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DNV: Preparing for the EU ETS – next steps

Ship owners and managers should make an agreement on who assumes the responsibilities for the EU MRV and EU ETS and to provide an updated Monitoring Plan to the verifiers, says DNV.

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Classification society DNV on Friday (17 November) released a statutory news for cargo and passenger ships above 5,000 GT sailing in the EU on the upcoming Emission Trading System:

Background

The EU amended the Emission Trading System (EU ETS) Directive to include shipping from 1 January 2024. The monitoring, reporting and verification requirements detailed in the EU MRV regulation have also been revised to support the EU ETS. 

The European Commission (EC) is now in the process of developing implementation and delegation regulations providing more details, and DNV will communicate these in due course. 

This news provides an update on the options for the responsible shipping company, as well as other relevant technical, operational and commercial matters when preparing for ETS. Please make sure to visit our revamped EU ETS topic page with a comprehensive FAQ section providing you with even more clarity and guidance on these critical topics.

Shipping company responsible for the EU ETS and EU MRV

The EC has adopted an implementing regulation detailing which company is responsible for monitoring and reporting greenhouse gas (GHG) emissions and surrendering emission allowances. The default responsible entity is the registered owner, also if the ship is on a bareboat charter. The responsibility can be shifted to the technical manager – i.e. the ISM company – only by an agreement between the registered owner and the ISM company explicitly stating the delegation. 

The company responsible for monitoring and reporting under the MRV regulation must be the same as the company responsible under the ETS directive for surrendering emission allowances. However, the practical aspects related to monitoring and reporting – such as developing a monitoring plan, implementation, and developing emissions reports – can still be performed by technical management companies.

Options for managing the responsibility and practical aspects related to the EU MRV and EU ETS

There are basically three options for managing the responsibility and practical aspects related to the EU MRV and EU ETS: 

1. The registered owner takes on the responsibility for compliance with the MRV and ETS and establishes its own monitoring system

The owner company should provide its Administering Authority (AA – see below) with a list of ships for which it assumes responsibility with the MRV and ETS obligations. The registered owner must establish its own monitoring system, develop a Monitoring Plan, have it assessed by a verifier, and submit it to the AA by 1 April 2024.

2. The registered owner takes on the responsibility for compliance with the MRV and ETS but delegates the practical monitoring to the ISM company 

The owner company provides its AA with a list of ships for which it assumes responsibility with the MRV and ETS obligations. The ISM company can continue with the monitoring and reporting as today, but the Monitoring Plan must be updated referring to the owner as the responsible entity. 

The ISM company will implement the Monitoring Plan and provide the emissions reports for the registered owner. It is still not decided if it will be possible for the ISM company to submit the plans and reports in Thetis MRV on the owner’s behalf. 

3. The registered owner delegates the responsibility for compliance with the MRV and ETS to the ISM manager 

The registered owner company and ISM company must sign a document clearly indicating that the ISM company has been mandated by the shipowner to comply with the MRV and ETS obligations. The ISM company may be mandated by several owner companies, but it remains a single shipping company responsible for the combined fleet under the MRV and ETS. Under this option, the existing Monitoring Plan can be continued, provided it is extended with the required additional elements required by the updated Monitoring Plan template (see below).

Shipowners and ship managers should make an agreement on who assumes the responsibility for the EU MRV and EU ETS, and update any documentation as needed.

Administering Authority (AA)

Each company, whether it is the registered owner or ISM company, will be assigned to an AA of an EU/EEA member state. Companies registered in an EU/EEA country will be assigned to the AA of that country. Companies registered outside the EU/EEA will be assigned to the AA of the country where their ships had the most port calls the last four years. The EC will provide a list of companies and their respective AA by 1 February 2024. 

Each shipping company responsible for one or more ships under ETS needs to apply for a Maritime Operator Holding Account with its AA, within 40 days after the list is published by the EC. The practicalities related to this will vary between different AAs. The AA is then required to open the account within an additional 40 working days.

The documentation requirements for opening an account are common for all AAs and include:

• General info about the legal entity (e.g., name, address, contact person)

• If the company is the registered owner: a list of ships for which the company assumes control 

• If the account holder is part of a group: a document clearly identifying the structure of the group (certified true copy required).

