TECHNICAL AND REGULATORY NEWS No.

06/2018 – Statutory

PRACTICAL ADVICE FOR IMO DSC DATA

COLLECTION STARTING 1 JANUARY 2019
Relevant for ship owners and managers, shipyards, design offices, suppliers and flag states.

May 2018

Both EU MRV (Monitoring, Reporting and Verification) and IMO DCS (Data Collection System)
requirements are mandatory, and are the first step in a process to collect and analyse CO2 emission
data for the shipping industry. EU MRV data collection already started from 1 January 2018, while
IMO DCS data collection on fuel consumption to comply with the IMO DCS regulations starts
1 January 2019. This statutory news provides practical advice on IMO DCS compliance.

Whilst the EU scheme focuses on CO2 emissions from shipping
activities to, from and within the EU area, the IMO scheme covers
emissions from shipping globally. Whether, how and when the
two regimes will converge is not yet decided, however.
A conclusion of the two schemes as well as the full timeline can
be found on our IMO DCS web pages.
With only some eight months to go before IMO DCS data
collection starts, DNV GL has compiled a list of a few practical
clarifications and recommendations:
Combined reporting for EU MRV and IMO DCS is
recommended:
ƒƒ If your vessel(s) is subject to both EU MRV and IMO DCS,
reporting is required as per the respective requirements.
However, combined reporting for the two schemes can be
done through a combined reporting template. Shipping
companies which have already contracted DNV GL as their
MRV verifier only need to make minor adjustments for the
DCS reporting.
ƒƒ Methods for the monitoring and measurements of fuel con-
sumption are described in SEEMP Part II (see below). A web
application to ease the completion and submission of SEEMP
Part II will be available from DNV GL in June 2018. Further
information about this web application will be provided in
due course on our IMO DCS web pages.
What kind of reporting is required from ships to meet
the regulatory and verification obligations?
ƒƒ For the purpose of verifying the data collected, DNV GL
requires the ship to submit detailed data via regular reporting
on specific events throughout the year. Event reports are
required to calculate:
ƒƒ Consumption data: Based on log abstract reports (arrival/
noon/departure) containing position, fuel consumption,
distance and time. As a minimum, ships should report
upon all port departures and arrivals. For ship operators
applying noon reports as part of their performance moni-
toring, such daily reporting can be used as a basis for the
reports.

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 ƒƒ Fuel balance: To enable verification of the overall fuel
balance for the reporting period (year), the ship operator
is required to provide documentation of bunker delivery
notes (BDN) for each bunker delivery as well as remain-
ing on board (ROB) reports. ROB should as a minimum be
reported at the start, middle and end of the year.
SEEMP Part II is for recording fuel consumption
for IMO DCS
A few clarifications with respect to SEEMP Part II:
ƒƒ SEEMP Part II should be submitted separately of SEEMP Part I,
which should already be in place on board the ship. Hence,
only the new Part II of the SEEMP is now subject to approval
according the MARPOL Annex VI, Reg. 5.4.5.
ƒƒ The approved SEEMP Part II is to be on board all ships in
service on or before 31 December 2018 as an appendix to
the SEEMP Part I, regardless of the vessel delivery date.
ƒƒ SEEMP Part II should describe the monitoring of fuel
consumption for the main fuel consumers on board for
propulsion and normal operations, i.e. main engine, auxiliary
engines, boilers and inert gas generators (not fuel consumed
by the emergency generators, lifeboat engines, etc.).
ƒƒ DNV GL, as Recognized Organization (RO), will also approve
SEEMP Part II plans for non-DNV GL-classed vessels, subject
to authorization and approval by the respective flag. Further-
more, it is up to the flag to decide if the RO covering the
statutory work for a vessel can be different from the RO veri-
fying the fuel oil consumption (FOC) report for that vessel.
Flag acceptance and ROs for IMO DCS
Some clarifications to the role of ROs for IMO DCS:
ƒƒ DNV GL is authorized by most flag authorities for statutory
services and is in the process of becoming authorized for
DCS too. Some flags, however, for instance Liberia, will also
authorize companies other than traditional class societies
(ROs) to perform DCS verification work.
DNV GL – Maritime, Brooktorkai 18, 20457 Hamburg, Germany, Tel: +49 40 36149 0, www.dnvgl.com/maritime
ƒƒ Since the respective flag authorities may issue further flag-
specific requirements (we do not expect any significant flag-
specific requirements, however), it is advisable to contact the
relevant flag for more detailed and updated information.
ƒƒ For practical purposes, we recommend that our customers
use the same verifier for EU MRV and IMO DCS.
Recommendations
ƒƒ Prepare SEEMP Part II by using our SEEMP II digital report-
ing tool, which will be available by June 2018 on our Verac-
ity platform. This will be an online template where you are
guided in preparing the document. We recommend preparing
SEEMP II using this app well in advance of the 31 December
2018 deadline to ensure timely assessment for compliance.
ƒƒ Prepare for the DCS reporting of the required data once
announced by DNV GL in due time. As for MRV, DNV GL will
offer a fully digital reporting approach (meaning: no manual
dispatch of data files or similar).
Customers choosing DNV GL as their verifier for the yearly DCS
FOC reports will receive all required information from DNV GL
throughout the coming months to prepare for their obligations.
References
Our IMO DCS web pages
Our EU MRV web pages
IMO web page on DCS
CONTACT
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