners/managers 
were "fully agreeing" or "tending to agree" with this statement. 
"EU MRV should use "cargo capacity" instead of ‘cargo carried" 

ii) 

  Shipping sector: the majority of the respondents of this group favour this option. 
  Around half of EEA MS/Flag administrations also welcome this idea.  
  MRV  verifiers,  service  providers,  accreditation  bodies,  research  and  academy 
and citizens don’t have a firm stance about this issue, with a relatively share of 
them opting for the “don’t know” option. 

  A majority of civil society organisations fully disagree with this statement.  
iii)  EU MRV should use ‘IMO DCS parameters ‘distance travelled over ground’ and 

‘hours underway’  

  A large majority (84) of respondents across all the stakeholders groups  agreed 
on  the  value  of  taking  into  account  the  IMO  DCS  parameters  of  "distance 
travelled over ground "and "hours underway", instead of 'distance travelled' and 
’time spent at sea". 

  The  shipping  sector  and  Member  States/Flag  administrations  were  especially 
explicit  about  this.  Also  a  majority  of  independent  MRV  verifiers  and  service 
providers were “fully agreeing"/"tending to agree’ with this option. 

  The  rest  of  the  groups  seem  not  to  have  a  clear  position:  civil  society 
organisations  have  a  less  strong  position  that  in  the  case  above  with  half  fully 
agreeing/  tending  to  agree  and  half  in  favour  of  the  “don’t  know”  option.  
Citizens/individuals  are  also  split.  Finally  a  majority  of  national  accreditation 
bodies and ports stakeholders opt for the “don’t know option”.  

45 

 
 
 
 
  On verification  

The  questionnaire  contained  three  statements  and  asked  participants  to  indicate  their 
support for them.  

i) 

On  the  role  of  MRV  verification  in  guaranteeing  data  quality  and  level  playing 
field for ships and companies   

Almost all respondents either fully agreed or tended to agree with the general statement 
that MRV should ensure both quality plus equal level playing field no big differences can 
be signalled in terms of stakeholders' groups.  

ii)  On the benefits of robust and verified data against its costs estimated at 500 euros 

per year 

The shipping sector is the group with the highest level of disagreement on this particular 
statement, but without a unanimous view on the issue. A majority (18 out of 29) of ship 
owners/managers  tend  to  disagree,  whereas  their  professional  associations  seem  not  to 
have a firm opinion or insights into this.  

On  the  other  hand,  MRV  verifiers/RO,  Accreditation  bodies,  citizens/individuals  and 
researchers fully agree/tend to agree, almost unanimously, that the benefits are justified 
by the verification costs.  Also civil society organisations fully agree/tend to agree with 
this  assessment  and  consider  third  party  verification  critical  to  ensure  the  quality  of 
reported  emissions  data  while  it  represents  an  insignificant  additional  operating  cost 
which cannot justify weakening the MRV approach. 

EEA MS/Flag administrations, by a small majority, also support this statement.  

iii)  Who should perform verification under the EU MRV Regulation?  

Stakeholders appear divided in relation to who should perform verification 

  37  respondents  indicated  a  preference  for  EU  Recognised  Organisations  (RO) 

performing verification according to specific rules,  

  33 respondents prefer verification to be performed by independent verifiers,  
  12  opted  for  Port  State  Controls  Officers  carrying  out  in-depth  inspections  for 

MRV shipping according to specified rules, 

  11 participants chose "Other”. 

A small share of the Shipping sector (6) indicated in a clearly coordinated manner that no 
verification EU level was necessary as "only IMO DCS should be in place". 

  Transparency of data collected 

i) 

Is publication of  environmental information on CO2  emissions of  individual  ships 
relevant for the public? 

A  majority  of  stakeholders  groups  considers  that  publication  of  environmental 
information on CO2 emissions of individual ships is relevant for the public. 

  In  particular  civil  society  organisations,  citizens/individuals  and  research  and 
academy,  EU  MRV  verifiers,  National  Accreditation  Bodies  and  service 
providers, EEA MS /Flag administrations fully agree or tend to agree with this 
statement. 

46 

 
 
 
 
 
 
 
  On  the  other  hand,  the  shipping  sector  is  quite  sceptical  in  particular  ship-
owners/managers: 20 of the 29 ship owners / managers fully disagree with this 
statement. Industry associations are less negative: 13 out of 24 fully disagree 

ii)  Does  transparency  of  technical  and  operational  efficiency  of  ships  help  markets' 

actors to take informed decisions? 

