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Gard on FuelEU: Monitoring plans must be ready in August

FuelEU Maritime will come into effect from 1 January 2025, but monitoring plans for vessels already calling at European ports must be submitted by 31 August 2024, says Gard.




Guillaume Périgois on Unsplash

Maritime protection and indemnity (P&I) club Gard on Monday (3 June) published an insight to remind companies calling at European ports to get ready before the end of the summer.

FuelEU Maritime will come into effect from 1 January 2025, but monitoring plans for vessels already calling at European ports must be submitted by 31 August 2024: 

The purpose of the FuelEU Maritime(FuelEU) is to stimulate shipping’s uptake of renewable and low-carbon fuels to reduce greenhouse gas (GHG) emissions. Vessels trading within or calling at the EU/EEA, regardless of their flag, will have to comply with the GHG emission limits of the energy used onboard. Further details about the regulation can be found in our introductory article.

Whilst vessels over 5,000 GT have had to submit Monitoring Reporting Verification (MRV) data since 2018, the FuelEU Monitoring Plan is separate to this. Vessels cannot rely upon existing MRV monitoring plans. 

Instead, a new Monitoring Plan is required, although aspects of the existing MRV plan can be used. 

Who needs to comply?

The company responsible for compliance with FuelEU (the company) is always the ISM company, i.e. the Document of Compliance (DoC) holder, irrespective of whether the DoC holder is the registered owner, a bareboat charterer, or a third-party technical ship manager. As the majority of owners delegate ISM Code responsibilities, in reality the responsible entity is likely to be the technical manager.

This contrasts with the EU ETS, where the responsible company may be the owner or the DoC Holder. As such, the responsible shipping company may differ for the EU ETS and FuelEU. The company must register with an Administering Authority, which is fortunately the same entity as that for EU ETS compliance. 

In cases of compliance deficit and FuelEU penalties, the entity responsible for purchasing the fuel or for taking operational decisions that affect the vessel’s GHG emissions could be required to reimburse the ISM company for these penalties.

What does this mean in practice?

Companies will need to submit a separate FuelEU Monitoring Plan for each of their vessels. The EU Commission has produced a draft template Monitoring Plan, which has recently been subject to public consultation. The standardised template was expected to be published in the first quarter of 2024. According to the European Commission’s website, the template is currently “in preparation”, along with the technical rules for the template’s uniform application.

Monitoring Plans, which can be amended for the particular vessel, are available from classification societies and other third parties accredited by the European Maritime Safety Agency. Some verifiers provide this in an online form format.

Monitoring Plans cannot be submitted to classification societies/accredited third parties for verification until the official EU template standard Monitoring Plan and supporting documentation have been published. This is scheduled for the end of June 2024. Companies will then have July and August to submit their Monitoring Plans to their chosen verifier.

For vessels falling under the scope of the Regulation for the first time after 31 August 2024, companies should submit a Monitoring Plan to the verifier no later than two months after each vessel’s first call at a EU/EEA port.

Well-to-wake GHG emissions

FuelEU is based on a Well-to-Wake approach to the GHG emissions of the energy used onboard a vessel. This means that the emissions in producing and transporting the fuel to the bunker tanks are taken into account, as well as the emissions when the fuel is burned. 

Compliance in the first instance requires the use of certified biofuels, LNG, LPG, auxiliary power units (fuel cells), shore power, wind-assisted propulsion, or a combination of these. As zero or near-zero emission fuels (e-methanol, e-ammonia, e-hydrogen) are more widely available, these will enable compliance as the FuelEU GHG limits further reduce from 2030.

The purpose of the Monitoring Plan is to monitor, record and report data about the types and quantities of fuel or other sources of energy used onboard and the GHG emissions associated with them.

Key elements of the revised Monitoring Plan

Vessels trading in the EU/EEA countries should have the approved FuelEU Maritime Monitoring Plan on board before 1 January 2025. Once the Monitoring Plan is finalised, the verifier should record it in the FuelEU database. The Monitoring Plan should be accessible to the Administering State.

The FuelEU Monitoring Plan is detailed and must include the following key elements, amongst other information:

Emissions sources are to be listed and described, such as main engines, auxiliary engines, fuel cells, and waste incinerators.

Fuel types are also to be listed and described, for example: ‘H2 (Fossil)’, ‘NH3 (Fossil), ‘Methanol (Fossil)’, ‘Ethanol’, ‘Bio-diesel’, ‘Hydrotreated Vegetable Oil (HVO)’, ‘e-diesel’, ‘e-methanol’, ‘e-LNG’, ‘e-H2’, and ‘e-NH3’. Where there is fuel blending, each component of the blended fuel must be considered as a separate fuel.

The emission factor to be applied to each fuel type applicable over the reporting period must be identified.

A description of the relevant procedures to update emissions sources, fuel types, fuel consumption and activity data per voyage (such as distance travelled, cargo carried, time spent at sea).

