CH4 and N2O Emissions Measurement and Reporting

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Although carbon dioxide (CO₂) is the principal contributor to shipping's greenhouse gas (GHG) footprint according to the Fourth IMO GHG Study 2020, methane (CH₄) and nitrous oxide (N₂O) have significantly higher global warming potentials (GWPs).  Consequently, relatively small quantities of CH₄ and N₂O can substantially increase a vessel's overall GHG footprint when expressed as CO₂ equivalent (CO₂-eq). Reducing methane emissions, in particular, can be an effective means of lowering a vessel's total CO₂-eq emissions, improving compliance with existing and emerging environmental regulations, and enhancing the long-term viability and competitiveness of methane-based marine fuels.

The growing uptake of liquefied natural gas (LNG) as fuel has brought increased attention to onboard methane emissions, particularly methane slip from internal combustion engines. While methane-based fuels can deliver substantial reductions in carbon dioxide emissions compared with conventional marine fuels, methane slip may offset part of these climate benefits because methane is a potent greenhouse gas.

At the international level, there are currently no mandatory IMO requirements for monitoring or reporting CH₄ and N₂O emissions under existing short-term GHG measures. However, future IMO mid-term measures are expected to address all major greenhouse gases, including CO₂, CH₄ and N₂O. In parallel, the European Union has already incorporated CH₄ and N₂O emissions into its maritime regulatory framework, including the EU Monitoring, Reporting and Verification (MRV) Regulation, the EU Emissions Trading System (EU ETS) and FuelEU Maritime.

To support more accurate emissions accounting, the European Commission has adopted guidelines permitting the use of verified actual methane slip values in place of default methane emission factors under FuelEU Maritime and the EU ETS. In addition, the IMO has recently adopted new guidelines for test-bed and onboard measurement of CH₄ and N₂O emissions, together with methodologies for engine load monitoring (ELM) and continuous emissions monitoring systems (CEMS). These developments provide operators with pathways to demonstrate actual engine performance, potentially reducing compliance costs where verified emissions are lower than default values and encouraging continued improvements in engine technology, monitoring and operational practices.

Industry experience to date indicates strong operator interest in demonstrating actual methane slip values, particularly for low-pressure LNG engine technologies where default factors may significantly overstate emissions and inflate compliance costs. Engine manufacturers have generally been supportive in providing the measurement data required to establish CH₄ Technical Files, and several test-bed programs for medium-speed four-stroke dual-fuel and spark-ignited gas engine platforms are underway, with completion targeted across 2026–2027. Operators of LNG-fueled fleets — including LNG carriers and cruise vessels equipped with dual-fuel diesel-electric (DFDE) propulsion — are paying considerable attention to actual methane slip certification as a means of reducing FuelEU Maritime and EU ETS compliance exposure.

At the 80th session of the Marine Environment Protection Committee (MEPC 80), Member States of the International Maritime Organization (IMO) adopted the 2023 IMO Strategy on Reduction of GHG Emissions from Ships, updating the Initial GHG Strategy. The 2023 IMO GHG Strategy sets an enhanced ambition to reach net-zero GHG emissions from international shipping by or around 2050, with indicative checkpoints for 2030 and 2040. To support this objective, the Strategy envisages the development of mid-term GHG reduction measures building on previously adopted short-term measures.

At present, there are no mandatory requirements for monitoring or reporting methane (CH4) and nitrous oxide (N2O) emissions under the existing short-term measures, i.e. IMO EEDI/EEXI, SEEMP, DCS and CII. However, such requirements are expected to be introduced as part of future mid-term measures, including a GHG Fuel Intensity (GFI) metric, supported by IMO’s life cycle assessment (LCA) framework. The 2024 LCA Guidelines (resolution MEPC.391(81)) provide default emission factors for CH4 and N2O, including default methane slip by engine type, while also allowing the use of actual emission factors subject to the development of relevant procedures for verification and certification.

Although adoption of the mid-term measures was originally planned at an extraordinary session in 2025 (MEPC.ES/2), that meeting was adjourned for one year to allow additional time for deliberations. Consideration of the measures is expected to continue at MEPC 85 (December 2026), supported by further discussions at intersessional meetings of the Intersessional Working Group on Reduction of GHG Emissions from Ships (ISWG-GHG). Should mid-term measures be adopted under the tacit acceptance procedure, they would enter into force 16 months thereafter (i.e. at the earliest in 2028).

To calculate the GHG emissions as CO2-eq, the 2024 LCA Guidelines use the global warming potential (GWP) over a 100-year time-horizon, as given in the Intergovernmental Panel on Climate Change (IPCC) Fifth Assessment Report (AR5).

GHG

GWP

CO2

1

CH4

28

N2O

265

 

Default methane slip factors under 2024 LCA Guidelines

Engine type

Methane slip (% of consumed fuel)

LNG Otto (dual fuel, medium speed)

3.5%

LNG Otto (dual fuel, slow speed)

1.7%

LNG Diesel (dual fuel, slow speed)

0.15%

LBSI (lean-burn spark ignition)

2.6%

Steam turbines and boilers

0.01%

 

The difference between default and actual methane slip values can be significant, particularly for medium-speed four-stroke dual-fuel engines, where the default factor of 3.5% may substantially exceed measured performance. Engine manufacturers have indicated that actual methane slip for the latest engine designs — incorporating technologies such as variable compression ratio (VCR) and intelligent combustion emission reduction (iCER) — can be 50–80% lower than default values. For high-pressure, diesel-cycle gas injection engines (e.g. two-stroke ME-GI type), the default slip of 0.15% is already relatively low, meaning the potential benefit of testing and certification is more limited.

At MEPC 84, the Committee agreed that, without prejudice to any future mandatory framework, actual Tank-to-Wake (TtW) emission values for CH4 and/or N2O may be quantified on a voluntary basis using the following approaches:

  1. Engine load monitoring, in accordance with the ELM Guidelines, in conjunction with the 2026 Guidelines for test-bed and onboard measurements of CH4 and/or N2O emissions from marine diesel engines; and/or 
  2. A continuous emissions monitoring system (CEMS), in accordance with the CEMS Guidelines.

 

Test-bed or onboard measurements

At MEPC 83, the Guidelines adopted through resolution MEPC.402(83) established a protocol for measurements, calculation and reporting of CH4 and/or N2O emission values from marine diesel engines, including documentation and verification requirements.

At MEPC 84, the 2026 Guidelines were adopted through resolution MEPC.414(84), superseding MEPC.402(83). Further details on this revision are provided in the ABS MEPC 84 Brief.

Measurements, calculations and reporting for CH4 and/or N2O emission values should be carried out in accordance with the NOx Technical Code 2008 (NTC 2008), as amended, except as specifically provided in the protocol set out in appendix 1 to MEPC.414(84).

Emission measurements should be carried out at the mode points specified in the relevant test cycles under the NTC 2008. For test cycles E2 and E3, emissions at the 10% mode point or the lowest mode point at which gas fuel would be used should be measured and reported in addition to the existing mode points.

Measurement Location

Individual Engine

Engine Group represented by the Parent Engine

Engine Family represented by the Parent Engine

Test-bed

 Accepted

 Accepted

Accepted

Onboard

 Accepted

 Accepted

Not accepted without further justification

 

Required content of the CH4 and/or N2O file

The applicant for the establishment of the emission values should prepare a CH4 and/or N2O file containing the items specified in Section 2 of MEPC.414(84), which are summarized below.

Resolution MEPC.414(84) refers to the "Applicant" as the party that may establish the CH₄ Technical File; therefore, it does not have to be the OEM. In practice, however, the Applicant would need to work closely with the engine OEM, since data from the NOₓ testing and the engine's NOₓ Technical File — which are typically considered the OEM's intellectual property — would be required. Arranging separate onboard testing without OEM cooperation would likely be very costly.

 

Use of existing measurement data

Measurements conducted prior to the adoption of these Guidelines may be accepted, provided that they were carried out in accordance with the NTC 2008.

Where CH₄ measurements are not available, emission values for total hydrocarbons (HC), as set out in the engine's NOₓ technical file, may be used as a proxy.

  • The CH₄ emission values may be established based on the weighted percentage of methane in the gas fuel.
  • Where the fuel composition is not available in the engine's NOₓ technical file, total HC emissions should conservatively be assumed to consist of 100% CH₄.
  • Where existing E2 data lack the 10% load point (or lowest gas-fuel mode point), D2 data from the same Parent Engine may be considered representative, provided the Parent Engine is certified for both test cycles and operates with identical settings.