A majority of stakeholders (65) "fully agree/tend to agree" with this statement. 

The  shipping  sector  replies  are  the  most  reticent  ones,  while  there  seem  to  be  some 
nuances as industry associations “fully disagree" and "ship owners / managers, "tend to 
disagree"  on  the  usefulness  of  this  information  for  markets  as  they  fear  distortion  of 
competition. 

Other aspects, information, comments or suggestions  

At the end of the questionnaire, stakeholders could identify relevant issues areas/aspects 
or add further information, comments or suggestions.  

Some  suggestions  are  clearly  out  of  the  scope  of  the  OPC:  independent  MRV  verifiers 
willing to be recognised as RO under IMO DCS, a NGOs requesting inclusion of other 
shipping pollutants, including methane and black carbon, under the EU MRV Regulation 
or  those  indicating  that  no  EU  monitoring  reporting  of  EU  related  data  should  be  in 
place. 

The most relevant for the study can be summarised as follows 

EEA  MS/Flag  administrations  submitted  five  position  papers.  A  majority  of  EEA  MS 
supported  the  current  approach  on  "cargo  carried",  "verification"  and  "transparency"  as 
pivotal  aspects.  They  also  supported  that  domestic  shipping  and  in-  ports  emission  are 
kept  under the scope of  the EU MRV. Two other EEA MS prefer a closer approach to 
IMO DCS for some of these elements. 

Civil  society  organisations  indicated  a  preference  for  delaying  any  amendment  of  the 
MRV and leaving both schemes operate in parallel, as this could provide relevant views 
on those elements needing modification. They support the current approach on domestic 
shipping  and  in-port  emissions  and  on  actual  cargo  data  as  critical  to  calculate  ship 
operational  efficiency.  Finally,  they  supported  third  party  verification  to  ensure  the 
quality of reported emissions data and transparency of "per ship" data, as a key element 
to improve efficiency. 

47 

 
 
 
 
 

E-SURVEY 

Stakeholder sample and respondents  

A  total  of  58  survey  responses  (out  of  sample  of  150)  were  received.  The  majority  of 
responses  (34)  came  from  the  shipping  sector  and  particularly  its  professional 
associations Also independent MRV verifiers (7) participated on a large scale. Member 
States (4), NGOS (4) and accreditation bodies (4) participated as well. 

Output and qualitative analysis  

The following conclusions can be stressed: 

Scope, in terms of ship size, and definitions (e.g.: companies, "at berth" versus "at sea") 
were considered important. 
Monitoring  parameters  have  been  considered  essential  to  the  goal  and  intent  of  the 
schemes.  
Technical  adjustments  ensuring  a  common  and  harmonized  approach  would  reduce 
administrative burden related to the coexistence of two schemes.  
Verification  rules  and  processes  were  not  necessarily  a  priority  area,  while  ensuring 
competent verifiers at a reasonable costs was important. 
Accreditation:  using  the  same  process  for  both  schemes  was  considered  somehow 
important.  
Transparency  was  not  deemed  as  important  element  once  alignment  of  the  monitoring 
parameter cargo carried is taken into account. 
Reduction  of  administrative  burden  will  result  from  closer  approaches  in  terms  of 
definitions, monitoring parameters and reporting and verification processes. 

 

“AD HOC” CONTRIBUTIONS  

Four “ad hoc” contributions were received outside the formal consultation context.  

 

 

 

Two  professional  associations  submitted  identical  responses  indicating  that 
collecting a separate set of data under an EU system was unnecessary; 
Another  professional  association  of  ships  carrying  out  activities  currently 
excluded  supports  maintaining  the  current  scope  for  the  EU  MRV  for  a 
transitional period; 
 One consortium of regional and local authorities praised the objectives of the 
MRV shipping in its current design.  

48 

 
 
 
 
 
 
 
 
ANNEX 3: WHO IS AFFECTED 

Who is affected? 

How are they affected? 

The shipping industry  

(high interest). 

Other  actors  of  the  shipping 
(as  cargo  owners, 
sector 
logistics 
and 
ports) (high interest) 

companies 

EEA Member States: 

Third countries flag States  

International organisations  

Regional 
authorities 

and 

local 

(moderate interest). 

National accreditation bodies  

(high interest). 

