Business

Gard: Be prepared to document carbon emissions during PSC inspections

While Europe is reviewing to streamline MRV regulations with the IMO DCS, it is advised for ship operators to be aware of the differences between the two systems.

Published

6 years ago

July 1, 2020

Admin

Norweigian maritime insurance company Gard on Tuesday (30 June) published a case study to highlight differences between the IMO DCS and EU MRV to the shipping community to help avoid any unnecessary breaches in regulation:

By 30 June 2020, ships that used EU ports in 2019 must carry onboard a document certifying that they have fulfilled their obligations under the EU regulation for monitoring, reporting and verification of CO2 emissions for the 2019 reporting period. The comparable deadline under the global IMO data collection system was 31 May 2020.

In February 2020, a Member’s vessel was detained in a European port due to a breach of Regulation (EU) 2015/757 on the monitoring, reporting and verification of carbon dioxide (CO2) emissions from maritime transport (EU MRV). According to the attending port state control officer, “the ship did not show evidence of compliance with the EU MRV regulation for the 2018 reporting period”. While the vessel carried onboard a statement of compliance certifying that its monitoring plan was in compliance with the EU MRV regulation, the master was not able to demonstrate that the plan had been properly implemented during the 2018 reporting period, i.e., he could not provide evidence of having submitted the emissions report to relevant stakeholders or a valid document of compliance as required under Article 18 of the regulation. The vessel was eventually permitted to leave port but only after depositing a security amount of EUR 15,000.

The EU MRV regulation – a recap

The EU system for monitoring, reporting and verification of CO2 emissions from maritime transport requires ships above 5,000 gross tonnes calling at ports in the European Economic Area (EEA) to track and report key information about CO2 emissions, fuel consumption and other relevant information per voyage and on an annual basis, starting in 2018. Voyages that take place within the EEA are also covered, as are emissions occurring when the ship is securely moored or anchored at a port (at berth) whilst loading, unloading or hoteling. Any operation other than transportation of cargo or passengers for commercial purposes is excluded from the regulation.

When the data produced by this ongoing monitoring activity have been reported to and successfully checked by an independent accredited verifier, a document of compliance (DoC) will be issued which confirms a ship’s compliance for a specific reporting period. A valid DoC has to be available for inspection onboard no later than 30 June of the year following the end of a reporting period.

International action

At the international level, the Paris Agreement emphasises the need to peak global greenhouse gas (GHG) emissions as soon as possible and emphasises the need to reduce such emissions in all sectors of the economy, including aviation and shipping. The IMO is committed to contribute to the global efforts to address climate change and one of its measures is the amendments to MARPOL Annex VI on the data collection system for fuel oil consumption of ships (IMO DCS), starting in 2019.

Like the EU MRV, adherence to the IMO DCS is mandatory and applies to ships above 5,000 gross tonnes. The IMO DCS also requires ships to carry onboard a document confirming compliance with the monitoring and reporting requirements. MARPOL Annex VI Reg.6.6 requires the flag administration or RO to issue a statement of compliance (SoC) related to fuel oil consumption no later than five months from the beginning of the calendar year – which means that an SoC must be available for inspection onboard no later than 31 May of the year following the end of a reporting period.

However, while the two systems have the same general objective, there are important differences:

The IMO DCS comprises any activity carried out by ships in the marine environment, while the EU MRV covers only transport of goods and persons.
The IMO DCS applies to all international voyages, while the EU MRV applies only to voyages to and from EEA ports, including domestic voyages.
Emissions in EEA ports are reported separately in the EU MRV system.The IMO DCS requires annual aggregated data, while the EU MRV uses data per voyage.
The IMO DCS requires data on the deadweight tonnage (the carrying capacity of the ship), while the EU MRV requires data related to transport work (weight of actual cargo carried or number of passengers).
The IMO DCS requires publication of aggregated data, while the EU publishes data on the performance of individual ships.
DNVGL’s website “EU MRV and IMO DCS” provides a good overview of the two monitoring systems and further details the differences between them.

EU and IMO systems to align

The good news is that the European Commission (EC) is currently reviewing the MRV regulation with a view to, as far as practicable, streamline the two systems. A proposal tabled in the EC in February 2019 suggests aligning important definitions used in the EU regulation with those of the IMO DCS. It also proposes to use some of the monitoring and reporting requirements of the IMO DCS, e.g. to replace ‘cargo carried’ with the ‘deadweight tonnage’ and to calculate ‘distance travelled’ using the IMO guidelines as basis. However, key aspects of the EU MRV regulations, such as its scope, verification requirements and publication of individual ships’ data of CO2 emissions and energy efficiency, would be maintained. The European Parliament’s briefing of 4 October 2019 further explains the changes the proposal would bring.

Recommendations

While the shipping sectors’ focus on air pollution prevention measures is likely to be secondary to more urgent matters associated with the ongoing pandemic, we encourage ship operators to ensure that all their eligible ships carry onboard a valid SoC confirming compliance with the IMO DCS for the 2019 reporting period (deadline was 31 May 2020). No later than 30 June 2020, ships that used EEA ports in 2019 must also carry a valid DoC certifying that they have fulfilled their obligations under the EU MRV regulation.

Ships that have historically never visited an EU port and therefore do not have an approved monitoring plan or a DoC are still allowed to trade in the EU, but will need to prepare a monitoring plan within two months of their first visit and will need to submit a report of this voyage for the reporting period.

If copies of the SoC and DoC are not available onboard, the ship is not in compliance with the legislation and is thus liable for fines, or even detention, as determined by each port authority.

Source: Gard
Photo credit: shaah shahidh
Published: 1 July, 2020

Legal

Singapore police arrest eight over alleged illegal MGO transaction off Tuas

SPF says preliminary investigations found that crew members of a Singapore-registered tugboat misappropriated MGO worth about SGD 10,570 without their company’s knowledge and sold it illegally.

Published

9 hours ago

August 14, 2026

Admin

Singapore police arrest eight over alleged illegal MGO transaction off Tuas

The Singapore Police Force (SPF) on Thursday (13 August) said it has arrested eight men, aged between 25 and 54, for their suspected involvement in an illegal transaction of Marine Gas Oil (MGO).

On 13 August 2026 at about 1.05am, officers from the Police Coast Guard (PCG) conducted a check on a Singapore-registered tugboat in the waters off Tuas and discovered that eight crew members were possibly involved in the illegal transaction of MGO.

“Preliminary investigations revealed that the crew members of the tugboats misappropriated MGO valued at about SGD 10,570 (USD 8,258), without their company’s knowledge,” SPF said in a statement.

“The MGO was sold illegally for their personal financial gain.”

The eight crew members will be charged in court on 14 August 2026 with the offence of theft by servant of property in possession of master under Section 381 of the Penal Code 1871 If convicted, they shall be punished with an imprisonment term that may extend to seven years and shall also be liable to fine.

“The Police take a serious view of illegal transaction of MGO in Singapore Territorial Waters and will continue to conduct enforcement and security checks to prevent, deter and detect such illicit activities in Singapore waters,” SPF added.

Photo credit: Singapore Police Force
Published: 14 August, 2026

Port & Regulatory

Gard: Sulphur-related bunker claims rise amid tighter China MSA enforcement

Claims involving excessive sulphur content in marine fuels have been rising, while stricter inspections by the China MSA have heightened the focus on sulphur compliance, particularly in the Bohai Sea.

Published

9 hours ago

August 14, 2026

Admin

Maritime protection and indemnity (P&I) club Gard on Wednesday (12 August) highlighted that claims involving excessive sulphur content in marine fuels have been rising, while stricter inspections by the China MSA have heightened the focus on sulphur compliance, particularly in the Bohai Sea:

Rise in off-spec sulphur claims

Recent claims experience indicates that bunker quality continues to pose a significant operational risk for shipowners. In our earlier review of bunker-related claims during the first five months of 2026, we highlighted a rise in off-specification bunker incidents amid increased pressure on global fuel supply chains following the escalation of the conflict in the Middle East.

Specifically for Sulphur compliance, between January and June 2026, the number of sulphur-related cases increased by more than threefold compared with the same period in 2025. Notably, the number of cases recorded in the first six months of this year has already exceeded the total number reported during the whole of last year by approximately 40%.

While each case is fact-specific, the increase is notable because excessive sulphur content constitutes a MARPOL compliance issue. Unlike many other bunker quality problems, sulphur non-compliance identified through port state inspections can result in vessel delays, enforcement action, and substantial costs associated with debunkering and fuel disposal.

The map below illustrates the geographical distribution of sulphur-related claims recorded during the first six months of 2026, based on the location where the bunkers were stemmed.