A description of the control system to be put in place, which should include written procedures for data flow activities, risk assessment, and control activities.

Procedures for monitoring the fuel consumption of each fuel type as well as the energy provided by substitute sources or a zero-emission technology. A description of the procedures for monitoring and reporting the well-to-tank and tank-to-wake emission factors of energy to be used on board.


Photo credit: Guillaume Périgois on Unsplash
Published: 4 June 2024

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NYK installs wind-assisted ship propulsion system on bulker “NBA Magritte”

NYK Bulkship (Atlantic) installed two wind-assisted ship-propulsion units on Cargill-chartered bulk carrier on 8 July at the port of Rotterdam, the Netherlands.





NYK installs wind-assisted ship propulsion system on bulker “NBA Magritte”

NYK Line on Tuesday (23 July) said NYK Bulkship (Atlantic) N.V. (NBAtlantic) has installed two wind-assisted ship-propulsion units on the bulk carrier NBA Magritte on 8 July at the port of Rotterdam, the Netherlands.

The bulk carrier is engaged in a long-term charter contract with Cargill (USA). 

“This is the first time a unit of this type has been installed on an NYK Group vessel,” NYK said on its website. 

Sitting on a 20-foot-long (approximately 6-metre) flat rack container with no walls, VentoFoil has a 16-metre vertical wing that acts as suction sail which expects about 5 times as much force compared to no-suction versions.

Features of VentoFoil

・VentoFoil creates propulsion with the pressure difference on both sides of the wing and is expected to help reduce greenhouse gas (GHG) emissions during vessel navigation.

・It takes in wind through its suction port and obtains greater propulsion by amplifying the pressure difference.

・The system can be easily activated and deactivated through a touch panel installed on the bridge, enabling operation without increasing the crew’s workload.

・It is smaller than similar wind equipment, making it easy to install and relocate.

・It can be folded in about 5 to 6 minutes, keeping it out of the way of cargo handling. (See video below.)

NBAtlantic will collect data on the propulsion generated by this equipment, as well as meteorological and ocean conditions during navigation, and measure the unit’s effectiveness in collaboration with Cargill International Inc. and NYK R&D subsidiary MTI Co., Ltd.

This initiative is part of NYK’s long-term target of net-zero emissions of GHGs by 2050 for the NYK Group's oceangoing businesses. The NYK Group will utilise the knowledge gained in this research and development to promote initiatives related to various energy-saving technologies, including the use of wind power.


Photo credit: NYK Line
Published: 24 July 2024

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DNV: Leading maritime cities driving decarbonization of shipping

Dr Shahrin Osman, Business Development Director, DNV Maritime Advisory and co-author of Leading Maritime Cities report, explains the central importance that decarbonization and digitalization occupy within shipping.





Dr Shahrin Osman, Business Development Director, DNV Maritime Advisory

Dr Shahrin Osman, Business Development Director, DNV Maritime Advisory and co-author of the Leading Maritime Cities report, explained the central importance that decarbonization and digitalization occupy within shipping in this article published on Tuesday (23 July). 

He outlined how maritime cities are the centres of gravity driving this forward, facilitating innovation and coming up with the solutions which are needed for shipping to reach its ambitious decarbonization goals:

The Leading Maritime Cities report shines a light on the key cities driving the maritime industry forward. With decarbonization and digitalization key factors in today’s maritime world, the report’s co-author explains how these are being advanced by activities in the leading maritime cities.

The latest edition of the Leading Maritime Cities (LMC) report was published in April this year. The collaboration between DNV and Menon Economics delivers fresh insights into the maritime cities which offer the best policy measures, infrastructure and supporting institutions, and how these are driving advancements in the maritime industry.

Leading maritime cities in a world of transition

The LMC report recognizes the central importance that decarbonization and digitalization occupy within shipping. The impact of these two dimensions cuts across the traditional pillars that cities are benchmarked on. To address their transformative effect, this year’s report introduces new indicators – such as capabilities in the adoption of digital technologies and automated processes for port operations, and proactivity in implementing green and sustainable financing practices.

“The maritime industry is in the midst of a major transformation,” says Dr Shahrin Osman, Business Development Director, DNV Maritime Advisory and co-author of the report. “Decarbonization targets mean that the entire industry is looking at how it can undergo a transformation of technologies and fuels to reduce emissions, all of this being supported by advances in digitalization.”

Singapore dominates rankings with strong decarbonization efforts

“Maritime cities are the centres of gravity driving this forward. This is where the leading companies and talents are residing and where the real transformations are taking place. They provide platforms for progress and serve as conduits, linking the industry with the wider global economy.”

Like in the previous edition of this report in 2022, a combination of objective and subjective indicators are used to rank the different cities. Singapore was once again recognized as the leading maritime city, followed by Rotterdam and London, with Shanghai and Oslo making up the remainder of the top five. The Asian city-state hit the top spot in three out of the report’s five pillars, retaining its position as leader in Attractiveness and Competitiveness and overtaking Athens and Shanghai in Shipping Centres and Ports and Logistics. Much of this is due to Singapore’s strong positioning towards decarbonization.