Ship-owners as well as other parties having assumed 
the  responsibility  for  the  operation  of  the  ship  and 
their  European  are  to  monitor  and  report  on  a  ship 
basis  both  the  EU-  MRV  shipping  and  the  global 
IMO  DCS.  Companies  need  to  collect  and  report 
data  for  each  of  the  ships  they  operate  calling  at 
European  Economic  Area  (EEA)  ports  since  1st 
January.  From  2019  onwards,  a  largely  similar 
sample  of  ships  (EU  flagged  and  Non  EU  flagged) 
will  be  requested  to  report  on  their  global  activities 
to  their  Flag  Administration  pursuant  to  IMO  DCS 
and on their EEA related voyages to the Commission 
pursuant to MRV (via THETIS MRV)  

Reducing  and  compensating  their  carbon  footprint 
and  stimulating  energy  efficiency 
in  maritime 
transport is part of these actor's priorities. 

EU  ports  have  an  interest  in  having  CO2  emissions 
monitored, collected and published. 

MSs  have  a  continuous  interest  in  receiving  their 
ships'  verified  annual  report  for  their  EEA  voyages 
as this will facilitate MS' verification and collection 
tasks  under  IMO  DCS.  MS  will  ultimately  be 
responsible  for  enforcement  under  both  schemes 
(either as flag States as a port States). 

EEA MS acting as flag States will have a major role 
for their own ships under IMO DCS, which entails a 
considerable administrative burden. 

are involved in the implementation of IMO DCS and 
will receive EU related data from their ships. 

dealing  with  transport  and  climate  change  e.g 
International  Maritime  Organisation  (IMO),  the  UN 
Framework  Convention  on  Climate  Change 
(UNFCCC)  and  various  United  Nations  bodies, 
World  Bank,  Organisation  for  Economic  Co-
operation  and  Development,  International  Energy 
Agency, etc, have a moderate interest.  

from 

Especially 
cities  whose 
communications rely on maritime transport services, 
may also be interested. 

regions 

and 

affected 

as 
Are 
accreditation under the MRV shipping  

responsible 

for  providing 

49 

 
 
 
 
 
 
 
Civil society groups 

(high interest). 

(robust 

Technology  providers  and 
innovators  such  as  ships 
producer 
fuel 
consumption and emission data 
should 
the 
designing  of  more  efficient 
ships),  marine 
equipment 
companies and research bodies  

incentivize 

Citizens/General Public 

(medium interest). 

Those  actors  addressing  the  environmental  impact 
from  maritime  transport  e.g.  academia,  think  tanks, 
Environmental  NGOs,  shipping  emission  players 
(developers of projects related to CO2 emissions and 
energy  efficiency  for  shipping)  are  interested  in 
climate change being addressed across the economy, 
and in data from MRV. 

These dealing with the development and provision of 
marine equipment are indirectly affected to an extent 
as they provide means to reduce emissions, increase 
efficiency  and  support  the  monitoring  of  emissions 
from ships 

They have an interest in action being taken to tackle 
climate change across the economy, with all sectors 
contributing,  as  well  as  measures  for  collecting 
robust  data  on  maritime  CO2  emissions  and  other 
relevant  information,  as  these  affect  their  quality  of 
life and that of future generations.  

On  the  other  hand,  having  robust  information  on 
maritime  transport  emissions  concerns  citizens  as 
customers  of  maritime 
transport  services  and 
consumers of goods transported by ships. 

50 

 
 
 
 
 
 
 
Overview of administrative burden 

MRV activities 

Administrative  burden  – 
Baseline scenario 

Administrative  burden  – 
Preferred option (Option 2) 

Verification activities 

The  preferred  option  would 
keep  the  verification  costs  at 
their  current  relatively  low 
level. 

Verification  costs 
turned 
out to be significantly lower 
than  estimated  in  the  2013 
impact  assessment  (€4500 
per  vessel  per  year  for 
verification 
outsourcing 
all 
and 
activities 
corresponding  processes). 
According 
industry 
to 
sources, albeit the estimates 
vary,  verification  costs  are 
in 
the  order  of  below 
€1000. 

In  the  preferred  option,  the 
proposed  revised  definitions, 
monitoring  parameters,  plans 
and  templates  would  reduce 
administrative 
burdens. 
However,  the  actual  savings 
would  depend  on  the  MRV 
system 
each 
installed 
company  and  the  nature  of 
their  fleet.  In  addition,  these 
savings  would  apply  to  the 
current  monitoring 
and 
reporting costs, which are low 
in 
other 
operational costs (of 0.28%). 

comparison 

to 

in 

Monitoring and Reporting 
activities 

the 

2013 

impact 
In 
assessment, 
the 
administrative burden of the 
EU  MRV  was  estimated  at 
€26.1  million  per  year  for 
11400  ships  above  5000 
GT.  This  is  in  cases  where 
ship-owners 
ship 
operators do not yet apply a 
similar 
monitoring 
approach. 

and 

to 

the  2013 
According 
impact  assessment, 
these 
additional  costs  represent 
only  an  increase  of  0.28% 
of  the  average  operational 
costs (excluding fuel costs). 

