About
The EU MRV Regulation is part of the EU's strategy to reduce greenhouse gas emissions from the maritime industry and requires MRV companies to:
- Submit a monitoring plan to a MRV accredited verifier, which shall reflect the technical specifications and the monitoring methods to be applied.
- Monitor the vessels' greenhouse gas emissions, fuel consumption and other relevant information with a view to aggregate data into an annual emissions report.
- By 30 April of each year, the responsible party must submit a satisfactorily verified emissions report. In 2025, this date was changed to 31 March.
- The monitoring plan and emissions reports are to be submitted to a verifier accredited by a national accreditation body, which is to be independent of the company/ship operator.
- By 30 June each year, the shipping company must ensure that all the vessels which have performed activities in the previous reporting period and are visiting ports in the EU/EEA, carry on board a MRV Document of Compliance.
As a part of the revision to the EU ETS, general cargo vessels between 400 and 5,000 gross tonnes was included in the EU MRV regulation from 1 January 2025. Building on the experience from the EU MRV, the Commission shall present a report on whether other vessels (including offshore vessels) between 400 and 5,000 gross tonnes may also be included in EU ETS no later than 31 December 2026.
Who does it impact?
- Ship-owners or another company or person having assumed responsibility for the operation of a ship and compliance with EU ETS and EU MRV, for ships exceeding 5,000 GT operating within the EEA area (to, from or between EEA ports), and for general cargo vessels between 400 and 5000 gross tonnes.
- The EU MRV Regulation applies regardless of the vessel's flag state or country of ownership, and it applies to vessels carrying cargo or passengers for commercial purposes to, from or between ports within the EEA.
- In a circular, the Norwegian Maritime Authority concluded that offshore supply vessels delivering persons, provisions and equipment from shore to offshore installations will not be regarded as 'commercial transport of cargo and passengers' and will therefore not be subject to the EU MRV Regulation.
- However, in a Commission Delegated Regulation which was adopted on 16 October 2024, the Commission published a list of types of vessels that were designed or certified to perform service activities offshore or at offshore installations, which shall be included in the EU MRV from 1 January 2025. This includes offshore supply ships.
- The relevant test would therefore be what service the vessel was designed or certified to perform, not what kind of service the vessel is actually performing. There is still uncertainty surrounding the list, and particularly how the terms "port calls" and "voyages" should be understood in the context of offshore vessels. It is expected that the Commission will publish more information in this regard, and Thommessen is monitoring the developments.
Status: In force
The EU MRV Regulation was adopted by the European Council and Parliament and entered into force on 1 July 2015.
Due to several amendments, the obligations have gradually become more comprehensive.
Relation to other initiatives and regulations
The EU MRV Regulation and the IMO Data Collection System on fuel consumption are two similar systems, which will run in parallel for as long as the two regimes are not aligned by the EU and IMO.
The main differences are:
- The EU MRV Regulation focuses on emissions from shipping activities within the EU area, whereas the IMO DCS covers emissions from global shipping;
- The EU MRV Regulation requires reporting of actual cargo carried, whereas the IMO DCS uses ship DWT as cargo proxy;
- The EU MRV Regulation provides requirements for monitoring plans in a special format, whereas the IMO DCS requires a Part II of the SEEMP, called Ship Fuel Oil Consumption Data Collection Plan with its own given format;
- The EU MRV Regulation requires verification by an accredited body, whereas the IMO DCS requires verification by the flag state or a recognised organisation (such as, but not limited to, authorised class societies);
- Data under the EU MRV Regulation must be submitted through the THETIS-MRV system of EMSA, whereas the IMO DCS data collected are reported to the relevant flag state administration or recognised organisation; and
- Data reported under the EU MRV Regulation is published on a per-ship basis, whereas data reported under the IMO DCS is anonymously published by the IMO.
Following the UK's withdrawal from the European Union, the UK has introduced its own UK MRV regime, which applies to emissions from ships sailing between UK ports and UK and non-EEA ports, and otherwise largely mirrors the EU MRV regime.
Participants
The EU MRV Regulation currently applies to ships above 5,000 GT, as well as general cargo vessels between 400 and 5000 gross tonnes, regardless of their flag or country of ownership, carrying cargo or passengers for commercial purposes to, from or between ports within the EEA.
Thommessen's comments
The obligations under the EU MRV Regulation are to be fulfilled on a 'per ship' basis and the fulfilling MRV company will be either the ship-owner, or any other company or person, such as a manager or a bareboat charterer, which has assumed the responsibility for the operation of the vessel from the ship-owner. From 1 January 2024, the default responsible party will be the shipowner. The responsibility may be delegated to the entity that has assumed responsibility as the Document of Compliance (DOC) holder under the ISM Code (ISM DOC Holder). This is done by delegating responsibility for the EU Emission Trading System ('EU ETS'), as the same entity should be responsible for compliance under the EU ETS and the EU MRV.
The responsible party shall submit a report with aggregated emissions data from all the vessels for which it is responsible in the reporting period, which runs from 1 January to 31 December each year.
The data that is reported under the EU MRV Regulation will form the basis of the calculation of how many allowances must be submitted under the EU Emission Trading System.
The EU MRV Regulation runs in parallel to the IMO Data Collection System on fuel consumption, which both intend to quantify emissions from shipping activities.
There are certain differences between the two regimes and if a vessel is subject to both the EU MRV Regulation and the IMO Data Collection System on fuel consumption, reporting must be made as per the respective requirements. Additionally, vessels may also be subject to the FuelEU Maritime Regulation. Although there is considerable overlap, respective reports are required.