Regulations on environmental safety for ships and floating installations have been amended, and MARPOL Annex VI has been updated and expanded with requirements for the preparation of an Energy Efficiency eXisting ships Index (EEXI) and Carbon Intensity Index (CII).
The Energy Efficiency Design Index (EEDI) and the Ship Energy Efficiency Management Plan (SEEMP) became mandatory from 1 January 2013.
In 2018, the UN shipping organization IMO adopted ambitions for a 40 percent reduction in greenhouse gas (GHG) emissions from 2030 and at least 50 percent by 2050. Longer-term measures are still being discussed in the IMO. The same is true if the goal should be at least a 50 per cent reduction in emissions from shipping by 2050, or if the ambition should be faster cuts towards zero emissions.
To reach the targets, the IMO countries agreed in 2021 on some technical and operational measures that apply from 1 November 2022, for all ships. This means that from 1 January 2023, all ships must calculate their energy efficiency index (EEXI). Then the ships must also collect and report annual carbon intensity (CII), which from 2024 gives a grade A-E. In addition, shipping companies must submit plans (SEEMP) for how energy efficiency will gradually improve in line with stricter requirements for each ship.
See IMO's GHG strategy plan here.
Which ships do the EEDI, EEXI, CII and SEEMP regulations apply to?
The regulation on carbon intensity for international shipping in Chapter 4 of MARPOL Annex VI applies to all ships of 400 gross tonnes and over. In any case, the provisions in chapter 4 do not apply to ships that operate exclusively within waters that are subject to the sovereignty or jurisdiction of the ship's flag state and ships that do not have mechanical means of propulsion, as well as platforms including floating production, storage, and offloading units (FPSO’s) and floating storage units (FSO’s) and drilling platforms, regardless of means of propulsion.
EEXI and CII are among the short-term measures that have been introduced.
The EEXI targets for energy efficient ship design apply to all existing ships over 400 GT (gross tonnage), while the CII and the CII scale from A-E will apply to all vessels over 5000 GT (gross tonnage).
The changes in MARPOL Annex VI apply from 1 November 2022. The requirements for EEXI and CII certification apply from 1 January 2023, with the first annual reporting for the year 2023, with an initial CII rating given in 2024 based on these figures.
From 1 January 2023, it is mandatory for all ships to calculate their achieved energy efficiency index for existing ships (EEXI) to measure their energy efficiency and start the collection of data for reporting their annual operational carbon intensity indicator (CII) and CII assessment and rating (A-E).
Verification that the ship's achieved EEXI and technical file are in accordance with the requirements must take place at the first annual, intermediate or renewal survey after 1 January 2023. The survey is part of the scope of the IAPP survey, and compliance is documented by issuing the IEE - the certificate.
The Carbon Intensity Index (CII) is intended to reward ships that in operation have low emissions on a scale from A-E, while EEXI goes for more technical requirements. The CII scale is calculated from reported fuel consumption via IMO's Data Collection System (DCS). The ships are graded from A-E where A is the best, C is a minimum rating and D and E are poor. If a ship receives the grade D three years in a row or E one year, the shipping company must submit a plan for how the ship will reach an acceptable level. The CII rating must be included in the ship's energy efficiency plan (SEEMP).
CII is basically based on fuel consumption measured per tonne/nautical mile and dead weight (load capacity). The calculations must take into account what the ship is actually carrying, whether it is light materials or heavy cargo. The point is to avoid that going with a light load or in ballast gives points.
The shipping companies must draw up a plan (SEEMP) that shows how the ships will achieve ever lower emissions in the short term or come in line with the requirements.
Energy Efficiency Design Index (EEDI)
All new ships (that is, ships with a construction contract signed on 1 January 2013, or later) that fall under specific ship categories (that is: bulk carriers, gas tankers, tankers, container ships, general cargo ships, reefer ships, combination ships, passenger ships, ro-ro cargo ships and ro-ro passenger ship) must calculate its achieved EEDI (Energy Efficiency Design Index). The calculation of the index must be done as described in guidelines issued by the IMO.
All new ships that fall under certain ship categories and are above a certain size must have an EEDI that is equal to or lower than a ship-specific reference value given in a table in chapter 4. The requirements to have an index value lower than the reference value will gradually become stricter. The requirements are given in table 1 in MARPOL Annex VI Chapter 4.
EEDI for new ships is the most important technical measure and aims to promote the use of more energy efficient (less polluting) equipment and engines. EEDI requires a minimum level of energy efficiency per capacity mile (e.g., tonne mile) for different ship types and size segments. From 1 January 2013, new ship designs must meet the reference level for their ship type and the level is gradually tightened every five years from 2015 onwards.
It is expected that EEDI will stimulate continued innovation and technical development of all components that affect the fuel efficiency of a ship right from the design stage. EEDI leaves the choice of technologies to be used in a specific ship design to the industry. As long as the required level of energy efficiency is achieved, the ship designers and builders are free to use the most cost-effective solutions for the ship to comply with the regulations.
EEDI gives a specific figure for an individual ship design, expressed in grams of carbon dioxide (CO2) per ship's capacity mile (the smaller the EEDI, the more energy efficient ship design) and is calculated with a formula based on the technical design parameters for the ship. The CO2 reduction level (grams of CO2 per tonne-mile) for the first phase is set at 10% and will be tightened every five years to keep pace with the technological development of new efficiency and reduction measures.
