According to Lloyd’s Register, from 1 January 2024, maritime emissions will be included in the European Union Emissions Trading System (EU ETS). This means the acquiring and surrender of emission allowances for ships over 5,000GT that call at a port or anchorage within the European Economic Area (EEA – EU plus Norway and Iceland).

This news is relevant to all shipowners, ship operators and ship managers.

This new requirement is part of the European Commission’s “Fit for 55” package for ships, which in 2023 has revised the EU Monitoring Reporting and Verification (MRV) Regulation (Regulation EU 2015/757) and now includes shipping in the Emissions Trading Scheme (ETS) Directive (Directive (EU) 2003/87).

Deadlines for compliance
Requirements for MRV and ETS compliance start on 1 January 2024. MRV Monitoring Plans need to be updated and assessed by accredited verifiers, ahead of submission to Administering Authorities, by 1 April 2024.

While the implementing and delegated acts supporting the MRV Regulation and ETS Directive are expected to be published at the end of 2023 or beginning of 2024, action needs to be taken now.

Key steps and recommendations By end of 2023:
Shipowners/ship managers/charterers should have agreed on the responsible entity for both ETS and MRV obligations. If a shipowner decides to delegate the responsibility, there must be a contractual arrangement in place that can be shared with the relevant verifiers and AA upon request.

Lloyd’s Register (LR) Recommendation: Decisions on responsible entities for compliance with MRV and ETS should be decided now. The designated entity responsible for compliance should be the same for both ETS and MRV. Contracts specifying responsibility should be negotiated and in place ahead of MP assessment by verifiers. 

From October 2023: 
Shipowners and ship managers must prepare the MP according to the pending revised Implementing Regulation (EU) 2016/1927 Annex I – MP Templates. Shipowners and ship managers with ships that have a MP already in place must have it updated, adding in the newly required additional information.

LR Recommendation: The contractually designated party responsible for MRV and ETS compliance should look at the draft MP requirements now and start compiling the appropriate information based on the draft MP template. 

By January 2024 (or when the official MP template is available):
Shipowners/ship managers/charterers should send the ship’s MP to LR for assessment*. LR clients must submit this through Emissions Verifier, which allows the assessed MP to be exported via an .xml file and imported into THETIS-MRV.

LR Recommendation: To help ensure that assessment is complete ahead of the 1 April 2024 submission deadline, all information should be uploaded to Emissions Verifier no later than a month after the official publication of the MP template. Should document upload be made after this date, LR cannot guarantee that the MP assessment will be completed in time for the 1 April 2024 submission deadline to the AAs. 

From January 2024 (or when the updated THETIS-MRV module is available): 
Shipowners/ship managers/charterers need to update ship MP information in the THETIS-MRV platform. The THETIS-MRV currently lacks additional fields for the updated MP requirements, but this expanded functionality is expected to be available in January 2024.

From January 2024: 
Shipowners/ship managers/charterers need to prepare and submit ship level emission reports to LR for verification. This should cover CO2 emissions only, as per the MRV requirements from Regulation EU 2015/757 as published April 2015, based on data collected in 2023.

From 1 January to 31 December 2024: 
At the ship level, shipowners/ship managers/charterers  must start monitoring voyages, fuel consumption, emissions and, at the end of the first monitoring period, start preparing the ship Emissions Report (ER).

By 1 February 2024: 
The European Commission will publish the first Administering Authority (AA) list (to be updated every two years), indicating the EU Member State that will be the attributed AA for each shipping company. If a company is not on the list (e.g. a new company), the shipping company will have to register for THETIS-MRV with the THETIS-MRV helpdesk who will be able to assist in assigning ships to an AA. The company will then be added to the list at its next update.

It is expected that companies will be able to open a Union Registry Account and Maritime Operator Holding Accounts in 2024 after publication of the list of responsible AAs. This Holding Account will be key to enabling EU allowances to be purchased and surrendered in compliance with the EU ETS. For more information, see FAQ – Maritime transport in EU Emissions Trading System (ETS) (europa.eu).

Before 1 April 2024: 
Shipowners/ship managers/charterers need to submit the MP assessed by LR to the AA via THETIS.

Before 31 March 2025 and every year thereafter: 
LR needs to verify the submitted ERs at ship and company level. As part of this verification, each company, and possibly the ship, will receive a physical site visit at least once every four years. Site visits in intervening years may be virtual or waived (if conditions allow), but may not be waived for three consecutive periods. This ER verification, including site visit, must be completed ahead of the 31 March submission deadline.

By 31 March 2025 and every year thereafter: 
Shipowners/ship managers/charterers need to submit the verified ER to the AA.

1 month before 31 March 2025 and every year thereafter: 
Shipowners/ship managers/charterers need to prepare and submit ship and company level emission reports to the verifier for assessment.

By 6 June 2025: 
Administering authorities will approve the MP submitted by 1 April 2024 for compliance with EU 2015/757 MRV requirements.

By 30 September 2025 and every year thereafter:  
Shipowners/ship managers/charterers or shipping companies are to surrender sufficient EU allowances to cover the verified emissions as per the verified ER data at company level. This should all be completed through a Union Registry Account.

Read Here
	Issue 87 of Robban Assafina (Sept./ Oct. 2023)