UK MRV regime – MIN 669 (M+F) Reporting Emissions Data

The Club would like to draw Members’ attention to the UK MCA’s guidance issued on 17.09.21, providing updated details on the requirements for monitoring and reporting emissions data from ships to the UK MRV Regime.

  • While the UK is no longer part of the EU MRV regime, the EU Regulation which established that regime was retained in the UK’s domestic law, subject to requisite amendments. The UK is therefore establishing a UK MRV regime to monitor, report and verify emissions data from ships calling at UK ports.
  • The legislation establishing the new UK MRV regime is now in place but the processes for its practical operation are still being finalised. The legislation had envisaged data being collected from 2021 but it is recognised that it would not be possible for ship operators and verifiers to comply with the obligations under the regime without further preparation. 
  • The UK MRV regime is expected to be fully in place by the end of 2021. Operators will therefore be expected to begin collecting data for voyages for  the UK MRV regime from 1 January 2022 onwards, for the 2022 reporting period. No enforcement action will be taken by the MCA until 2023.
  • To avoid duplication, emissions data for voyages between the UK and countries in the EEA, and vice-versa should continue to be reported to the EU MRV regime.
  • Only emissions data for voyages between UK ports, between UK and non-EEA ports, and vice-versa, and from vessels at berth in a UK port will need to be reported to the UK MRV regime. 
  • From 1 July 2021, ships which used a UK or EEA port in 2020, should be carrying a Document of Compliance (DoC) for emissions data collected during the 2020 reporting period, to comply with the EU MRV regime. A DoC issued under the EU MRV regime and which covers voyages between the UK and EEA ports is recognised as a UK DoC equivalent for those voyages.
  • By 31 December 2021, an assessed UK MRV monitoring plan needs to be in place. If a ship already uses a monitoring plan under the EU MRV regime, the ship operator should confirm with the verifier if the plan is suitable for the UK MRV regime, or if changes are needed.
  •  From 1 January 2023, all verifiers must be accredited by the United Kingdom Accreditation Service (UKAS). Ship owners should check the status of their verifier(s).
  • From 30 June 2023, a separate DoC will be needed by ship operators to cover voyages to and from UK ports, made in the previous reporting period, which fall outside the scope of the EU MRV.

Please see the timeline below for the application of the UK MRV regime in Annex C of MIN 669 (M+F):

2021

  • End of May 2021 – informal consultation with key stakeholders
  • End of September 2021 – publication of MCA guidance (MIN); verifiers begin applying to UKAS for accreditation
  • October 2021 – ask verifier if existing EU MRV monitoring plan is suitable for UK MRV
  • 31st December 2021 – Deadline for assessment of the monitoring plan

2022

  • 1st January 2022 - Data collection: start of 1st reporting period for UK MRV
  • November 2022 – Planned delivery of key elements of “PMRV”
  • 31st December 2022 – end of 1st reporting period

2023

  • 1st January 2023 - Collection of 2023 data begins
  • 15th of February 2023 – 2022 emissions report sent to verifier
  • End of March 2023 – verifier assesses report and resolves any issues
  • 30th April 2023 – verified emissions report submitted
  • 30th of June 2023 – Document of Compliance issued to ship for 2022 data

The UK MCA’s guidance may be accessed here for additional details relating to the key legal requirements, the voyage and the emissions data required, and the activities covered under the UK MRV regime. If Members have any questions relating to the UK MRV regime, your usual contact at the Club will be pleased to assist you.

 

Jacqueline Tan

Legal Services Manager

Date06/10/2021