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IMO Update by DNV: Marine Environment Protection Committee – MEPC 78

13 Jun 2022

Classification society DNV on Saturday (11 June) published ‘IMO UPDATE: MARINE ENVIRONMENT PROTECTION COMMITTEE – MEPC 78’.

It focuses on highlights of the 78th session of the IMO’s Marine Environment Protection Committee (MEPC 78) that was held remotely from 6 to 10 June 2022 including approval of a proposal for a sulphur emission control area (SECA) in the Mediterranean Sea, reporting of flashpoint in the Bunker Delivery Note and discussions on market-based measures. 

The following are extracts from the full document: 

Meeting highlights

  • Finalization of guidelines for the EEXI, CII and SEEMP
  • Consideration of revisions to the IMO GHG Strategy and future technical and market-based measures
  • Approval of a new sulphur emission control area (SECA) expected to take effect from 1 July 2025, subject to final adoption at MEPC 79 in December 2022
  • Adoption of amendments to MARPOL Annex I and the IBC Code on watertight doors
  • Adoption of amendments to MARPOL Annex II on the Hazard
  • Evaluation Procedure for chemical tanker products
  • Extension of the ballast water experience building phase

Reporting of flashpoint in the Bunker Delivery Note (BDN)

Following the approval of amendments to SOLAS Chapter II-2 by MSC 105 in relation to the flashpoint of oil fuel, amendments to Appendix V of MARPOL Annex VI (Information to be included in the BDN) were approved subject to adoption at MEPC 79. The following new item has been added to the BDN: “Flashpoint (°C) or a statement that flashpoint has been measured at or above 70°C”.

Unified interpretations

MEPC approved a unified interpretation of Regulation 18.3 of MARPOL Annex VI with regard to the use of biofuels. The amendment clarifies that fuels with a biofuel content up to 30% in principle fall under the definition of marine fuel oil derived from petroleum refining (Regulation 18.3.1) and no further NOx testing is required. For fuels with a biofuel content of more than 30%, it needs to be verified that the engine is not altered beyond the approved parts and settings of the NOx Technical File (Regulation 18.3.2) in order to not require NOx testing.

Revision of the IMO GHG Strategy

There was an extended exchange of views on the scheduled revision of the IMO GHG Strategy, but with no new decisions being made. The main divergence in views between countries is the split between those calling for full decarbonization by 2050, and those calling for further assessments on feasibility and impacts on states before such a decision can be made. 

The MEPC will adhere to the established workplan on this matter and make its decision at MEPC 80 in July 2023. Further discussions will take place at an intersessional meeting agreed to be held back-to-back with MEPC 79 in December 2022. There is also the expectation that an intersessional meeting will be held in the spring of 2023 dedicated to this matter. 

Mid and long-term measures to reduce GHG emissions

There was an extensive discussion on potential mid and long-term measures at the intersessional meeting held two weeks prior to MEPC 78. At this meeting, proposals for various market-based measures were discussed: 

  • A levy system based on absolute well-to-wake GHG emissions. The GHG price is determined by the IMO. 
  • A levy system based on CII performance, where ships with CII performance below a benchmark pay a contribution per tonne CO2, and ships with performance above the benchmark receive a reward. The contribution is determined by the IMO, while the reward depends on the level of achievement of the fleet.
  • A levy system based on absolute tank-to-wake CO2 emissions where the revenues are partly used to provide a direct rebate to zero-emission vessels. The CO2 price and rebate are determined by the IMO. 
  • An emissions cap-and-trade system, similar to the EU ETS, where the well-to-wake GHG emission level is set by the IMO and allowances are auctioned out. The carbon price is then determined by the market. 

Additionally, there were discussions on a proposed technical measure in the form of a well-to-wake GHG intensity fuel standard. 

MEPC 78 did not develop these proposals further, and discussions will continue at an intersessional meeting prior to MEPC 79 and following meetings. The decision on which measures to develop into regulations will be made at MEPC 80 in July 2023

On-board CO2 capture

Due to time constraints, only a very brief discussion was held on provisions for taking into account on-board CO2 capture in instruments such as the EEDI and CII. The topic will be discussed further at future meetings.

Lifecycle GHG/carbon intensity for marine fuels

An intersessional working group prior to MEPC 78 developed draft guidelines on lifecycle GHG/carbon intensity for marine fuels. The work will continue through a correspondence group reporting to MEPC 80 in July 2023.

Identification and protection of special areas, ECAs and PSSAs

MEPC 78 considered and approved a proposal for a Sulphur Emission Control Area (SECA) to be established in the Mediterranean Sea. The proposal is subject for adoption at MEPC 79 in December of this year, and is expected to take effect from 1 July 2025. The requirement will be the same as for other SECAs, mandating the use of fuel oil with a sulphur content of 0.10% or of an EGCS.


DNV recommends that our customers evaluate possible technical and operational modifications to comply with the upcoming GHG requirements and, when applicable, to prepare and submit an EEXI

Technical File and a SEEMP Part III for verification.

Note: The full version of this news can be downloaded here


Photo credit and source: DNV
Published: 13 June, 2022

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