IMO Releases Guidance on Amendments to MARPOL Annex VI Fuel Data Reporting

The International Maritime Organization (IMO) released MEPC.1/Circ.913 on November 20, 2024, offering guidance on the implementation of amendments to Appendix IX of MARPOL Annex VI. These amendments focus on enhancing the granularity of fuel consumption data collection and reporting for the IMO Ship Fuel Consumption Database (IMO DCS). Adopted through resolution MEPC.385(81), the changes aim to improve the accuracy and consistency of emissions monitoring and compliance.

Since 2019, vessels with a gross tonnage of 5,000 or more have been required to gather and report annual or partial-year fuel consumption data as part of their Ship Energy Efficiency Management Plan (SEEMP). The recent amendments stress the need for more detailed data collection regarding transport work and operational metrics, necessitating updates to SEEMP methodologies to ensure compliance. The 2024 Guidelines for SEEMP development (resolution MEPC.395(82)) outline the framework for these updates.

Key Changes and Requirements

Regulatory Updates:

• Regulations 27.1 and 27.2: Mandate uniform data collection and reporting at the same granularity level for each calendar year.
• Regulation 26.2: Requires the SEEMP to detail how data will be collected and reported.
• Regulation 5.4.5: Obligates flag Administrations to verify SEEMP compliance before ships commence reporting.

Implementation Timeline:

• Early Implementation (January 1, 2025): SEEMPs must be updated and verified to include enhanced granularity methodologies. Ships may need to retrofit equipment, such as flow meters, and begin collecting detailed data in 2025.
• Standard Implementation (August 1, 2025): SEEMPs must be updated by January 1, 2026. Data for 2025 will adhere to existing granularity levels, with enhanced granularity mandated starting in 2026. Ships delivered on or after August 1, 2025, must comply with the new data requirements immediately.

Stakeholder Actions:

• Administrations: Ensure revisions to SEEMPs and verify compliance before the implementation deadlines.
• Shipowners and Operators: Update SEEMPs, retrofit necessary equipment, and adjust data collection methodologies accordingly.
• Masters and Crew: Implement and adhere to the revised data collection and reporting processes.