About
With effect from 1 January 2013, the International Maritime Organization ('IMO') has made it mandatory for new and existing ships above 400 gross tonnes to carry on board a vessel-specific Ship Energy Efficiency Management Plan (SEEMP), as required by MARPOL Annex VI, Regulation 22.
The purpose of a SEEMP is to establish a mechanism to improve the energy efficiency of a ship's operation.
The SEEMP consists of three parts:
Part I: A ship management plan to improve energy efficiency (vessels over 400 gross tonnes)
Part II: Ship fuel oil consumption data collection plan (vessels over 5000 gross tonnes)
From 1 January 2023, Part III of the SEEMP (also known as the 'Enhanced SEEMP') came into force:
Part III: Ship operational carbon intensity plan (appliable to vessels subject to the Carbon Intensity Indicator ('CII') requirements)
When developing or revising a SEEMP, the process should follow a cyclical process including:
- Planning: The ship-owner is required to review current practices and energy usage on board the vessel with a view to identifying any shortfalls or areas for improvement of energy efficiency;
- Implementation: The ship-owner needs to develop a system of how each energy improvement measure is to be implemented;
- Monitoring: The ship-owner must have a monitoring system in place. The SEEMP guidance adopted by the IMO recommends the Energy Efficiency Operatorial Indicator (EEOI) to be used for monitoring, which has been developed to quantify the energy efficiency of a ship in terms of CO2 production per cargo-tonne nautical mile (g CO2/t.nm); and
- Self-evaluation, improvement and review: Each measure needs to be evaluated individually on a periodic basis and the results should be used to understand the level of improvements seen for each ship.
IMO has acknowledged that there are some issues with the SEEMP and CII Regulations. During the 82nd Marine Environment Protection Committee (MEPC 82) meeting in October 2024 it was agreed that gaps and challenges related to SEEMP would be addressed. The IMO has issued a work plan in which it has planned to consider and finalise further developments in spring 2026. Thommessen is closely monitoring these developments.
Amendments to MARPOL Annex VI Appendix IX which entered into force on 1 August 2025 will require ships to collect extra fuel data. The recommended primary method for collecting this "new" more granular data related to fuel oil consumption is by flow meters or bunker oil tank monitoring, but if this cannot be achieved, a secondary method of using subtraction or estimation may be applied.
SEEMP Part II must be amended and reviewed by the flag Administration or Recognised Organisation before a ship begins collecting the new data. For existing ships, the deadline is 1 January 2026. For new ships delivered on or after 1 August 2025, SEEMP Part II must be reviewed before entering service.
Ships that currently have a SEEMP Part III must also revise this to include an implementation plan showing how the required CII will be met for 2026–2028. This must also be approved by 31 December 2025.
If the new IMO Net-Zero Framework is adopted, this will entail some amendments to SEEMP in order to accommodate the new reporting requirements. If adopted, prior to the first reporting period of 2028 each ship must update its SEEMP Part II to include GFI reporting requirements (as detailed in Appendix XII to Annex VI of MARPOL).
Who does it impact?
- All ships of 400 gross tonnes and above must be equipped with a SEEMP Part I.
- All ships above 5,000 gross tonnage must be equipped with Part II on data regarding consumed fuel.
- Cargo, RoPax and cruise ships exceeding 5,000 gross tonnes subject to the Carbon Intensity Indicator ('CII') requirements must include mandatory content pursuant to the CII requirements into the ship's SEEMP .
Status: In force
The MARPOL Annex VI Regulation 22 entered into force on 1 January 2013.
Relation to other initiatives and regulations
The SEEMP is related to the Energy Efficiency Design Index (EEDI).
As per MARPOL Annex VI Regulation 6, an International Energy Efficiency Certificate (IEEC) needs to be issued to both new and existing ships of 400 gross tonnes and above.
For new ships, an IEEC is to be issued at the vessel's initial survey provided that the EEDI has been verified and that a SEEMP is on board. For existing ships, an IEEC is to be issued no later than the first intermediate or renewal survey provided that the SEEMP is verified on board.
With the introduction of Part III or Enhanced SEEMP from January 2023, the SEEMP is directly tied in with the requirements under the Carbon Intensity Indicator ('CII').
Participants
Signatories to MARPOL Annex VI
Thommessen's comments
While the Energy Efficiency Design Index (EEDI) and the Energy Efficiency Existing Ship Index (EEXI) have been introduced to determine the energy efficiency of the vessel design of newbuildings and existing ships, respectively, SEEMP is a management tool intended to assist shipping companies in managing the ongoing environmental performance of their vessels and as such, improve the energy efficiency of the ships' operation.
A SEEMP is a ship-specific document containing energy efficiency improvement measures identified by the ship-owner, which must be kept on board each ship exceeding 400 gross tonnage. A SEEMP shall be developed taking into account the relevant guidelines adopted by the IMO.
The SEEMP does not need pre-approval by the flag state or class society, but it will be inspected at the first inspection for the International Energy Efficiency (IEE) Certificate. The SEEMP may form part of the ship's safety management system.