About
The EEXI is a framework for measuring a ship's energy efficiency for in-service vessels exceeding 400 gross tonnes. The EEXI requires shipowners to assess and measure their ships' CO2 emissions related to the technical design, against specific emission reduction factors for each vessel type. Shipowners may then have to implement technical alterations to adjust their vessels' emissions to the required level.
Different requirements will apply for different types of vessels, but all vessels must obtain the so-called required EEXI value. This value will be determined based on the ship type, the ship's capacity and method of propulsion. The required EEXI is the maximum acceptable Attained EEXI value.
The calculation of the attained EEXI value must be completed pursuant to guidelines included in MARPOL Annex VI, and is based on the requirements that are used for the Energy Efficiency Design Index (EEDI).
The attained EEXI value is the particular vessel's calculated EEXI value. This value may be below or equal to the required EEXI value. If the attained EEXI value exceeds the required EEXI value, certain mitigating actions must be taken in order to bring the attained EEXI value below the required EEXI value.
These mitigating actions could be any class approved alterations, however, a practical solution for many shipowners will be to install power limitation solutions. These could be engine power limitation (EPL) which would limit the amount of fuel that can enter an engine, or shaft power limitation (SHAPOLI), which automatically limits shaft power not to exceed a pre-set value.
Once the vessel has undergone its statutory survey where its attained EEXI meets the required EEXI, it will be issued an International Energy Efficiency Certificate (IEEC), which will be valid for the lifetime of the vessel. If a vessel does not have a valid certificate it may be subject to detentions.
Once the vessel has obtained its certificate, compliance with the EEXI regulation should not have any effect on the allocation of costs and responsibilities between owners and charterers. Nevertheless, if power limitation solutions have been installed, parties should be aware of agreeing to speed or performance warranties that may not be possible due to power limitation solutions.
Compliance with a related framework, the Carbon Intensity Indicator (CII), will require much more careful contractual considerations.
Who does it impact?
The EEXI applies to all vessels exceeding 400 GT falling under MARPOL Annex VI from 1 January 2023.
Status: In force
The amendments to MARPOL Annex VI entered into force on 1 November 2022, and the EEXI requirements became effective on 1 January 2023. The first annual reporting was completed in 2023, and the first rating was given in 2024.
IMO shall review the effectiveness of the implementation of the EEXI requirements by 1 January 2026 at the latest, and if required, develop and adopt further amendments.
Relation to other initiatives and regulations
The EEXI is one of several mandatory measures adopted by IMO in order to meet the greenhouse gas reduction targets established in the 2018 IMO strategy for reducing greenhouse gas emissions from ships. Other mandatory measures adopted by IMO comprise the Carbon Intensity Indicator (CII), the Energy Efficiency Design Index (EEDI) and Ship Energy Efficiency Management Plan (SEEMP).
MEPC 76 also adopted several guidelines addressing EEXI calculations.
Participants
Signatories to MARPOL Annex VI.
Thommessen's comments
The EEXI is one of several mandatory measures adopted by the IMO in order to reduce the carbon intensity from emission from ships.
The EEXI is a technical regulation that has applied since 1 January 2023. Ships will have to attain one approval once in their lifetime. This approval must be sought by the end of the first annual, intermediate or renewal survey for the International Air Pollution Prevention Certificate on or after 1 January 2023. The certification is based on the vessel's CO2 emissions per cargo ton and mile, considering the ship's design, particularly the propulsion, the reference speed of the ship, and fuel oil consumption. For most vessels, power limitation solutions will be the most straightforward way to comply with the EEXI.
Verification will typically be performed by a classification society as a recognised organisation, acting on behalf of the ship's flag state. If a ship exceeding 400 GT does not comply with the requirements, technical modifications will be required in order to improve the vessel's attained EEXI.
Parties to charterparties will need to allocate the risk and cost of compliance, as technical amendments to the vessel could mean a period of non-operation. BIMCO has published a new EEXI Transition Clause for Time Charter Parties. Under this clause, the costs related to compliance and loss of time are for the owners' account. A link to the EEXI Transition Clause for Time Charter Parties with guidance notes can be found below under 'Relevant Documents'.