Time is ticking for monitoring plan submission

Tobias Konik, CEO of First Choice Carbon, on the impending EU MRV deadline.

With less than six months to go until the August 31 deadline, most shipowners and managers have yet to prepare for each vessel above 5,000 gt a monitoring plan and to submit it for assessment to an accredited MRV shipping verifier.

Here’s a quick recap: In July 2015, the European Union adopted Regulation 2015/757 to introduce a system on the monitoring, reporting and verification of carbon dioxide emissions and other relevant information, such as cargo carried or distance sailed. This new piece of legislation concerns all merchant vessels above 5,000 gt which plan to call at a European port from 1 January 2018 onwards. Compliance is demonstrated by carrying onboard each vessel a document of compliance by 30 June 2019.

Shipping companies must go through several steps to obtain such a document of compliance. The first step is to create a ship-specific monitoring plan. The monitoring plan describes in detail the MRV management and control system including all the data flow and control activities from the moment data is recorded onboard the ship to the creation of an emissions report in the shore-side office.

Those who have already taken the first hurdle towards compliance can testify that the new European regulation differs quite substantially from what they know from IMO. It is often during the assessment where companies realise for the first time that the preparation of a monitoring plan is far more complex than it appears. But even at this stage, companies can still seek assistance from a MRV compliance specialist to resolve any non-conformities identified by the verifier.

What is commonly misunderstood is that, to complete the monitoring plan assessment successfully, companies must have in place a fully functioning MRV management and control system. It must be designed to reduce control risks. That is to say, companies must prevent misstatements in the emissions report by setting up an effective control system which picks up and corrects any errors at the source.

To avoid penalties for late submission, we recommend shipowners and managers to take action before it is too late. Now is the right time to think about a suitable compliance strategy. Fleets with 50+ vessels might prefer to hire a dedicated compliance officer, whereas for smaller fleets, it can make good business sense to outsource the whole compliance process to an MRV management company.

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