MEPC 85/6/4 – Determination of the carbon intensity indicator for bunker vessels

Introduction

1. MEPC 83 adopted resolution MEPC.400(83) on Amendments to the 2021 Guidelines
on the operational carbon intensity reduction factors relative to reference lines (CII reduction
factors guidelines, G3) (resolution MEPC.338(76)). These amended guidelines outline the
methods for determining the annual operational carbon intensity reduction factors and their
values from 2023 to 2030 (indicating how much carbon intensity needs to be reduced by ships
over this period), as referred to in regulation 28 of MARPOL Annex VI. The amendments
adopted at MEPC 83 included newly defined CII reduction factors for 2027 to 2030.

2. MEPC 83 also agreed on a work plan for phase 2 of the review of the short-term GHG
reduction measures (MEPC 83/17/Add.1, annex 5), to run from spring 2026 to spring 2028.
Phase 2 aims to enhance the SEEMP framework, further develop CII metrics, and ensure
synergies between the IMO carbon intensity/energy efficiency framework and the IMO NetZero Framework.

3. In this regard, during MEPC 83, the methodology for developing a SEEMP was further
amended in the Amendments to the 2024 Guidelines for the Development of a Ship Energy
Efficiency Management Plan (SEEMP) (resolution MEPC.395(82)), which were adopted by
resolution MEPC.401(83). These guidelines clarify that ʺunder wayʺ is considered to be the
period between full ahead on passage (FAOP) and end of sea passage (EOSP) as per the
Guidelines for Setting up a Maritime Single Window (FAL.5/Circ.42/Rev.3), and therefore
“not under way” is the period between end of sea passage and full ahead on the
following passage.

4. Subsequently, MEPC 84, in response to proposals presented in document
MEPC 84/6/17 (Brazil et al.) regarding clarification of CII calculation obligations in the context
of enhanced IMO DCS granularity reporting, including that distance travelled during
“under way” and “not under way” periods be collected separately, adopted, by resolution
MEPC.413(84), the Amendments to the 2024 Guidelines for the development of a Ship Energy
Efficiency Management Plan (SEEMP).

5. The Committee also requested the Secretariat to issue a consolidated text of the
guidelines, as amended, for dissemination as MEPC.1/Circ.925. Paragraph 7.6 reads
as follows:
ʺ7.6 “Under way” is defined as the period between full ahead on passage (FAOP)
and end of sea passage (EOSP) as per the Guidelines for setting up a maritime single
window (FAL.5/Circ.42/Rev.3). “Full ahead on passage” is more commonly referred
to in performance monitoring systems as “begin of sea passage”, which is also
defined in the IMO Compendium on facilitation and electronic business (IMO
Compendium) under IMO 0597 (Code EV10). “Not under way” is therefore the period
between end of sea passage and full ahead on passage. Note that canal passage,
that is, the period between begin canal passage (EV08) and end canal passage
(EV09) which are also defined in the IMO Compendium under IMO 0597 should be
considered not under way due to frequent manoeuvring, acceleration and
deceleration.ʺ

6. Previously, MEPC 81 adopted, by resolution MEPC.385(81), amendments to
appendix IX of MARPOL Annex VI on the information to be submitted to the IMO Ship Fuel Oil
Consumption Database (regulation 27), to include a requirement for the ship to collect and
report data on ʺfuel oil consumption while the ship is not under way by fuel oil typeʺ.
Compliance with the CII requirements by conventional bunker vessels.

7.Evidence presented by the shipping industry identified the challenges for ships across
the international fleet to comply with the current CII requirements, resulting in a detailed
discussion being held at MEPC 81. During that discussion, some delegations expressed their
expectation that the CII review process would result in a fairer system but also cautioned that,
if left unaddressed, this situation would be likely to lead to unintended consequences for the
decarbonization process and penalize ships for factors that were beyond their control,
for example due to short voyages and extended port waiting time (MEPC 81/16,
paragraph 6.19).

8.MEPC 81 had noted the concerns expressed regarding the shortcomings and
unintended consequences of the CII mechanism and the general agreement that these
concerns should be fully considered and addressed during the CII review process

9. MEPC 82/6/9 (IBIA) identified that bunker vessels are, and always will be, constrained
by the vital operational duty they undertake for international shipping that consists primarily of
short voyages and in-port manoeuvring. Consideration was therefore requested for an
amendment to the CII Guidelines, G5, with the inclusion, as with other ship types, of a specific
correction factor for bunker vessels based on analyses set out in documents ISWG-GHG 8/3/1
(Greece) and MEPC 81/INF.28. As with other proposals for correction factors submitted under
phase 1 of the review of the short-term GHG reduction measures, MEPC 83 decided to defer
further consideration to phase 2 (MEPC 83/17, paragraph 6.27, and MEPC 83/17/Add.1,
annex 5).

10. The series of amendments made to the SEEMP Guidelines and to appendix IX of
MARPOL Annex VI as identified above in paragraphs 3 to 6 require the distance travelled and
hours to be recorded both when the ship is ʺunder wayʺ and when ʺnot under wayʺ, along with
ʺfuel oil consumptionʺ for each of these distinct parts of the ship’s operation respectively. As a
consequence, it is now possible to calculate the CII for bunker vessels using data for both
ʺdistance travelledʺ and ʺfuel oil consumptionʺ when the ship is ʺunder wayʺ only.
Proposal

11. To appropriately and meaningfully reflect the vital operational duties of bunker
vessels, IBIA requests the Committee to consider that the calculation of CII for a conventional
bunker vessel should be when that vessel is ʺunder wayʺ only.
Action requested of the Committee.

12.The Committee is invited to consider the comments in paragraphs 7 to 10 above,
the proposal in paragraph 11 suggesting that the calculation of CII for a conventional bunker
vessel should be when that vessel is ʺunder wayʺ only, and to take action as appropriate

Edmund Hughes

IBIA Representative to the IMO