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• IMO Marine Environment Protection Committee (MEPC) at its 70th session adopted amendments to MARPOL Annex VI vide MEPC Resolution 278(70), regarding a data collection system for fuel consumption of ships. A new regulation 22A is included in MARPOL Annex VI Ch.4 on “Collection and reporting of ship fuel oil consumption data”.

• As per the new regulation, each ship of 5,000 GT and above on international voyages are required to develop a Data Collection Plan (SEEMP Part II based on Guidelines given in MEPC 282(70)) that includes a description of the methodologies which will be used to collect the data and the processes that will be used to report the data to the vessel’s Administration or RO. Upon satisfactory review of SEEMP, Confirmation of Compliance will be issued to the vessel.

• From 1st January 2019, vessels are required to collect data of fuel oil consumption as per reviewed SEEMP.

• The aggregated value of the data for each calendar year will have to be reported within three months after the end of each calendar year, to ship’s Administration or RO. Upon receipt of reported data, the Administration or RO will verify that it is in compliance with regulation 22A and issue a Statement of Compliance (SOC).

• Upon verification of reported data and issuance of SOC, the data will be transferred to the IMO Ship Fuel Consumption Database. 

• DG shipping, India has provided its requirements for implementation of above amendments to MARPOL Annex VI Ch. 4, vide Engineering Circular No. 02 of 2018.

• Calendar year considered in this circular is from Noon of 31st December 2018 to Noon of 31st December 2019 and so on thereafter.

• All ships registered under M.S. act 1958 (except FPSO, FSU, drilling rigs and ships not propelled by mechanical means) are required to comply with the circular and applicable requirements differ based on vessel category i.e.
  Vessels of 5000GT and above

• The specific requirements for each category are detailed as below:

⦁ Vessels of 5000 GT and above
⦁ Vessels of 5000GT and above certified in accordance with RSV Notification (DGS Order 18 of 2013) or Indian Coastal Vessel Notification (DGS Order 1 of 2014)
⦁ Vessels less than 5000GT

a. Vessels of 5000 GT and above:

i. Ship Energy Efficiency Management Plan

Companies are required to submit Part II of SEEMP to a Recognized Organization for review by 30th September 2018.

RO will review the Part II of SEEMP to ensure compliance with regulation 22.2 of MARPOL Annex VI by 30th November 2018 and will issue Confirmation of Compliance on satisfactory review.

Reviewed SEEMP along with Confirmation of Compliance to be placed on new ships on/before the date of delivery and for second-hand take over ships registered under Indian Flag at the time of issuance of first statutory surveys (interim or full term, whichever is issued first).

ii. Data Collection and Submission

By 29th February 2020 and 28th/29th February of each calendar year thereafter: Company to aggregate the collected fuel oil consumption and other relevant data as detailed in Regulation 22A of Chapter 4 of MARPOL Annex VI for each ship and submit the same to Recognized Organization which has reviewed the SEEMP.

iii. Verification of the reported data by the Administration or RO, and issuance of Statement of Compliance:

By 30th April 2020 and by 30th April of each calendar year thereafter - Upon receipt of data, the Recognized Organization will verify the submitted data taking into account Resolution MEPC 292(71): 2017 (Guidelines for Administration verification of ship fuel oil consumption data).

After satisfactory completion of the verification, the Recognized Organisation will issue a Statement of Compliance – Fuel Oil Consumption Reporting (for each ship for which the data is reported and verified) valid till 31st May of the calendar year next to the data reporting year (next to next of data collecting calendar year)

iv. Submission of verified data to Indian Register of Shipping

Company is responsible to submit the verified data to IRS; by 31st May 2020 and 31st May of every calendar year thereafter, for each ship in an extensible mark-up language (XML) format along with a copy of Statement of Compliance issued by the Recognized Organization. IRS will acknowledge receipt of data to the reporting Company identifying the ships for which data have been received.

v. Submission of verified data to IMO Fuel Oil Consumption

Database IRS will submit the data by 30th June every year to IMO fuel oil consumption database on behalf of administration and submit compliance report to the Directorate.

b. Vessels of 5000 GT and above certified in accordance with RSV Notification or Indian Coastal Vessel Notification

i. There is no requirement for review of revised SEEMP by Recognized Organizations. However, SEEMP to be revised to include the data collection and submission methodology in accordance with Regulation 22A which will be verified at first IAPP Annual/Intermediate/Renewal Survey after 1st January 2019. For new ships/second hand ships coming to Indian Flag revised SEEMP is to be available at the time of issuance of first interim/full term IAPP Certificate on behalf of Indian Flag.