The AA may also ask for a document proving:

• Registration of the legal entity, its bank account details and confirmation of VAT registration

• Name, date of birth and nationality of the legal entity’s beneficial owner, including the type of ownership or control they are exercising

• A copy of the instruments establishing the legal entity

• A copy of the annual report or of the latest audited financial statements, or if no audited financial statements are available, a copy of the financial statements stamped by the tax office or the financial director.

Companies, who know which AA they will be assigned to, should apply for a Maritime Operator Holding Account as soon as possible.

Change of company and partial emissions reports

In case of change of company (i.e., either the registered owner or the ISM company), the MRV regulation requires that a partial emissions report is verified and submitted in the Thetis MRV no later than three months after the change. This ensures that both the previous and the next companies can submit a company level emissions report containing the emissions for which each company was liable for surrendering allowances for under the ETS in the reporting period. The need for a partial emissions report strictly follows from the responsible company, either the registered owner or the ISM company. In case the owner has assumed the responsibility, a change in the ISM company will not trigger the need for a partial emissions report. If the responsibility is delegated to the ISM company and the ship changes owner, it will depend on whether the new owner delegates the responsibility to the same ISM company. If the new owner assumes the responsibility itself, or a new ISM company takes over the responsibility, a partial emissions report is required.

Update of Monitoring Plan

An updated Monitoring Plan assessed to be in conformity by a verifier must be submitted to the AA by 1 April 2024. Regardless of which AA the company is assigned to, the submission of Monitoring Plans and emissions reports is performed through Thetis MRV. 

The Monitoring Plan has been expanded to reflect the additional obligations under the MRV and ETS. The new plan template covers, among other smaller adjustments:

  • Emission factors for CH4 and N2O, in addition to CO2 
  • Procedures related to determining the emission factors for biofuels, RFNBOs (renewable fuels of non-biological origin) and RCFs (recycled carbon fuels)
  • Emission source class and slippage coefficient values for LNG-fuelled ships
  • Detailed information on the shipping company 
  • Information on application of carbon capture and storage technologies
  • Procedures covering data flow activities and risk assessment.

The figure on the following page summarizes the EU MRV/ ETS milestones as discussed in this news.

MRV/ETS requirements timeline

TecReg28 770 tcm8 250048

DNV recommends that companies establish or update their Monitoring Plans and submit them for assessment as soon as possible. Conveniently, the revised MRV Monitoring Plan online form from DNV is now available in Fleet Status on Veracity to support the preparation, with information from the previous plan revision readily available. Validation rules and info boxes will guide you to ensure all updated tables are filled in and the plan is ready to be submitted.

MRV Monitoring Plan >>

Recommendations

Ship owners and managers should make an agreement on who assumes the responsibilities for the EU MRV and EU ETS and to provide an updated Monitoring Plan to the verifiers. For DNV customers, the revised MRV Monitoring Plan online form is available in Fleet Status on Veracity. AAs should be updated on the ships as soon as it is clear which AA each company is assigned to. DNV recommends that companies, who know which AA they will be assigned to, apply for a Maritime Operator Holding Account as soon possible.

AAs should be updated on the ships as soon as it is clear which AA each company is assigned to. DNV recommends that companies, who know which AA they will be assigned to, apply for a Maritime Operator Holding Account as soon possible.

Photo credit: CHUTTERSNAP on Unsplash
Published: 21 November, 2023

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Shipping Corridor

Singapore, LA and Long Beach unveil Partnership Strategy for Pacific Ocean green and digital shipping corridor

Ports and C40 have commissioned a study to analyse trade flows and vessel traffic between the three locations as well as estimate quantity of near-zero/zero-emission bunker fuels required for this traffic.

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Singapore, LA and Long Beach unveils Partnership Strategy for Pacific Ocean green and digital shipping corridor

The Maritime and Port Authority of Singapore (MPA), Port of Los Angeles (POLA) and Port of Long Beach (POLB) on Wednesday (6 December) unveiled a Partnership Strategy for a green and digital shipping corridor (GDSC) across the Pacific Ocean at the 28th United Nations Climate Change Conference.

The release of the Partnership Strategy follows the signing of a memorandum of understanding (MoU) by MPA, POLA and POLB during Singapore Maritime Week in April 2023. The MoU formalised the partnership, which is supported by C40 Cities, with the aim of establishing a GDSC connecting the three global hub ports.