EEDI has been developed for the largest and most energy-intensive segments of the world's merchant fleet and will cover 72% of the emissions from new ships covering the following ship types: oil tankers, bulk carriers, gas carriers, general cargo, container ships, refrigerated cargo and combination ships. For ship types not covered by the current formula, suitable formulas are expected to be developed in the future that address the largest emissions first.
Ship's Energy Efficiency Management Plan (SEEMP), Energy Efficiency Operational Indicator (CII) and Energy Efficiency Operational Indicator (EEOI)
All ships over 400 GT must have a ship-specific energy efficiency plan (SEEMP) on board (also ships without an IEE certificate). This must be included as part of the ship's safety management system (SMS). From 1 January 2023, the SEEMP must be verified by survey on board ships of 5000 GT and above to document their plans to meet their CII targets. Ships in international traffic must have an international energy efficiency certificate (IEE) based on EEDI and SEEMP.
SEEMP is an operational measure that establishes a mechanism to improve the energy efficiency of a ship in a cost-effective manner. SEEMP also provides an approach for shipping companies to manage ship and fleet efficiency performance over time using, for example, EEOI as a monitoring tool. The guidance for the development of SEEMP for new and existing ships contains best practice for fuel-efficient ship operation, as well as guidelines for the voluntary use of EEOI for new and existing ships (MEPC.1/Circ.684).
EEOI enables operators to measure the fuel efficiency of a ship in operation and to measure the effect of any changes in operation, e.g., improved travel planning or more frequent propeller cleaning, or the introduction of technical measures such as waste heat recovery systems or new propellers. SEEMP encourages the ship owner and operator at every stage of the plan to consider new technologies and practices when trying to optimize the performance of a ship.
SEEMP consists of three parts:
Guidance for Part I of the SEEMP required by regulation 26.1 of MARPOL Annex VI is dealt with in sections 3, 4 and 5 of the IMO SEEMP guidelines. The purpose of this section is to provide an approach to monitor ship and fleet efficiency performance over time and describe ways to improve ship energy efficiency and carbon intensity. Part I of the SEEMP applies to all ships of 400 GT and above, including ships in domestic traffic in Norway.
Guidance for Part II of the SEEMP required by regulation 26.2 of MARPOL Annex VI is dealt with in sections 6, 7 and 8 of the IMO SEEMP guidelines. The purpose of this section is to provide a description of the methods to be used to collect data required in accordance with regulation 27 of MARPOL Annex VI and the processes by which the ship shall use to report data to the ship's administration or any organization duly authorized by it. Part II of the SEEMP applies to any ship of 5,000 GT and above.
Guidance for Part III of the SEEMP as required by rules 26.3 and 28.8 of MARPOL Annex VI is dealt with in sections 9, 10, 11, 12, 13, 14 and 15 of the IMO SEEMP guidelines. The purpose of this section is to provide:
- a description of the method to be used to calculate the ship's achieved annual operational CII as required by regulation 28 of MARPOL Annex VI
- the processes to be used to report this value to the ship's Administration or any organization duly authorized by it
- the required annual operational CII for the next three years
- an implementation plan documenting how the required annual operation CII should be achieved over the next three years
- a procedure for self-evaluation and improvement; and MEPC 78/17/Add.1 Annex 8, page 6 I:\MEPC\78\MEPC 78-17-Add.1.docx
- for ships classified as D for three consecutive years or classified as E, a corrective action plan to achieve the required annual operational CII.
Part III of the SEEMP applies to any ship of 5000 GT and above that falls into one or more of the categories in regulations 2.2.5, 2.2.7, 2.2.9, 2.2.11, 2.2.14 to 2.2.16, 2.2. 22, and 2.2.26 to 2.2.29 in MARPOL Annex VI.
DCS and Statement of Compliance (DCS SoC)
The Monitoring, Reporting and Verification (MRV) system for the EU and the UK and the Data Collection System (DCS) for the IMO are mandatory and the first step in a larger process to collect and analyse ship emissions data. As a data collection system, DCS collects data, including correction factors and voyage adjustments, for individual ships in a fleet.
The ship shall, within three months after the end of each calendar year, report to its administration or an organization duly authorized by it, the aggregated value for each data set out in Appendix IX to this Annex, via electronic communication and in a standardized format which must be prepared by the organization. After verification of supplied data and obtained annual operational CII values, issue a statement of compliance to the ship. Ships which have been rated as Class D for three consecutive years or rated as Class E in accordance with regulation 28 shall not be issued with a Statement of Compliance unless a corrective action plan has been properly developed and reflected in the SEEMP and verified by a recognised organization with proper authorization from this (RO).
Starting in 2024, the CII must be calculated based on the DCS data from the previous year and then reported to the DCS to be verified with the aggregated DCS data. The achieved CII and environmental assessment (A to E) will then be noted on the DCS Statement of Compliance (DCS SoC). The statement of compliance that is issued must be valid in the calendar year in which it was issued, in the following calendar year and in the first five months of the following calendar year. All statement of compliance must be kept on board for at least five years.
IMO's list of resolutions and guidelines related to energy efficiency can be found here: