International Convention for the Prevention of Pollution from Ships (MARPOL) Updates

To address concerns of the potential impact of a heavy fuel oil (HFO) spill on the Arctic environment, amendments to MARPOL Annex I were adopted to incorporate a prohibition on the use and carriage for use as fuel of HFO by ships in Arctic waters. Under the new Regulation 43A in MARPOL Annex I, the prohibited fuel oils are described as “oils, other than crude oils, having a density at 15 C higher than 900 kg/m 3 or a kinematic viscosity at 50 C higher than 180 mm 2 /s.” The use and carriage for use as a fuel of HFO would be prohibited in Arctic waters on and after 1 July 2024. 

For ships to which Regulation 12A of MARPOL Annex I (oil fuel tank protection) is applicable, this prohibition would be effective on and after 1 July 2029. Administrations with coastlines that border Arctic waters would have leeway to temporarily waive the requirements of this prohibition for vessels under their registry while operating in waters under the jurisdiction of that Administration, up until 1 July 2029, after which no such waivers may be issued. 

Effective Date: November 1, 2022

Source: MEPC.329(76)

To support enforcement of the IMO’s global limit on sulfur content in fuel oil use or carried for use on board vessels, several amendments to MARPOL Annex VI were adopted to facilitate fuel oil sampling and testing by port State authorities. The amendments will require the installation of dedicated sampling points on all new vessels, and existing vessels must install these sampling points by their first IAPP certificate renewal survey on or after April 1, 2023. 

This requirement will not apply to a fuel oil service system for a low flashpoint fuel for combustion purposes for propulsion or operation on board the ship.

Effective Date: April 1, 2022

Sources: MEPC.324(75), MEPC.1/Circular 889, and MEPC.1/Circular 864, Revision 1

In further developing the regulations related to the Energy Efficiency Design Index (EEDI), the IMO deemed it appropriate to accelerate Phase 3 of the development from 2025 to 2022. As a result, several amendments to the EEDI reduction factors tables were made to increase the reduction factors for specific ship types and sizes. 

Additionally, the IMO adopted a new regulation requiring Administrations and their recognized organizations to report the required and attained EEDI values for new and existing ships to the IMO. For existing ships, this reporting must be done by 1 November 2022. 

Amendments to the 2018 Guidelines on the Method of Calculation of the Attained Energy Efficiency Design Index (EEDI) for New Ships were also adopted. The amendments clarify the information about attained and required EEDI to be reported to the IMO for each ship and provide a standard format for reporting this information.

Effective Date: April 1, 2022

Source: MEPC.324(75) and MEPC.332(76)

New requirements have been adopted to introduce the Energy Efficiency Existing Ship Index (EEXI) to support the IMO’s goals for reducing greenhouse gases in shipping. Similar to the EEDI requirements for new vessels, specific types of existing vessels must establish a required EEXI value and demonstrate an attained EEXI value of equal or lesser value. 

An EEXI technical file must be approved for each vessel. Verification of a ship’s attained EEXI shall occur at the first IAPP annual, intermediate, or renewal survey, or at the first IAPP initial survey, whichever occurs first, on or after January 1, 2023. 

For ships subject to EEDI regulations, the attained EEDI may be taken as the attained EEXI if the value of the attained EEDI is equal to or less than the required EEXI.

Effective Date: November 1, 2022

Source: MEPC.328(76)

The IMO has adopted these guidance documents related to EEXI: 

• 2021 Guidelines on the Method of Calculation of the Attained Energy Efficiency Existing Ship Index (Resolution MEPC.333(76))
• 2021 Guidelines on Survey and Certification of the Attained Energy Efficiency Existing Ship Index (Resolution MEPC.334(76))
• 2021 Guidelines on the Shaft/Engine Power Limitation System to Comply with the EEXI Requirements and Use of a Power Reserve (Resolution MEPC.335(76))

Effective Date: November 1, 2022

Source: MEPC.333(76), MEPC.334(76), and MEPC.335(76)

New requirements have also been adopted to introduce the Carbon Intensity Indicator (CII) to support the IMO’s goals for reducing greenhouse gases in shipping. Specific types of new and existing vessels will be required to establish a required annual operational CII value for the vessel, and after the end of each calendar year (beginning with 2023), calculate an attained annual operational CII value. 

These values will be used each year to assign a CII rating of A (highest) through E (lowest). A ship rated as D for three consecutive years or rated as E must develop a plan of corrective actions to achieve the required annual operational CII. 

Effective Date: November 1, 2022 

Sources: MEPC.328(76)

The IMO has adopted these guidance documents related to CII (identified as CII Guidelines G1 through G4):

• G1: 2021 Guidelines on Operational Carbon Intensity Indicators and the Calculation Methods (Resolution MEPC.336(76))
• G2: 2021 Guidelines on the Reference Lines for Use with Operational Carbon Intensity Indicators (Resolution MEPC.337(76))
• G3: 2021 Guidelines on the Operational Carbon Intensity Reduction Factors Relative to Reference Lines (Resolution MEPC.338(76)) 
• G4: 2021 Guidelines on the Operational Carbon Intensity Rating of Ships (Resolution MEPC.339(76))  

Effective Date: November 1, 2022

Source: MEPC.336(76), MEPC.337(76), MEPC.338(76), and MEPC.339(76)