The International Maritime Organization (IMO) has introduced significant amendments to MARPOL Annex VI, specifically regarding the Data Collection System (DCS) for fuel oil reporting and the Ship Energy Efficiency Management Plan (SEEMP) Guidelines. These changes aim to enhance the granularity and accuracy of fuel consumption data, thereby contributing to improved monitoring and a reduction in greenhouse gas emissions from ships.
Applicability and Implementation Timeline
The amendments to Appendix IX of MARPOL Annex VI, mandating increased granularity in DCS fuel oil reporting, were adopted at MEPC 81. Concurrently, the SEEMP Guidelines (Resolution MEPC.395(82)) were revised to support these MARPOL amendments.
The new requirements will take effect for most ships from January 1, 2026. However, for newbuilds delivered on or after August 1, 2025, the requirements will apply immediately from their delivery date.
To ensure compliance, a revised and approved SEEMP Part II, along with a new Confirmation of Compliance (CoC) confirming adherence to the 2024 SEEMP Guidelines, must be onboard each vessel by January 1, 2026. It’s clarified by MEPC.1/Circ.913 that for administrations implementing the amendments on the August 1, 2025, entry-into-force date, existing ships will continue collecting data with the current level of granularity throughout 2025, transitioning to the enhanced level from January 1, 2026.
Enhanced Granularity in Fuel Consumption Reporting
The core of the amendments is the requirement for vessels to report fuel consumption with greater detail:
- Split by Consumer Groups: Fuel consumption must now be reported separately for defined consumer groups, as outlined in the SEEMP Part II. While many operators have already implemented this practice as part of the OVD standard, it will now become mandatory for all vessels.
- Defined consumer groups include:
- Main engine (ME)
- Auxiliary engine (AE)
- Boiler
- Others (Insignificant consumption, e.g., from incinerators, may be merged with another consumer group if appropriate).
- Defined consumer groups include:
- “Underway” vs. “Not Underway” Reporting: Fuel consumption must be distinctly divided into “Underway” and “Not underway” legs of the route.
Prior to collecting data at this enhanced granularity level, each ship is required to revise its SEEMP Part II, taking into account the 2024 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) (Resolution MEPC.395(82)).
Revised Definition of “Underway” and Reporting Implications
At MEPC 83, amendments were adopted to the definition of “underway,” necessitating the reporting of BOSP (Begin of Sea Passage) and EOSP (End of Sea Passage) events. DNV interprets BOSP as the point at which transit speed is reached, and EOSP as the start of deceleration from transit speed.
Key implications of this revised definition include:
- Event-Based Reporting for Deviations: The start of operations such as anchoring, ship-to-ship (STS) transfers, and canal passages that require a deviation from transit speed must be indicated with an EOSP event. Resuming the voyage after such an operation must be indicated with a BOSP event.
- Berth-to-Berth Methodology: For short voyages where a distinct sea passage cannot be easily distinguished in reporting, the berth-to-berth methodology will apply.
- Deprecation of Noon-Events-Only Reporting: The previous practice of reporting only noon events will be deprecated. Berth-to-berth reporting will now be required for all vessels, ensuring more continuous and precise data collection.
- Exact Event Names: To indicate the start or end of the underway period, vessels must use specific event names (in their exact spelling):
- BOSP / BeginOfSeaPassage
- FAOP / FullAheadOnPassage
- EOSP / EndOfSeaPassage
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Source: DNV
