About
The EU MRV Regulation is part of the EU's strategy to reduce greenhouse gas emissions from the maritime industry and requires MRV companies to:
- Submit a monitoring plan to a MRV accredited verifier, which shall reflect the technical specifications and the monitoring methods to be applied.
- Monitor the vessels' greenhouse gas emissions, fuel consumption and other relevant information with a view to aggregate data into an annual emissions report.
- The monitoring plan and emissions reports are to be submitted to a verifier accredited by a national accreditation body, which is to be independent of the company/ship operator.
- By 31 March of each year, the responsible party must submit a verified emissions report.
- By 30 June each year, the shipping company must ensure that all the vessels which have performed activities in the previous reporting period and are visiting ports in the EU/EEA, carry on board a MRV Document of Compliance.
As a part of the revision to the EU ETS, general cargo vessels between 400 and 5,000 gross tonnes was included in the EU MRV regulation from 1 January 2025. Building on the experience from the EU MRV, the Commission shall present a report on whether other vessels (including offshore vessels) between 400 and 5,000 gross tonnes may also be included in EU ETS no later than 31 December 2026.
Who does it impact?
Commercial vessels
- Ship-owners, or another company or person having assumed responsibility for the operation of a ship and compliance with EU ETS and EU MRV, for ships exceeding 5,000 GT operating within the EEA area (to, from or between EEA ports), and for general cargo vessels between 400 and 5000 GT.
- The EU Commission is currently reviewing the potential inclusion of other types of ships between 400 – 5000 GT within the EU MRV scope.
- The EU MRV Regulation applies regardless of the vessel's flag state or country of ownership, and it applies to vessels carrying cargo or passengers for commercial purposes to, from or between ports within the EEA.
Offshore vessels
- Offshore vessels of 400 GT or above that were designed or certified to perform service activities offshore or at offshore installations are included in the EU MRV from 1 January 2025. This includes offshore supply ships.
- The relevant test is therefore what service the vessel was designed or certified to perform, not what kind of service the vessel is actually performing.
- For offshore vessels, the definition of "a port of call" also includes a port call to relieve crew, and stops at offshore facilities with an assigned UN/LOCODE and/or that is permanently connected to a port.
- The inclusion of offshore vessels in the EU MRV and EU ETS legal frameworks have been criticised by the industry, particularly how the concepts of "port calls" and "voyages" should be understood in the context of offshore vessels. Thommessen is monitoring how the EU Commission responds to this.
Status: In force
The EU MRV Regulation was adopted by the European Council and Parliament and entered into force on 1 July 2015.
Due to several amendments, the obligations have gradually become more comprehensive.
Relation to other initiatives and regulations
The EU MRV Regulation and the IMO Data Collection System on fuel consumption are two similar systems, which require the responsible parties to report separately on emissions.
The main differences are:
- The EU MRV Regulation focuses on emissions from shipping activities within the EU area, whereas the IMO DCS covers emissions from global shipping;
- The EU MRV Regulation requires reporting of actual cargo carried, whereas the IMO DCS uses ship DWT as cargo proxy;
- The EU MRV Regulation provides requirements for monitoring plans in a special format, whereas the IMO DCS requires a Part II of the SEEMP, called Ship Fuel Oil Consumption Data Collection Plan with its own given format;
- The EU MRV Regulation requires verification by an accredited body, whereas the IMO DCS requires verification by the flag state or a recognised organisation (such as, but not limited to, authorised class societies);
- Data under the EU MRV Regulation must be submitted through the THETIS-MRV system of EMSA, whereas the IMO DCS data collected are reported to the relevant flag state administration or recognised organisation; and
- Data reported under the EU MRV Regulation is published on a per-ship basis, whereas data reported under the IMO DCS is anonymously published by the IMO.
Reports under the FuelEU Maritime regulation are also submitted in the THETIS-MRV, which entails there is a significant degree of integration between the two systems.
Following the UK's withdrawal from the European Union, the UK has introduced its own UK MRV regime, which applies to emissions from ships sailing between UK ports and UK and non-EEA ports, and otherwise largely mirrors the EU MRV regime.
Participants
The EU MRV Regulation currently applies to ships above 5,000 GT, as well as general cargo vessels between 400 and 5000 gross tonnes and offshore vessels of 400 GT and above, regardless of their flag or country of ownership, carrying cargo or passengers for commercial purposes to, from or between ports within the EEA.
Thommessen's comments
The obligations under the EU MRV Regulation are to be fulfilled on a 'per ship' basis and the fulfilling MRV company will be either the ship-owner, or any other company or person, such as a manager or a bareboat charterer, which has assumed the responsibility for the operation of the vessel from the ship-owner. From 2025, shipping companies falling within the scope of the EU ETS must also submit aggregated emissions data at company level. The default responsible party is be the shipowner. The responsibility may be delegated to the entity that has assumed responsibility as the Document of Compliance (DOC) holder under the ISM Code (ISM DOC Holder). The same entity must be responsible for compliance under the EU ETS and the EU MRV.
The responsible party shall submit a report with aggregated emissions data from all the vessels for which it is responsible in the reporting period, which runs from 1 January to 31 December each year.
The data that is reported under the EU MRV Regulation forms the basis of the calculation of how many allowances must be submitted under the EU Emission Trading System.