51 

 
 
 
 
 
ANNEX 4: MODELLING 

This  Impact  Assessment  relies  largely  on  the  outcomes  of  the  one  carried  out  in  2013 
(SWD(2013) 237 final) accompanying the EU MRV Regulation.  Quantitative impacts of 
the  EU  MRV  as  assessed  in  2013,  are  recalled  in  sections  6  and  7.  It  has  not  been 
considered necessary to update those data by running the model again or carrying out a 
new  analysis,  given  the  short  time  that  has  passed  since  the  EU  MRV  Regulation  was 
adopted, and the fact that its implementation has started recently, not having yet provided 
any data (with reporting obligations only starting in 2019).  

The 2013 impact assessment used a model developed by AEA Technology based on the 
TIMES  model  architecture.  This  model  allowed  an  assessment  of  the  costs  of  the 
different  policy  options  then  considered,  of  the  emissions  abatement  profile  over  time 
and  of  the  cost  effectiveness  (€  per  tonne  CO2  abated)  of  taking  action  on  shipping 
emissions. Additional areas of interest included the extent to which shipping routes may 
change  in  response  to  policy  action,  the  potential  for  modal  shift  as  a  policy  response, 
and  the  extent  of  in-sector  abatement  versus  out-of-sector  abatement.  This  model  was 
built  on  three  building  blocks:  (i)  a  representation  of  shipping  activity,  (ii)  a 
representation of vessels and (iii) cost assumptions. Detailed information on this model 
can be found on Annex VI of SWD(2013) 237 final. 

On this basis, it should be noted that the scenarios that have been assessed in the current 
impact  assessment  are  all  based  on  adjustments  to  the  same  policy  instrument,  the  EU 
MRV.  The  options  that  have  been  considered  mean  adjustments  mostly  of  technical 
nature, but do not alter the nature of the instrument used to address shipping emissions. 
As  a  consequence,  a  refined  quantification  of  impacts  cannot  be  done  through  existing 
tools. Therefore, this impact assessment takes the 2013 data as a point of departure, and 
the additional analysis that has been undertaken is mostly of a qualitative nature. 

52 

 
 
 
 
ANNEX 5: COMPARING THE EU MRV REGULATION AND THE IMO DCS 

The  EU  MRV  Regulation  has  the  objective  of  collecting  CO2  emissions  data  from 
maritime  transport  to  inform  policy-makers’  decisions  on  the  need  and  type  of  further 
action,  if  any.  In  addition,  the  EU  MRV  Regulation  aims  to  encourage  the  uptake  of 
reduction  measures  through  the  publication  of  CO2  emissions  and  energy-efficiency 
related data on a "per ship" basis, providing data on emissions in ports that can facilitate 
their action, and providing a potential basis for future action as set out in the EU's 2013 
Communication.  The  IMO  DCS  has  the  objective  to  collect  data  on  fuel  consumption, 
and with this indirectly addresses CO2 emission data. Besides this, while the two systems 
bear many similarities, some important design differences exist: 

Firstly,  in  terms  of  scope,  the  IMO  DCS  applies  to  all  international  maritime  transport 
activities of ships of 5000GT and above. In contrast, the EU MRV Regulation covers not 
only data from EU-related international voyages but also from domestic (as internal to a 
MS) and emissions within EU ports and from ports from ships above 5000 GT. While the 
EU  MRV  Regulation  only  applies  to  maritime  transport  activities  (carrying  cargo  or 
passengers  or  cargo  for  commercial  purposes),  whereas  the  IMO  DCS  comprises  any 
activity  carried  out  by  ships  operating  in  the  marine  environment.  There  are  also  some 
differences in terms of categories of ships covered as fish catching and processing ships 
are covered by IMO DCS, but not under EU MRV Regulation. 

In addition  to  the divergences in  scope, some of  the parameters to  be monitored differ. 
The EU MRV Regulation includes monitoring and reporting of “actual cargo carried” as 
the basis to calculate average operational energy efficiency "per ship". Instead of "actual 
cargo  carried",  the  IMO  DCS  collects  data  on  the  “cargo  carrying  capacity”. 
Furthermore,  the  two  systems  use  slightly  different  definitions  of  the  parameters 
“distance travelled” and “time spent at sea”/ “hours underway”. 