Distribution of sulphur related claims

China MSA steps up sulphur compliance enforcement

According to our correspondent, Huatai, on 5 June 2026, the maritime authorities of Tianjin, Hebei, Liaoning and Shandong jointly launched a special campaign on ship pollution prevention and control in the Bohai Sea region. The campaign involves coordinated supervision by local MSA branches across the region and is expected to last nearly five months. It covers major ports and surrounding port areas in the Bohai Sea region, including Tianjin, Tangshan, Qinhuangdao, Huanghua, Jinzhou, Yingkou and Longkou.

While the initiative is broader than bunker sulphur compliance alone, its scope includes inspections relating to air pollution prevention, SOx emissions, fuel compliance and other high-pollution-risk operations. Enforcement measures are expected to comprise onboard inspections, cross-regional enforcement activities, unannounced spot checks and remote monitoring. These efforts will be supported by a combination of UAV patrols, maritime patrol vessels, shore-based monitoring systems and rapid on-site fuel testing.

As a result, vessels trading in the Bohai Sea region may experience increased scrutiny of fuel compliance documentation, fuel sampling records, onboard fuel management procedures, and the handling or disposal of suspected non-compliant fuel.

Documents typically requested by China MSA

Based on our recent experience, including the case discussed above, and subject to the specific requirements of the local MSA office, owners and operators may be requested to provide supporting documentation such as:

Bunker documentation – Bunker Delivery Notes (BDNs), MARPOL fuel sample records, fuel test reports, and relevant fuel quality certificates.
Statutory certificates – including the International Air Pollution Prevention (IAPP) Certificate and International Oil Pollution Prevention (IOPP) Certificate.
Operational records – engine logbooks, deck and navigation logbooks, Oil Record Book entries, and records relating to fuel transfers, storage and consumption.
Sampling documentation – the Master’s statement and any records demonstrating how fuel samples were drawn, sealed, labelled, handled and retained.
Correspondence records – communications with the authorities, bunker suppliers, charterers and other relevant stakeholders.
Fuel disposal records – approved disposal plans, debunkering documentation, receipts and evidence of final disposal, where applicable.

The exact documentation required will depend on the nature of the investigation, the findings of the inspection, and the requirements of the local enforcement authority.

Possible regulatory consequences in China

Under the Air Pollution Prevention and Control Law of the People’s Republic of China, ocean-going vessels are required to use fuel oil meeting atmospheric pollutant control requirements after berthing. Vessels operating within designated emission control areas must also comply with applicable emission standards. Article 106 provides that where vessel fuel oil fails to meet applicable standards or requirements, the competent maritime authorities may impose fines ranging from RMB 10,000 to RMB 100,000. Liability may extend to shipowners, ship operators and ship managers depending upon the circumstances of the case.

Recommendation

Sulphur compliance should be treated as both a fuel quality and regulatory risk. Owners and operators are encouraged to take preventive steps before bunkering, act promptly if non-compliant fuel is suspected, and preserve evidence carefully if an inspection or claim arises. Under amended

Resolution A.1206(34), Appendix 18, 2.1.5, if the BDN shows compliant fuel, but the master has independent test results of the fuel oil sample taken by the ship during the bunkering which indicates non-compliance, the master may document this by notifying the ship’s flag Administration, with copies to:

the competent authority of the relevant port of destination,
the Administration under whose jurisdiction the bunker deliverer is located,
and to the bunker deliverer.

Photo credit: shraga kopstein on Unsplash / Gard
Published: 14 August, 2026

LNG Bunkering

Shell expands LNG bunkering footprint in Spain with Valencia

As one of the region’s key maritime hubs, the company said Valencia expands the options available to shipowners seeking LNG supply along major shipping routes.

Published

9 hours ago

August 14, 2026

Admin

Shell expands LNG bunkering footprint in Spain with Valencia

British oil giant Shell on Thursday (13 August) said Valencia has joined its growing network of bunkering locations, making LNG available as a marine fuel.

The successful completion of the first LNG bunkering operation in Valencia marked an important milestone for Spain and further strengthened Shell’s LNG supply capabilities across the Mediterranean.

In a video shared by the company, bunkering vessel Alice Consulich was shown supplying an undisclosed volume of LNG to the container ship MSC Sabrina.

“As one of the region’s key maritime hubs, Valencia expands the options available to shipowners seeking LNG supply along major shipping routes,” Shell said in a social media post.

Shell said the achievement reflected the strong collaboration across the maritime value chain, including MSC Mediterranean Shipping Company, the Port of Valencia and Fratelli Cosulich Group.

“We look forward to making more LNG bunker deliveries in Valencia and across the Mediterranean as LNG infrastructure and capabilities continue to expand,” the company said.

Photo credit: Shell
Published: 14 August, 2026