1. The maritime Administration of Cyprus has issued Circular No.18/2021, dated 13th April 2021 providing information to assist ship owners/ managers meet the deadline for submission of emission data as required by MARPOL Annex VI / Regulation 22A – the ‘IMO-DCS Regulation’ and by the ‘EU-MRV Regulation’.
2. The deadline for the submission of aggregated data as per the IMO- DCS Regulation by a company (company means the owner/manager/bareboat charterer or other person or entity responsible for the operation of a ship) for ships under their management, is within three (3) months after the end of each calendar year, namely the 31st March of each year, for the previous year. The “Statement of Compliance – Fuel Oil Consumption Reporting” for the reporting period is to be issued two (2) months at the latest after the submission, i.e. by 31st May of each calendar year.
Accordingly, it is recommended that the aggregated data are submitted as early as possible after the ending of the reporting period, so that the data verification, the issuance of the “Statement of Compliance” and the submission thereof to the IMO’s database before the deadline of 31st May of each calendar year can be completed in time.
3. The deadline for the submission of the annual emissions data as per the EU-MRV Regulation by a company (company means the owner/manager/bareboat charterer or other person or entity responsible for the operation of a ship) for ships under their management for the previous year is the 30th April of each calendar year. The “Document of Compliance” is to be issued by the 30th June the latest.
Accordingly, it is recommended that the emissions data are submitted as early as possible after the ending of the reporting period, in order to allow the verifier sufficient time to check of the data and to issue the “Document of Compliance” before the deadline of 30th of June, of each calendar year.
4. Following is to be noted in order to comply with the requirements of the IMO-DCS Regulation.
a. In case of change of flag of the ship: In the event of transfer of a ship from one Administration to another, the ship shall on the day of completion of the transfer or as close as practical thereto, shall report to the losing Administration or any Recognised Organizations (RO), the aggregated data for the period of the calendar year corresponding to that Administration, as specified in appendix IX to MARPOL Annex VI.
b. In case of transfer of a ship from one management company to another: In the event of a change from one Company to another, the ship shall on the day of completion of the change or as close as practical thereto, report to its Administration or any Recognised Organizations (RO), the aggregated data for the portion of the calendar year corresponding to the Company.
c. In the event of change from one Administration to another and from one Company to another concurrently, above paragraphs ‘a’ and ‘b’ shall also apply.
5. In addition to the above the following is to be noted for the purposes of compliance with the requirements of the EU-MRV Regulation.
a. Where there is a change of a Company, the new company is to ensure that each ship under its responsibility complies with the requirements of this Regulation in relation to the entire reporting period during which it takes responsibility for the ship concerned. Therefore, the Company responsible for the ship on 31st of December is the one taking over the reporting responsibilities to compile year aggregated data for the entire reporting period, including the activities carried out while a ship was under the management of a previous Company.
b. By the 30th June of the year following the end of the reporting period, ships arriving at, within or departing from a port under the jurisdiction of a EU Member State, and which have carried out voyages during that reporting period, are required to carry on board a valid Document of Compliance demonstrating the submission of the required data, as per Art. 18 of the EU-MRV Regulation.
6. Further, the Administration has informed that there were several omissions which were reported by IMO and EU during the evaluation of data submitted for the year 2019, as follows:
a. When a ship changed owner and or manager, there was a failure of submission by the previous owner and/or manager of emissions data and other information required by Regulation for their period of the ownership / management, enabling the new owner and/ or manager to proceed with the submission to the RO or Verifier, and that the new owner/manager failed to request/ensure that the data are submitted to them.
b. There was a delay for the submission of reports to either the MRV verifier or the RO, as the case was applicable, thus resulting to delayed verification and issuance of the Document of Compliance /Statement of Compliance.
c. There was a high percentage or erroneous submissions which resulted to re-submission after amendments, and delay on the verification process and the issuance of the Document of Compliance /Statement of Compliance.
d. There was several cases when the ship’s type was reported to be different than the type of ships as listed in MARPOL Annex VI/Reg. 2, which resulted to the rejection of the submitted reports.
7. Ship owners/ operators and masters of Cyprus flagged ships are advised to be guided by above and ensure compliance.
This Technical Circular and the material contained in it is provided only for the purpose of supplying current information to the reader and not as an advice to be relied upon by any person. While we have taken utmost care to be as factual as possible, readers/ users are advised to verify the exact text and content of the Regulation from the original source/ issuing Authority.