IMO 75 Regulatory Updates After a 5 Day Meeting

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The Marine Environmental Protection Committee (MEPC) of the International Maritime Organization  (IMO) met remotely over the week of November 16th to 20th.

Viswa Lab in its latest technical update listed a short summary of the important points covered.

We will be discussing these topics in detail in follow-up technical updates.

We are rushing this to you for your immediate information.

All these valuable updates are based on a recent article published in DNVGL.

The following amendments were adopted. 

MARPOL Annex VI 

Fuel oil sampling and verification: The amendments introduce two new fuel oil samples for the  purpose of confirming compliance with the MARPOL sulphur requirements and the carriage ban for  fuel oil with a sulphur content exceeding 0.50%, namely the “in-use” sample drawn from the fuel oil  system representing the fuel in use, and the “on-board” sample representing fuel intended to be  used and carried in the fuel oil storage tanks.

The EEDI Phase 3

The EEDI Phase 3 starting date will be advanced from 1 January 2025 to 1 April 2022 for container  ships, large gas carriers (>15,000 DWT), general cargo ships, LNG carriers and cruise passenger ships  having non-conventional propulsion.

A stepwise reduction requirement will apply to container  ships, starting with a 30% reduction rate for small container vessels and increasing up to 50% for  very large container ships.

The EEDI reference line for large bulkers above 279,000 DWT will be constant, calculated based on  279,000 DWT, regardless of the actual DWT.

The amendments will enter into force on 1 April 2022.

Ballast Water Management Convention

A commissioning test of the ballast water management system (BWMS) based on  BWM.2/Circ.70/Rev.1 (revised at this session) will be required for the initial survey or when  performing an additional survey for retrofits.

The commissioning test analysis undertaken may be  indicative and will not apply to ships that already have an installed BWMS certified under the  BWMC. Please note that some flag administrations are requiring commissioning testing ahead of  the BWMC amendments entering into force. 

A new tick box for management methods other than D-1, D-2 and D-4 has been added in the  International Ballast Water Management Certificate. This is meant for vessels using alternative  approaches, such as reception facilities (B-3.6-7). 

The amendments will enter into force on 1 June 2022.

Harmful aquatic organisms in ballast water 

The draft revised the BWM circular on “Guidance for the commissioning testing of ballast water  management systems” was approved as BWM.2/Circ.70/Rev.1. The compliance testing is intended  to confirm the correct installation of the equipment as per the amendments to the BWMC adopted  at this session. 

Draft amendments to the “Guidance on ballast water sampling and analysis for trial use” in  accordance with the BWM Convention and Guidelines (G2) was approved as BWM.2/Circ.42/Rev.2.  This includes two new indicative methods and a reference to the detail method of MPN Dilution

Air pollution and energy efficiency  

No further exemption was granted for the Tier III NOx emissions regulations for large yachts with a  loadline greater than 24 metres in length and less than 500 GT, meaning that the Tier III NOx  emission levels will be applicable for such yachts with keel laid after 1 January 2021. 

Most items under this agenda item were postponed to MEPC 76 including adoption of the revised  Guidelines for Exhaust Gas Cleaning Systems (resolution MEPC.259(68)). A Correspondence Group  was established to work further on items that were not discussed at MEPC 75. 

Reduction of GHG emissions  

Draft amendments to MARPOL Annex VI were approved, introducing new regulations to reduce  GHG emissions from ships. These are the Energy Efficiency Existing Ship Index (EEXI), operational  Carbon Intensity Indicator (CII), which includes a rating scheme (A to E), and an enhanced SEEMP  with mandatory content, approval and subsequent audits.

Energy Efficiency Design Index (EEDI)

The EEXI will impose a requirement equivalent to Energy Efficiency Design Index (EEDI) Phase 2 or 3  (with some adjustments) to all existing ships regardless of the year of build and is intended as a  one-off certification. The EEXI is to be verified and a new Energy Efficiency Certificate issued no  later than the first annual International Air Pollution Prevention (IAPP) survey on or after 1 January  2023. 

Calculation of CII

All cargo and cruise ships above 5,000 GT need to calculate a CII (e.g. Annual Efficiency Ratio [AER])  given in grams CO2 per dwt-mile) and will be given an annual rating of A to E. The rating thresholds  will be increasingly stringent towards 2030. For ships that achieve a D rating for three consecutive  years or an E rating in a single year, a corrective action plan needs to be developed as part of the  SEEMP and approved. 

On or before 1 January 2023, all ships above 400 GT need to have an approved SEEMP on board,  and the implementation of the SEEMP will be subject to audits. For ships above 5,000 GT, the  SEEMP also needs to include mandatory content, such as an implementation plan on how to achieve  the CII targets. 

The amendments are expected to be adopted at MEPC 76 in June 2021 with entry into force on 1  January 2023. 

Intersessional working group in May 2021

A Correspondence Group will, together with an intersessional working group in May 2021, finalize  the necessary guidelines supporting the approved regulations, including baselines, methods of  calculations and ship-segment-specific requirements, to be approved at MEPC 76. 

For more information about the regulations and DNV GL services, please visit  our decarbonization and EEXI topic pages

The industry proposal for an International Maritime Research and Development Board (IMRB) saw a  robust discussion; however, the only conclusion was to invite interested parties to comment on this  and related proposals through submissions to MEPC 76. 

Pollution prevention and response

IBC Code 

A Circular giving guidance on replacing the IBC Code certificates following the 2019 amendments of  the IBC Code was approved.

It was also agreed to include a qualifier following the IBC Code product  name for products currently listed in Ch.17 for which the carriage requirements have been revised  in order to apply the new carriage requirements ahead of the next IBC Code amendments. 

A PPR.1 Circular concerning the application of revised carriage requirements for “methyl acrylate”  and “methyl methacrylate” was endorsed.

AFS Convention 

Amendments to the AFS Convention to include controls on cybutryne and an operative paragraph  with respect to issuance of the new International Anti-fouling System Certificate (IAFSC) were  approved. 

This implies a ban to apply or re-apply anti-fouling systems containing cybutryne from 1 January  2023. All ships should remove or seal such anti-fouling systems no later than 60 months following  the last application of such anti-fouling system prior to 1 January 2023, except fixed and floating  platforms, FSUs and FPSOs constructed prior to 1 January 2023 and not dry-docked on or after that  date; ships not engaged in international voyages; and ships of less than 400 GT engaged in  international voyages, if accepted by the coastal state. 

The amendments are expected to be adopted at MEPC 76 in June 2021 with entry into force on 1  January 2023. 

Ban on carriage of HFO as fuel in Arctic

Amendments to MARPOL Annex I, Reg. 43A, prohibiting the use and carriage of HFO as fuel in the  Arctic from 1 July 2024 were approved. For vessels complying with Reg. 12A, fuel oil tank protection  (e.g. double hull), the proposed entry into force date is 1 July 2029. There is also an option for  states with an Arctic coastline to waive the requirement for ships flying its flag and operating in its  water until 1 July 2029. 

The amendments are expected to be adopted at MEPC 76 in June 2021 with entry into force on 1  July 2024. 

Implementation of IMO instruments 

Amendments to MARPOL Annexes I, IV and VI were approved, exempting unmanned non-self propelled (UNSP) barges from survey and certification requirements. 

The amendments are expected to be adopted at MEPC 76 in June 2021 with entry into force on 1  January 2023. 

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Source: Viswa Lab