The scope of cooperation through the Partnership Strategy and success indicators specified within build upon the MoU signed in April 2023 and reaffirm the corridor partners’ commitment to drive global action to digitalise and decarbonise the shipping industry and improve efficiencies.

The GDSC Strategy outlines steps to accelerate decarbonisation of the maritime shipping industry by enabling first mover organisations to achieve net-zero greenhouse gas emissions by the earliest feasible date, in support of the goals defined by the 2023 International Maritime Organization’s Strategy on Reduction of GHG Emissions from Ships. The ports and C40 will work together and with value-chain stakeholders from the fuel and maritime sectors to:

● Coordinate decarbonisation efforts: GDSC partners will help to catalyse and coordinate efforts to enable ships calling at the Port of Singapore, Port of Los Angeles and Port of Long Beach to achieve net-zero greenhouse gas emissions by the earliest feasible date. 

● Build consensus on green shipping best practices: GDSC partners will seek to establish consensus around green shipping best practices and standards.

● Improve access to and adoption of technology and digital solutions: To enhance supply chain efficiency, resilience and decarbonisation while reducing costs and improving reliability, GDSC partners will work to develop and deploy innovative technology and digital solutions.

● Leverage networks: GDSC partners will work with stakeholders involved in other green shipping initiatives, including those established by the three ports and other parties, to scale the uptake of zero and near-zero emission technologies, fuels and energy sources.

To achieve these aims, a partnership structure and governance mechanism have been developed to provide clarity on the roles and responsibilities of GDSC partners. The strategy also outlines processes for onboarding new participants, financial management, confidentiality and decision-making.

As next steps, the ports and C40 have commissioned a study to analyse trade flows and vessel traffic between Singapore, Los Angeles and Long Beach. The study will estimate the quantity of near-zero and zero-emission fuels required for this traffic, and guide implementation by identifying opportunities for collaboration to advance the development of the GDSC.

The founding partners will now engage stakeholders from across the shipping and fuel supply value chains that share the GDSC's vision and aims, with the intention of onboarding new corridor participants in 2024. 

Mr Teo Eng Dih, Chief Executive of MPA, said: “We are excited to see this partnership grow from strength to strength with the Green and Digital Shipping Corridor Partnership Strategy. We have embarked on evaluating the various digital solutions and zero and near-zero fuels options that could be trialled along the route between Singapore and the San Pedro Bay Port Complex. We look forward to the support of all the corridor stakeholders over the coming months to conduct trials and potentially scale them for wider adoption.”

"This Partnership Strategy document is the foundation upon which we'll build the future of maritime shipping,” Port of Los Angeles Executive Director Gene Seroka said. “Our success requires the resolve and dedication of the three partnering ports as well as our industry partners. Together, we will model the collaboration necessary to achieve our climate and efficiency goals." 

“Over the last two decades, we've learned that collaboration between maritime industry partners is the key to making meaningful progress in reducing emissions and cleaning the air,”Port of Long Beach CEO Mario Cordero said. “This trans-Pacific green shipping corridor takes this concept global. The strategies we develop here can be used as a roadmap by a larger network of seaports and supply chain companies to invest in programs, technologies, software and infrastructure to decarbonize international trade everywhere.”

C40 Executive Director Mark Watts, said: "C40 is proud to support our port partners in delivering this Partnership Strategy. The advancement of this Green and Digital Shipping Corridor brings the shipping sector one step closer to a 1.5°C-aligned trajectory. Green shipping is only achievable through collaboration because no one stakeholder can afford to move unless they know others are likely to follow. That’s where C40 is delighted to help, bringing our network of world-leading cities, which include most of the world’s largest and most forward-looking ports."

Note: The Partnership Strategy document can be viewed here

Photo credit: Maritime and Port Authority of Singapore
Published: 7 December, 2023

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Biofuel

PIL and DP World embark on biofuel bunkering trials at Jebel Ali Port

Both parties will collaborate on trial shipments between Jebel Ali Port in Dubai and destinations within PIL’s network in near term which will include shipments on PIL’s vessels powered by a biofuel blend.

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PIL and DP World embark on biofuel bunkering trials at Jebel Ali Port

Singapore-based container operator Pacific International Lines (PIL) on Wednesday (6 December) said it signed a Memorandum of Understanding (MOU) with DP World, which handles around 10% of the world’s container trade, to jointly develop green solutions to decarbonise global supply chains.

