Must we comply with both IMO and EU MRV?
The European Union (EU) Monitoring, Reporting and Verification (MRV) regulation is something we discussed in 2013 in our blog MRV more teeth than SEEMP. At the time, the regulation was perceived as something that was a long way on the horizon. Things have since begun to heat up and some of the requirements under the EU regulation must be complied with, in 2017.
After the EU set itself on a clear path towards the MRV of carbon dioxide (CO2) emissions from ships, the IMO has embarked on a similar project with similar objectives. While the EU MRV regulation focuses on emissions from shipping activities within Europe, the IMO’s vision is quite global.
In recent years IMO member states, have made significant progress towards addressing GHG emissions from international shipping. Using data from the IMO CO2 data collection system, which is expected to record CO2 emissions data across the global fleet, the IMO in the spirit of Paris MOU, plans to include CO2 reduction objectives for the entire shipping sector. This is set for adoption in 2018 and as a sign of commitment, three additional inter-sessional meetings have been specifically approved to take this forward.
The EU regulation 2015/757 also known as the MRV regulation entered into force on 1st July 2015. The aim was to understand better the consumption of fuel and CO2 emissions from maritime transportation within Europe to be ultimately used towards any future greenhouse gas reduction programs. The full details of how the EU regulation will be implemented is being currently worked out by the European Commission.
It goes without saying that while the IMO system will need to be complied with globally, all ships irrespective of flag in EU ports, will need to be in full compliance also of the EU MRV regulation and therefore send their individual vessel data directly to the European commission. It therefore is important to understand the salient differences between the two:
EU MRV involves far more detailed reporting compared to the IMO equivalent.
Unlike the IMO which relies on recognized organisations (mainly classification societies), the EU follows the path of verifier bodies authorised by national accreditation bodies, that are associated with the EU emission trading system.
The European Commission as required by EU regulation, intends to be transparent with the information it gathers and publish all data including every ship and company identifier. The IMO on the other hand intends to keep all info anonymous.
There is a fear among the member states of the IMO that the EU may use this data to set baselines, benchmark performance or set an efficiency index that could be unfair to some ships, especially if it is based on data that may not be pertinent to a vessel’s actual efficiency or CO2 emissions. Not just that, since the EU data is publicly available, it could be particularly disruptive. The data can be used by third parties, and the concern is that detailed and sensitive data when publicly available, could be misused, impacting commercial markets.
The anonymous nature of IMO’s collected data is with the specific intent only to ascertain the global CO2 emissions from international shipping. It is felt that this data will facilitate better policy decisions and examination of need for further reduction in GHG emissions.
There is a consensus in the shipping community that there is no need for two similar regulatory regimes to coexist and therefore become more of a nuisance. It is believed that perhaps its better if both systems can be aligned and accepted globally. Uniformity in regulation will mean ease of compliance and a level playing field across the globe.
The regulators whether at the IMO or the EU, need to keep in mind that the fewer the regulatory constraints, the easier it is for shipping and the cheaper it is to receive goods across the world. Automating the whole MRV process will be a leap forward not just in reducing the administrative burden but also in avoiding the red tape in monitoring and enforcing compliance.
Let us know your thoughts.