Verification of the CH4 and/or N2O emission values

To confirm that the emission values have been established in accordance with these Guidelines, the CH4 and/or N2O file should be submitted to the Administration for verification. Upon satisfactory review, a Statement of emission values for CH4 and/or N2O will be issued.

 

Engine load monitoring

The Guidelines adopted by resolution MEPC.415(84) specify a method for engine load monitoring (ELM) to derive emission factors reflecting the actual operation of the engine.

ELM may be used in place of pre-defined weighting factors specified in section 3.2 of the NTC 2008. It should be combined with verified CH4 and/or N2O emission measurements to derive representative emission values. The Guidelines provide a procedure for calculating the methane slip value for the entire year.

 

Emission values at different engine loads

Emission values at different engine loads are derived from the verified CH4 and/or N2O emission values established in accordance with resolution MEPC.415(84), as follows:

  • Between measured points, the emission values should be calculated by linear interpolation.
  • For engine loads below the lowest measured load point, the emission value at the 10% load point (or the lowest gas-fuel mode point) should be used.
  • For loads above the highest measured load point, the emission value at the highest measured load point should be used.

 

Load monitoring

Engine load should be continuously monitored and may be:

  • Measured from torque flange, shaft strain gauge or calculated from the generator output; or
  • Estimated indirectly (e.g. cylinder pressure or injection duration), subject to Administration approval.

Measurement equipment should meet the requirements of appendix IV (tables 3 and 4) of the NTC 2008 and be calibrated per manufacturer's recommendations.

Engine load should be continuously monitored and recorded at a frequency of not less than 0.0035 Hz. Load should be averaged over 30-minute intervals, or another period approved by the Administration. Zero-load and liquid-fuel-only operation must be excluded from the averaging.

The monitoring method, data-collection procedure, annual load monitoring data and corresponding emission calculations should be approved by the Administration.

 

Calculations

Two options are provided in the ELM Guidelines for calculating annual emission values (g/g fuel):

Option A: If a fuel flow measurement device is installed (example shown below).

 

 

Option B: If no fuel flow measurement device is installed (example shown below).

 

Engine Load Monitoring (ELM) is emerging as a practical solution because it allows measured methane emissions to be weighted against the vessel's actual operating profile rather than relying solely on standard test-cycle assumptions. This is particularly relevant for vessels with variable load profiles, such as LNG carriers and cruise vessels.

Approval and verification

The monitoring method, data collection procedures and annual load monitoring data and corresponding emission calculations should be approved by the Administration or an RO.

 

Continuous emission monitoring system

The Guidelines adopted by resolution MEPC.416(84) establish a framework for the onboard measurement and mass-based quantification of CH4 and/or N2O emissions using continuous emissions monitoring systems (CEMS).

The Guidelines also include:

  • Requirements for data recording and storage.
  • Documentation requirements, including:
    • An Administration approved CEMS file detailing the system and the operating procedures to be followed together with related requirements covering the functionality of the CEMS and verification that the data generated is reliable.
    • A CEMS record book detailing maintenance, servicing and fault resolution activities.

A framework for the certification of a CEMS by the Administration, including initial and annual survey requirements.

The European Union has established a comprehensive regulatory framework governing greenhouse gas (GHG) emissions from maritime transport, integrating requirements under the EU MRV Regulation, the EU Emissions Trading System (ETS) and FuelEU Maritime. Collectively, these instruments introduce lifecycle (well-to-wake) emissions accounting, the use of verified actual emission factors — including methane slip (CH₄) — and broader provisions for alternative fuels.

 

 

Regulatory Architecture

The EU maritime GHG framework rests on three instruments:

EU MRV and EU ETS — Monitoring, reporting, verification and pricing of CO₂, CH₄ and N₂O emissions. The emissions are aggregated using 100-year GWP. The applicable GWP values are set out in Commission Delegated Regulation (EU) 2020/1044, which references the IPCC Fifth Assessment Report (AR5).

FuelEU Maritime — GHG intensity limits assessed on a well-to-wake (WtW) basis, combining upstream fuel production (well-to-tank (WtT)) and onboard combustion (tank-to-wake (TtW)) emissions. The GWP values are based on the Renewable Energy Directive (RED) (Directive (EU) 2018/2001), which aligns with the IPCC AR4, although alignment with the IPCC AR5 is expected via future amendments to the RED.

