ALIGNMENT OF EU MRV REGULATION WITH IMO CO2 DATA

COLLECTION SYSTEM

On behalf of the EU and global shipping industries, we are encouraged by the

positive statements from the European Commission acknowledging the
significant progress made by IMO Member States in addressing GHG emissions
from international shipping. With the full support of industry, IMO Member States
have agreed, among other things, to develop a comprehensive strategy for
further reduction of GHG emissions from shipping. This initial IMO strategy will be
further refined using data from the IMO CO2 data collection system, also adopted
at MEPC 70, which will provide data on CO2 emissions from ships across the world
fleet.
We acknowledge that the Commission is currently working out the full details of
how the EU Regulation will be implemented, but in addition to complying with
the IMO system, all ships calling at EU ports, including ships flying flags outside of
the EU, they will soon have to comply and send data about their ships directly to
the European Commission.
Some of the requirements of the EU Regulation must be met during 2017.
The following is a simple analysis of three areas where significant differences
currently exist between the IMO and EU regimes:
- Metrics: The metrics that the EU requires ships to report are much more
detailed than those required by the IMO regime. Aside from the
administrative burden created, there is concern among many IMO member
states that the next step may be for the EU to use this data to develop a
unilateral operational efficiency index, which in turn could be used to
unfairly penalize individual ships. , using abstract metrics that have no
relation to the actual carbon efficiency of the ship. or CO2 emissions.
- Verification: The EU verification system requires the use of verification
bodies authorized by national accreditation bodies associated with the EU
Emissions Trading System, rather than Recognized Organisations.
- Data publication: The EU wants to publish detailed data on individual
ships visiting EU ports, which can be misused, resulting in unfair
penalization of ships and, as a consequence, market distortion.
In view of the significant progress being made at IMO, we encourage the
Commission to examine ways in which the requirements of the EU MRV
Regulation can be aligned with the global system that has been adopted by IMO
Member States.
In addition to the need for global regulatory uniformity and the avoidance of dual
systems, we believe it will be timely for the EU to send an early signal to other IMO
Member States that it intends to achieve a single CO2 data collection system for
transport international maritime.
With the support of industry, developing countries have been persuaded to
accept the IMO's 'three-step' process and the adoption of the CO2 data collection
system, as a step prior to consideration of further measures. , but with the
understanding that this would help prevent action.
A signal from the Commission confirming that it is taking the necessary steps to
align the EU regime with the IMO data collection regulation would go a long way
in avoiding polarization in the next round of discussions at the IMO, stimulating a
further progress towards the ambitious global solution that the Commission is
also seeking, and which the global and EU shipping industries fully support.

European Community Shipowners’ Associations:

- The European Community Shipowners’ Associations (ECSA) is the voice of
the European shipping industry. Founded in 1965 as “Comité des
Associations d'Armateurs des Communautés Européennes (CAACE)”, ECSA
promotes the interests of 19 member associations of the EU and Norway.
ECSA strives for a regulatory environment that fosters the international
competitiveness of European shipping.

ECSA has a Board of Directors, four specialised committees, a number of

working groups and task forces, targeting specific issues, and a permanent
Secretariat based in Brussels.

International Chamber of Shipping:

- ICS has members from around 40 countries. Our membership comprises

national shipowners’ associations, through which structure ICS uniquely
and legitimately speaks for and represents the significant majority of
international shipping. Our national member associations represent
shipping companies from all sectors of the shipowner community. These
include dry bulk carriers, oil tankers, chemical tankers, gas carriers,
container ships, general cargo ships, offshore support vessels, and
passenger ships.

ICS was established in 1921 to ensure the development, promotion, and

application of best practices throughout the shipping industry. ICS
continues to support shipping and be the leading advocate for high
operational standards and a regulatory environment embracing safety,
environment, open markets and fair competition.

As the collective voice of the international shipping industry, ICS articulates

and advocates shipowner positions to international regulators International
Maritime Organization and International Labour Organization as well as to
other government regulators and relevant stakeholders. ICS aims to
positively influence regulatory changes while maintaining high standards
of quality, safety and environmental protection.
Asian Shipowners’ Association:
- Asian Shipowners’ Forum (ASF) was founded in April 1992 when its first
meeting was held at Japan Shipping Club in Tokyo. As one of the important
shipping organizations in the world, it consists of seven members from the
shipowners’ associations of Asia Pacific nations and Federation of ASEAN
Shipowners’ Associations (FASA). The ASF membership together is
estimated to control about 50% of the world merchant fleet today.

Five standing committees are formed in ASF and each is headed by a

nominated chairman. They are the Seafarers Committee (SC), Ship
Insurance & Liability Committee (SILC), Safe Navigation & Environment
Committee (SNEC), Shipping Policy Committee (SPC) and Ship Recycling
committee (SRC). The work is basically done between the annual ASF
meetings, with each committee being committed to convene at least one
meeting a year.

In view of the growing importance of the ASF, it was decided at the 16th
Annual General Meeting in Korea in May 2007 that the permanent office for
the ASF should be set up and the location of the ASF office in Singapore.
After the ASF 2nd Chairmen’s Meeting held in July, the ASF opened its
office in November 2007. This office acts as a channel to convey Asian
Shipowners’ voices to the international shipping community as well as to
enhance and strengthen the ASF’s stature. At the same time, it is also a
platform for all ASF members to liaise with one another and to help
promote cooperation, amity and friendship amongst its members.

To better reflect the work and progress of its members and committees, it
was proposed at the 18th ASF Chairmen’s meeting held in Beijing, China,
on 19th October 2015 to have its name changed to Asian Shipowners’
Association (ASA). Subsequently at the 25th ASF AGM, it was officially
declared the change of name from ASF to ASA. The name change does not
alter the values and objectives that it delivers but will continue to further
enhance the work done by ASF.

INTERCARGO:

- The International Association of Dry Cargo Shipowners (INTERCARGO) is

representing the interests of quality dry cargo shipowners. INTERCARGO
convened for the first time in 1980 in London and has been participating
with consultative status at the International Maritime Organization (IMO)
since 1993.

Provides the forum where dry bulk shipowners, managers and operators
are informed about, discuss and share concerns on key topics and
regulatory challenges, especially in relation to safety, the environment and
operational excellence. The Association takes forward its Members’
 positions to the IMO, as well as to other shipping and international industry
fora, having free and fair competition as a principle.

INTERTANKO:

- INTERTANKO (the International Association of Independent Tanker

Owners) is a trade association that has served as the voice for independent
tanker owners since 1970, representing the interests of its Members at
national, regional and international levels.

The organisation champions an industry dedicated to support global

energy networks by delivering safe, efficient and environmentally sound
transport services.

INTERTANKO actively works on a wide range of operational, technical, legal

and commercial issues affecting tanker owners and operators around the
world. It draws on regular and direct contact with its Members and other
industry stakeholders to develop and disseminate information and best
practice, essential to the tanker industry.