The Silicon Valley of the maritime industry

“Driven by key bodies like the Maritime and Port Authority of Singapore and the Global Centre for Maritime Decarbonization, Singapore has a forward-leaning, future-ready approach. They look at things not just for the next few years, but for the next decade,” says Shahrin. “This includes policies towards building up a multi-fuel infrastructure, the electrification of harbour craft, and the promotion of green shipping corridors.”

“Overall, this has made Singapore an attractive location for shipping businesses, to the point where we now regard it as the Silicon Valley of the maritime industry.”

Government policies driving the green transition in key cities

As the example of Singapore has shown, strong, progressive government policy is one of the key factors behind the evolution of maritime cities, underpinning a forward-leading approach. This can attract companies and top talent to a city, while creating a competitive economic environment with well-developed infrastructure can encourage these actors to stay.

“This is especially relevant for decarbonization initiatives, where returns on investments take longer, and are dependent on wider infrastructure being in place,” says Shahrin. “Government support mechanisms can be crucial in facilitating innovation, so that new products and solutions can be developed.”

Shahrin points to the Norwegian Green Shipping Programme as a prime example of good government policy in action. This brings together public and private actors to overcome key decarbonization barriers, supported by funding from the Norwegian parliament.

Attraction of talent to cities key to progress

Central to the attractiveness and competitiveness of a maritime city is its ability to attract and retain top talent. The presence of research and educational institutions can help to develop talent within that location. The availability of professional opportunities and general high standards of living will encourage leading talents to relocate.

“Achieving technological progress is dependent on aggregating available knowledge that could otherwise be located in silos, and bringing it all together in clusters,” says Shahrin.

Note: DNV’s full Maritime Impact can be viewed here


Photo credit: DNV
Published: 24 July 2024

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New study shows real world complexities and shortcomings of IMO CII formula

If IMO aims to maintain CII as a meaningful measure to incentivise shipping’s decarbonisation, a thorough review of the formula is necessary, says Royal Belgian Shipowners’ Association and AMS study.






The Royal Belgian Shipowners' Association (KBRV) released a study that investigated issues with the International Maritime Organization’s (IMO) Carbon Intensity Indicator (CII) formula. 

The study, titled Evaluating the Carbon Intensity Indicator: Challenges and Recommendations for Improvements, was done in collaboration with four master’s students from the Antwerp Management School (AMS). 

As part of their thesis project, the research conducted by the students included a comprehensive literature review, a qualitative analysis, and a quantitative analysis using data from Belgian-controlled ships.

The following are the key findings and recommendations of the study:

Key Findings 

Both literature review and qualitative analysis identified three variables with the most adverse impact on CII ratings:

  • Waiting Time: Time spent idling or waiting in ports or awaiting orders.
  • Number of Ports of Call: The frequency with which a ship docks at different ports.
  • Distance Travelled: The total nautical miles covered by the vessel.

The quantitative analysis confirmed the significant impact of these variables. However, a deeper dive into different shipping segments revealed a complex interplay of factors affecting CII ratings, making it difficult to pinpoint the main adverse variables universally.

For example, container vessels are highly affected by the number of port calls. An increased number of stops results in a worsened CII rating.

When comparing three Very Large Crude Carriers (VLCC) with similar distances travelled, waiting times, and number of port calls, differences in CII ratings still occurred. This could be attributed to external factors beyond anyone's control, such as adverse weather conditions.

For LPG carriers, there was a clear correlation between waiting days and CII ratings. Carriers that traded on routes with major port congestions - thus longing waiting time - scored lower than a sister ship with identical design efficiencies on less busy operating routes.


These findings underscore the multifaceted nature of CII ratings. If the IMO aims to maintain the CII as a meaningful measure to incentivise shipping's decarbonisation, a thorough review of the formula is necessary, taking into account the various factors beyond the control of both shipowners and charterers that influence the CII ratings. At a higher level, the scope and goal of the CII within the basket of measures needs to be reassessed as well.

Shipping is the most efficient way of transporting goods, emitting the lowest GHG per ton of transported cargo. Addressing the carbon efficiency of the sector requires the effort of every stakeholder involved, from shipowners and charterers to port authorities and customers. Placing the responsibility for a ship's efficiency solely on the shipowner does not accurately address the complexities and other influencing factors that exist.

Note: The study titled Evaluating the Carbon Intensity Indicator: Challenges and Recommendations for Improvements can be downloaded here

Manifold Times has covered several parties calling for the amendment of CII in the past including:

Related: INTERCARGO joins shipping industry in calls for IMO to amend CII flaws
Related: IBIA pursues amendment to Carbon Intensity Indicator for bunker vessels


Photo credit: International Maritime Organization
Published: 24 July 2024

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