In the near term, both parties will collaborate on trial shipments between Jebel Ali Port in Dubai and destinations within PIL’s network, with initiatives to reduce the shipments’ GHG footprint. This will include shipments on PIL’s vessels powered by a biofuel blend, biofuel bunkering, and deploying container handling equipment at terminals that run on renewable energy to handle the shipments.

Over the longer term, the companies will explore expanding this partnership to include other ports within DP World’s global network, and using other alternative bunker fuels, such as e-LNG, green methanol or green ammonia in PIL’s vessel operations and bunkering.

It was signed by Mr Lars Kastrup, Chief Executive Officer, PIL and Mr Tiemen Meester, Group Chief Operating Officer, Ports & Terminals, DP World, at the UN Climate Change Conference (COP28) in Dubai, United Arab Emirates (UAE), conveying their commitment to combating climate change and the collective goal of achieving net zero greenhouse gas (GHG) emissions by 2050 or earlier.

Mr Lars Kastrup, Chief Executive Officer, PIL said: “Supply chain resilience and sustainability is the bedrock of global trade growth. With the renewed commitment by the International Maritime Organisation (IMO) this year to take a significant step forward to decarbonise the shipping industry, we at PIL are responding actively to IMO’s call and working to invest in and implement green solutions to achieve our target of achieving net zero by 2050. In this regard, we are pleased to have DP World joining us on our sustainability journey. Capitalising on the combined strengths of our two organisations, we can both augment our sustainability efforts as we co-develop solutions to decarbonise our supply chains.”

Mr Tiemen Meester, Group Chief Operating Officer, Ports & Terminals, DP World, said: “Decarbonisation is the single biggest concern for DP World outside the constraints and the physical movement of goods. So, we are transforming our business and the impact global trade has on the climate. We have already committed to becoming carbon-neutral by 2040 and achieving net-zero carbon emissions by 2050. But we must explore partnerships with companies that share our ambitions and technology to be deployed right now for quicker results.”

Photo credit: DP World
Published: 7 December, 2023

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LNG Bunkering

DNV awards AiP to China Merchants Jinling Shipyard for world’s largest PCTC design

DNV has awarded an Approval in Principle certificate to China Merchants Jinling Shipyard (Nanjing) for its 11,000-CEU capacity LNG-fuelled PCTC design at Marintec China trade fair.

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DNV awards AiP to China Merchants Jinling Shipyard for world’s largest PCTC design

Classification society DNV on Wednesday (6 December) said it has awarded an Approval in Principle (AiP) certificate to China Merchants Jinling Shipyard (Nanjing) Co., Ltd. for its 11,000-CEU capacity LNG-fuelled pure car and truck carrier (PCTC) design at the Marintec China trade fair. 

Recognized as the world's largest PCTC, the 234m long and 40m wide ship will have 14 decks allowing 11,000 car equivalent units (CEUs) to be stored simultaneously, which not only increases efficiency but also reduces the transport cost per vehicle.

By implementing a combination of decarbonization measures, the so-called “Super Large Smart Green 11,000” design will result in a significant reduction in carbon emissions, in line with the stringent requirements of the Energy Efficiency Design Index (EEDI) Phase 3 and NOx Tier III. The PCTC will use LNG as its primary fuel and will be equipped with a 4,200cbm LNG storage tank.

With the assistance of ship designer Deltamarin, the hull line of the vessel has been optimised through numerous CFD calculations and ship model tests. Additional energy-saving features include a stern flow optimization device and an air lubrication system, which effectively minimise resistance and reduce the required propulsion power. The integration of hybrid propulsion systems and solar power further underlines the commitment to reducing energy consumption.

"We expect the market for electric vehicles to continue to grow, driving demand for PCTCs. Scale, energy efficiency and low carbon fuel are key to reducing emissions from the transport of these vessels. As a leading class for car carriers, DNV is honoured to be entrusted with the assessment of this next generation of car carriers and we look forward to working with China Merchants to bring these vessels to the water," said Norbert Kray, Regional Manager Greater China at DNV Maritime.

According to China Merchants, the shipyard is already in discussions with potential customers for the 11,000 CEU PCTC.

Photo credit: DNV
Published: 7 December, 2023

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