The definition of company is also a divergent point as the company fulfilling the MRV 
obligations  is  to  be  determined  on  a  case  by  case  basis  by  parties  involved.  Under  the 
IMO  DCS,  its  obligations  go  without  exception  to  the  one  having  assumed  the  SIM 
obligations. 

Allocation  of  monitoring  and  reporting  obligations  in  case  of  change  of  shipping 
companies is also different. Under the EU MRV Regulation shipping, submission of data 
occurs annually by the company responsible on 31st December in the form of an annual 
emissions  report.  Under  IMO  DCS,  reporting  of  aggregated  data  for  segments  shorter 
than  the  calendar  year,  are  possible  in  case  of  change  of  company.  Moreover,  the  EU 
MRV  describes  in  details  the  minimum  procedures  to  be  part  of  the  monitoring  plan 
templates, whereas the IMO DCS only provides for some general directions.  

Furthermore,  the  verification  methods  diverge.  Under  the  EU  MRV  Regulation,  data 
accuracy  is  guaranteed  by  third  party  verification  taking  place  before  submitting  those 
data to the flag State and to the Commission. It uses a similar but simplified verification 
system  as  the  one  applied  under  the  EU’s  Emissions  Trading  System,  based  on 
internationally  agreed  ISO  standards  and  EU  specific  verification  rules.  Verifiers’ 
performance and competencies are supervised by National Accreditation Bodies (NABs) 
in line with usual regulatory practices in the EU. Under IMO DCS flag Administrations 
or  its  RO  are  to  verify,  in  accordance  with  their  national  rules  and  taking  into  account 
IMO guidelines, the data submitted by their ships. 

Finally, as regards the publication of data and transparency. Similar to other sectors, the 
EU MRV Regulation  foresees public access  to  "per ship" annually  aggregated reported 

53 

 
 
data on CO2 emissions and average energy efficiency. It will thus provide information to 
stakeholders  and  the  general  public  on  CO2  emissions  from  EU  related  maritime 
transport  activities  and  create  incentives  for  more  efficient  ships  in  the  market.  In 
contrast,  datasets  under  IMO  DCS  will  be  anonymized  such  that  identification  of 
individual ships is not possible. Also, only IMO Member States will have access to this 
data  and  no  publication  via  the  IMO  DCS  is  foreseen.  While  this  will  enable  IMO  to 
analyse global data on the GHG emissions from international maritime activities so as to 
inform  further the decision-making measures, if  any, the uptake of emissions  reduction 
measures will not be incentivised in the absence of any peer review.  

The next table provided by EMSA gives an overview of the main differences between the 
two systems, where the figure aims to also indicate the synergies between the systems: 

54 

 
 
 
EU MRV Regulation 

IMO DC System 

Scope 

Ships above 5000 GT 

Voyages  to/from  &  between  EEA 
ports 

Monitoring Plan (MP) 

1 January 2018 

Ships 5000 GT and above 

All International Voyages 

SEEMP 

1 January 2019 

First monitoring period   2018 

2019 

Reporting  responsibility  Company responsible on 31 Dec 

Flag  responsible  for  effective 
period 

Reporting Parameters 

Fuel consumption and CO

2

Fuel consumption (CO

 derived) 

2 

Distance travelled 

Time spent at sea 

Cargo carried 

Distance travelled 

Hours under way 

DWT (deadweight) 

Transport work - Distance × Cargo 

Transport  work 
required) - Distance × DWT 

proxy 

(not 

Verification 

Independent Accredited Verifiers  

Flag Administrations or ROs 

Governance 

European Commission & flag State 

Flag Administrations 

Certification 

Document of Compliance (DoC) 

Statement of Compliance (SoC) 

Transparency 

Distinctive - ship specific database 

Disclosure 

Public 

Anonymous  -  aggregated  ship 
database 

Confidential 
access/analysis) 

(Parties 

55 

 
 
 
 
 
  
 
Explanatory Figure: per voyage (indicated in orange) is not a reporting obligation under the EU MRV Regulation but 
rather a monitoring obligation. Also, the SEEMP (MARPOL) is not reported, but contains energy efficiency parameters 
that  should  be  available  on  a  ship.  Abbreviation:  NT:  net  tonnage;  DWT:  deadweight  tonnage;  GT:  gross  tonnage; 
EEDI: energy efficiency design index; EIV: estimated index value. 

56