ii. The Company shall submit requisite fuel consumption (for each Indian ship managed by the Company) and other relevant data in the standardized format detailed in MEPC 282(70) to IRS by 30th April 2020 for the calendar year 2019 and thereafter on 30th April of each calendar year for the previous calendar year.

iii. IRS will verify the accuracy of the submitted data in accordance with Resolution MEPC 292(71): Guidelines for Administration verification of ship fuel oil consumption data.

iv. A Statutory Memo to be complied by 30th April 2020 is to be inserted in the Class Status of each ship. After receipt of relevant data, IRS will issue a confirmation of receipt of the data to the Company of the ship for submission of the same to the Classification Society of the vessel, so that Statutory Memo compliance date can be extended to 30th April of the next calendar year and so on.

c. Vessels less than 5000 GT

There is no requirement for availability or approval of a revised Ship Energy Efficiency Management Plan.

Company is required to submit following data to IRS in a standardized format by 30th April 2020 and 30th April of every Calendar Year thereafter:

⦁ Name of the Ship

⦁ IMO No./Official No.

⦁ Type of Ship

⦁ GT, Deadweight, NT

⦁ Total Fuel Consumption (All types of Fuel)

⦁ Rated Power of Main and Auxiliary Engine in KW.

⦁ Whether the particular is supplied with Shore Electric Power during port stay.

A Statutory Memo to be complied by 30th April 2020 is to be inserted in the Class Status of each ship. After receipt of above data, IRS will issue a confirmation of compliance to this circular to the Shipping Company for submission of the same to the ship Classification Society, so that Statutory Memo compliance date can be extended to 30th April of the next Calendar Year and so on

• Specific requirements during Change of Flag and / or Company are as below:

i. Change of Flag/Demolition (from India to a Foreign Flag for ships of 5000GT and above):

a. Company is required to submit fuel consumption data and other relevant data till the date of completion of transfer/demolition to the Recognized Organization which has reviewed the revised SEEMP.

b. RO will verify the data for compliance to the circular and issue Statement of Compliance – Fuel Oil Consumption Reporting.

c. This Statement of Compliance – Fuel Oil Consumption reporting received from RO is to be submitted by company to IRS along with data in requisite format. IRS will endorse a copy of Statement of Compliance – Fuel Oil Consumption Reporting after receiving the data.

d. Registrar of the vessel to ensure that above Statement of Compliance – Fuel Oil Consumption reporting endorsed by IRS is available prior issuing Registry deletion certificate.

ii. Change of Flag/Demolition (from India to a Foreign Flag for ships of 5000GT and above certified as per RSV or Indian Coastal Vessel Notification and Ships less than 5000GT):

a. Company is required to submit fuel consumption data till the day of completion of transfer/demolition to IRS in the format required by the circular.

b. IRS will verify the data for compliance to the circular and issue a confirmation of receipt of data.

c. Registrar of the vessel to ensure that above confirmation of receipt of data issued by IRS is available prior issuing Registry deletion certificate.

iii. Change of Company without Change of Registered Owner and Flag (Ships of 5000GT and above):

a. The previous Company is required to submit the requisite data (till the date of completion of transfer) in the format required by this circular to the Recognized Organization which has reviewed the revised SEEMP.

b. Upon satisfactory completion of verification of the data RO to issue Statement of Compliance- Fuel Oil Consumption Reporting valid till 31st May of next calendar year.

c. A copy of Statement of Compliance – Fuel Oil Consumption Reporting along with data in the requisite format is to be submitted to IRS by the previous company within 15 days of date of completion of transfer for onward submission of the data to IMO.

iv. Change of Company without Change of Registered Owner and Flag (Ships of 5000GT and above certified as per RSV or Indian Coastal Vessel Notification and Vessels less than 5000GT):

a. Previous Company to submit fuel consumption and other requisite data till the date of completion of transfer to IRS in the requisite format to the new company.

b. New Company to submit the consolidated data for the calendar year to IRS in accordance with the requirements of this circular.

• Compliance with the above requirements will be verified by the administration’s surveyor during the ISM audit and flag state inspection or statutory survey of the vessel.

• Ship owners/ operators and masters are advised to be guided by above.

Enclosure:

1. DG shipping Engineering Circular No. 02 of 2018.

Disclaimer:

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.

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