UK Monitoring, Reporting, Verification (MRV)

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ABS keeps you up to date with the most recent and upcoming United Kingdom regulations. Contact us today and let us help you prepare your fleet for compliance.

On January 31, 2020, the United Kingdom (U.K.) left the European Union (EU). A transitional phase lasted until December 31, 2020, during which EU laws remained in effect in the U.K. Following that period, the U.K. established a new dynamic with the EU, governed by the ‘EU-UK Trade and Cooperation Agreement’.

On July 16, 2020, the European Commission released a notice detailing the impact of the U.K.’s exit from the EU, and particularly how this will affect the EU monitoring, reporting and verification of emissions data for shipping. The notice highlighted that beginning in 2021:

·       The U.K. would no longer be subject to Regulation (EU) 2015/757, which governs the monitoring, reporting and verification (MRV) of carbon dioxide (CO2) emissions from maritime transport.

·       After the end of the transition period, emissions released within ports under the jurisdiction of the U.K. or from voyages from a U.K. port to a third-country port and vice-versa should no longer be reported under the EU MRV.

Given that the U.K. is no longer part of the EU MRV regime, it has transposed the EU legislation into U.K. law by SI 2018/1388 to create its own UK MRV regime, designed to monitor, report and verify emissions data from ships visiting U.K. ports.

 

Since January 1, 2022, ships over 5,000 gross tonnage (gt), transporting cargo and/or passengers for commercial purposes to and from U.K. ports, between U.K. ports or within U.K. ports (including while at berth), are subject to the UK MRV regime. Vessel types excluded from the regulation include warships, naval auxiliaries, fish-catching or fish-processing ships, wooden ships of a primitive build, ships not propelled by mechanical means or government ships used for non-commercial purposes.

To avoid duplication, data for voyages between U.K. and European Economic Area (EEA) ports and vice versa should not be reported under the UK MRV regime. Data on these voyages should continue to be submitted to the European Commission under the EU MRV regime.

The EU MRV framework has recently been expanded to cover voyages by offshore vessels undertaken for crew relief purposes. In contrast, the UK MRV currently applies only to ships engaged in the commercial transport of cargo or passengers, meaning that such crew relief activities by offshore vessels fall outside its scope. Nevertheless, offshore vessels that perform voyages for the commercial transport of cargo and passengers fall within the UK MRV’s scope.

The U.K. has issued MIN 669 on Reporting Emissions Data into the UK MRV regime, which provides guidance on reporting requirements, and MGN 662, which provides templates for the UK MRV regime.

Shipping operators should be collecting emissions data for their ships under the UK MRV regime from January 1, 2022, in accordance with an assessed UK MRV monitoring plan.

The UK MRV monitoring plan must be assessed by the verifier. Ships calling at U.K. ports, which do not currently have a monitoring plan, should have a plan in place without undue delay and no later than two months after each ship’s first fall in a U.K. port.

Ship operators with a monitoring plan compliant with the EU MRV framework can adapt and use the same plan, making adjustments as needed for both the EU and UK MRV frameworks. For example, a modification might be needed to indicate which voyages will be reported under the UK MRV regime through an addendum.

The type of data and parameters that need to be monitored on a per-voyage basis under the UK MRV regime include:

·       Port of departure and port of arrival, including the date and hour of departure and arrival

·       Amount and emission factor for each type of fuel consumed in total

·       Emitted CO2

·       Distance travelled

·       Time spent at sea

·       Cargo carried

·       Transport work

Under current requirements, the only emissions data that need to be reported under the UK MRV regime are for the following voyages:

·       Voyages between two U.K. ports

·       Voyages between a U.K. and a non-EEA port

·       Emissions generated at a U.K. port for the above voyages and when at berth at a U.K. port on voyages between U.K. and EEA ports.

Voyages between a U.K. port and a port in one of the U.K. Overseas Territories or Crown Dependencies, such as the Falkland Islands, Gibraltar, Isle of Man or Jersey, must be monitored and reported under the UK MRV regime. However, ports in these Overseas Territories and Crown Dependencies do not count as U.K. ports under the UK MRV regime. Consequently, voyages between two Crown Dependencies or Overseas Territories, such as between Jersey and Guernsey, should not be included. Similarly, a voyage from a port in an Overseas Territory or Crown Dependency to a port outside the U.K. is also not covered.

The monitoring and reporting data shall be accounted for under the first calendar year involved for voyages that start and end in different calendar years. Additionally, if a vessel changes ownership during a reporting period, it is the responsibility of the acquiring company to obtain all necessary information and emissions data from the selling company as soon as possible. This ensures that the acquiring company can submit a complete emissions report at the end of the reporting period.

Biofuels Treatment

Appropriate emission factors should be used for biofuels, alternative non-fossil fuels and other fuels that lack predefined values. Following the principles of the Directive (EU) 2018/2001, Annex V, Part C, Item 13, biofuels and bioliquids that are certified as sustainable shall be assigned to a zero CO2 emission factor.

Special attention should be given to biofuel blends. Unlike the EU MRV requirements, which mandate reporting each component of a biofuel blend separately, the UK MRV regime stipulates that the CO2 emission factor for the blend should be calculated as a mass-weighted average of the emission factors of the individual fuels. For example, in the case of a B30 heavy fuel oil (HFO) blend (30 percent fatty acid methyl ester (FAME) and 70 percent HFO), the CO2 emission factor should be equal to:

By January 1, 2022, to December 31, 2022, and each following year:

·       Start collecting data required under the UK MRV regime for the first recording period (e.g., January 1, 2022, to December 31, 2022), following the procedures established in the monitoring plan. To reduce complexity and save significant time for operators, the ABS Emissions Reporter Portal will verify the client’s submitted data and create three verified reports for IMO DCS, UK MRV and EU MRV, as applicable.

By February 15, 2023, and each following year:

·       Submit the emissions report for the preceding year to the accredited verifier for verification.

By April 30, 2023, and each following year:

·       Retain a verified emissions report covering the preceding reporting period.

·       The U.K. no longer has access to the THETIS-MRV database but is developing one that can receive MRV data. The U.K. has taken a decision to delay the requirement for ship operators to report emissions until the digital solution is fully operational.

·       The legal requirement for ship operators to monitor vessel emissions remains in place. Only the reporting requirements are delayed. Data from intervening years will be submitted once the new system is ready.

By June 30, 2023, and each following year:

·       Ensure that the U.K. Document of Compliance (DoC), confirming that a validated emissions report for voyages between U.K. ports, between U.K. ports and non-EEA ports and vice versa was submitted for the previous reporting period, is available on board. Please note that until the digital solution is in place and ship operators can report their emissions, ship operators are not required to carry a valid DoC for any ships subject to the UK MRV in the previous reporting period. No enforcement action will be taken by the U.K. Marine and Coastguard Agency (MCA).

·       Once the digital solution is in place, a separate U.K. DoC will be needed to confirm that a validated emissions report for voyages between U.K. ports, between U.K. ports and non-EEA ports and vice versa was submitted for each reporting period from 2022 onward.

Easy-to-use IMO DCS and UK MRV Reporting 

The ABS Emissions Reporter™ is a smart digital tool that allows owners and operators to input annual reports and monitor the status of their IMO Data Collection System (DCS)EU Monitoring Reporting and Verification (MRV) and UK MRV review process.