 

Emission

GWP under EU MRV/ETS (AR5)

GWP under FuelEU (AR4)

CO₂

1

1

CH₄

28

25

N₂O

265

298

 

Default emission factors prescribed in EU MRV Annex I (Regulation (EU) 2015/757) and FuelEU Annex II (Regulation (EU) 2023/1805) remain the regulatory baseline. Where data gaps exist, the framework mandates conservative assumptions - that the highest emission value within a fuel class and the least favourable fossil fuel pathway, ensuring environmental integrity but potentially penalizing operators whose actual performance is better than the defaults.

 

 

Companies may diverge from the default emission factors as follows:

  • Actual TtW emission factors may be used, except for CO₂ for fossil fuels, where certified by laboratory testing or direct emissions measurements, under Articles 10 (5) and (6) Regulation (EU) 2023/1805.
  • Actual WtT emission factors may be used, except for fossil fuels, provided they are certified in accordance with the Renewable Energy Directive (RED) (Directive (EU) 2018/2001) or Gas and Hydrogen Directive (Directive (EU) 2024/1788) by a scheme that is recognized by the European Commission (EC). A list of the voluntary and national certification schemes recognized by the EC is available here.

 

Methane Slip Framework

In October 2025, the European Commission adopted Guidelines that enable Companies to replace default CH₄ factors with verified actual methane slip values (Cslip) for the purposes of FuelEU Maritime and EU ETS. The EC Guidelines combine the IMO measurement protocol of resolution MEPC.402(83) with an interim procedure for engine load monitoring (ELM), pending establishment and incorporation of international standards into the EU framework.

Although MEPC 84 (May 2026) adopted updated IMO Guidelines — MEPC.414(84) for test-bed/onboard measurement, MEPC.415(84) for ELM and MEPC.416(84) for CEMS — superseding MEPC.402(83), these have not yet been incorporated into the EU framework. Therefore, the EC Guidelines continue to reference MEPC.402(83) on an interim basis. Companies seeking to use actual methane slip values under EU regulations should ensure their measurement protocols align with the EC Guidelines' current references until the EU framework is updated.

Measurement: Test-bed or onboard measurements should be carried out in accordance with resolution MEPC.402(83) and include the 10% or lowest mode point at which gas fuel would be used. Total hydrocarbon (THC) measurements may substitute for direct CH₄ measurement per IMO procedures.

Table: MEPC.402(83) Test Protocols

Measurement Location

Individual Engine

Engine Group

Engine Family

Test-bed

 Accepted

 Accepted

Accepted

Onboard

 Accepted

 Accepted

Not accepted without further justification

 

Engine load monitoring: Continuous load data is used to weight emission measurements across the vessel's operational profile, transitioning from static default factors to operationally representative values.

Calculation: Two approaches are permitted—a method based on gas fuel flow measurement (methane slip as % of fuel consumption) and a method based on engine power output (g/kWh emission factor)—both relying on IMO-compliant measurement data.

Documentation Requirements

To be able to apply the actual TtW methane slip emissions factors, the Company needs to provide the following documentation.

 

Initial Verification

The Methane File should be prepared jointly by the Engine Manufacturer and the Company and submitted to the flag Administration or a Recognized Organization (RO) for approval. The MRV/FuelEU Monitoring Plan should be updated and submitted to the MRV/FuelEU Verifier for assessment.

The use of actual methane slip values for the reporting period is subject to the following conditions being met:

  • Measurements completed before the end of the reporting period.
  • No changes to components, settings or operational values that could impact the slip.
  • Engine load monitoring procedures are in place from the beginning of the reporting period.

If any condition is not met, the actual emission factor can only be considered from the date when all conditions are satisfied.

Yearly Verification

Annual verification includes assessment of load monitoring data, emission calculations and supporting documentation within the FuelEU and ETS compliance cycles. Failure to meet any condition results in reversion to default emission factors.

The following information is to be submitted in the emissions/FuelEU Report and verified by the MRV/FuelEU verifier.

  • Load monitoring data and emission calculation as per Annex I of the EC Guidelines
  • Results of the verification procedure to establish the validity of the methane test cycles either through parameter check or onboard measurement
  • Engines with abatement systems are to provide an updated maintenance record book before the end of the reporting period.

 

A detailed analysis of the European Commission Guidelines on actual methane slip factors is presented in ABS Regulatory News No. 17/2025.

References