Technical Circular No: 021/2025
1. The 2021 Revised MARPOL Annex VI, adopted vide Resolution MEPC 328(76) requires as follows:
a. Regulation 26.3.1 - Ships to which this regulation applies to keep onboard a SEEMP (Part III).
b. Regulation 28.3 - A ship rated as E or rated as D for three consecutive years shall develop and undertake the verified planned corrective actions in the revised SEEMP (Part III) to achieve the required annual operational carbon intensity indicator (CII).
c. Regulation 26.3.3 - The SEEMP be subject to periodical company audits taking into account the guidelines outlined in MEPC Resolution 347(78).
The periodical company audits may include annual audits of the company (company audits) and verifications on board the ship (shipboard audits). If undertaken, the audits are to be conducted no later than six months after the issuance of the Statement of Compliance related to fuel oil consumption reporting and operational carbon intensity rating, i.e. no later than 30th November.
2. In this regard, the Liberia Maritime Administration has issued Marine Advisory No. 15/2025 providing instructions on implementing the Company and Shipboard audits of the Ship Energy Efficiency Management Plan (SEEMP) as follows:
a. Companies with one or more ships that obtained an E rating in any calendar year (XXXX) are to be audited no later than 30 November of the following year (XXXX+1); and with one or more ships that obtained consecutive D ratings in calendar years XXXX and XXXX+1, are to be audited no later than 30 November of year XXXX+2;
b. Shipboard audits to be conducted of ships that received two (2) consecutive E ratings of the annual operational CII (i.e. in the year XXXX+2);
c. Companies with ships that obtained ratings other than those described in point a. above to be audited at intervals not exceeding three (3) years;
d. Company audits may be combined with the annual company DOC audit if it is within the window of the DOC audit; or as a standalone audit, as may be decided by the Administration;
e. The Administration has decided to extend the due date of the Company audits for calendar year 2024 to 31 December 2025.
3. Vessel owners/ISM managers of the Liberian Flagged are advised to take note of above and contact an authorized recognized organization listed on the administration’s website to schedule an audit of the SEEMP as per the instruction provided in point 2.
Enclosure:
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.