IMO – New short-term measures to implement Green House Gas (GHG) strategy

On 23 October 2020, the IMO announced that two new draft mandatory short-term measures to cut the carbon intensity of existing ships have been agreed by its Working Group on Reduction of GHG Emissions from Ships. The new measures announced are in line with the ambition of the IMO’s Initial GHG Strategy which aims to reduce carbon intensity of international shipping by 40% by 2030, compared to 2008.

The current requirements

There are currently two energy efficiency measures addressing GHG emissions in MARPOL Annex VI chapter 4. These entered into force on 1 January 2013.

  1. (i) The Energy Efficiency Design Index (EEDI)  for new build ships which mandate that new builds must be more energy efficient than the baseline set for that ship type; and
  2. (ii) The mandatory requirement for all ships to have in place a Ship Energy Efficiency Management Plan (SEEMP) to improve energy efficiency through a variety of ship specific measures. This requirement does not include mandatory operational efficiency reduction targets.

The proposed new requirements

(i) The technical requirement on all ships to reduce carbon intensity, based on a new Energy Efficiency Existing Ship Index (EEXI). Ships are required to meet a specific required EEXI which is based on a required reduction factor (expressed as a percentage relative to the EEDI baseline); and

(ii) The operational carbon intensity reduction requirements, applicable to ships of 5,000 gt and above, based on a new operational carbon intensity indicator (CII).  The CII determines the annual reduction factor needed to ensure continuous improvement of the ship’s operational carbon intensity within a specific rating level. Documenting and verifying the ship’s actual annual operational CII against its required annual operational CII would enable the improvement or otherwise of the ship’s operational carbon intensity year on year to be determined, and rated accordingly.

The new measures proposed will build on the current mandatory energy efficiency requirements by bringing in requirements to assess and measure the energy efficiency of all ships and set the required attainment values.  They would require ships to combine a technical and an operational approach to reduce their carbon intensity.The draft amendments to MARPOL Annex VI will be forwarded to the Marine Environment Protection Committee (MEPC) 75 for consideration on 16-20 November 2020. If approved, they could be put forward for adoption at MEPC 76 in 2021, and if adopted, they will enter into force after a minimum 16 months following adoption. 

Members are directed to the full IMO press briefing for additional details. Members are also directed to the UK Club’s article, “A Roadmap to Ship Decarbonisation” for an overview of the IMO’s strategy for reducing GHG emissions from ships.

Jacqueline Tan

Legal Services Manager

Date29/10/2020