Mandatory fuel consumption data collection to start in 2019 under Regulation 22A

Mandatory fuel consumption data collection to start in 2019 under Regulation 22A

The International Maritime Organization (IMO) has adopted a mandatory fuel consumption data collection system for international shipping, requiring ships above 5,000 gross tonnage to start collecting and reporting data to an IMO database from the start of 2019.

It was adopted by the IMO’s Marine Environment Protection Committee on October 28 as amendments to chapter 4 of annex VI of MARPOL, adding a new Regulation 22A on Collection and reporting of ship fuel oil consumption data and new appendices covering Information to be submitted to the IMO Ship Fuel Oil Consumption Database. These amendments are expected to enter into force on 1 March 2018, under the tacit acceptance procedure.

What it means, and what’s next

Ships will have to collect consumption data for each type of fuel oil they use, and additional, specified data including proxies for transport work according to a methodology set out in the Ship Energy Efficiency Management Plan (SEEMP).

The 2012 Guidelines for the Development of a SEEMP have been revised accordingly and new 2016 Guidelines were adopted at MEPC (Resolution MEPC.282(70).  Concrete proposals were invited on a proxy for transport work for ships that do not carry cargo (e.g. cruise ships) as these details still need clarification. 

Details still to be worked out for cruise ships
Details still to be worked out for cruise ships

Draft Guidelines for Administration data verification procedures and draft guidelines for the development and management of the IMO Ship Fuel Consumption Database are still to be developed, and work will continue in a correspondence group.

There was support for encouraging voluntary early implementation of the data collection and submission, so shipping companies and Administrations get used to the process before it becomes a mandatory requirement. Any data submitted prior to 2019 will not form part of any analysis.


The purpose of the new Regulation 22A is to determine more precisely how much CO2 international shipping is responsible for as part of a three-step approach, starting with data collection, followed by data analysis, and finally policy decisions. The question it will seek to answer is whether any further measures are needed to enhance energy efficiency and address greenhouse gas emissions from international shipping.

Aggregated data will be reported to a ship’s flag State after the end of each calendar year, which will need to verify that the data has been reported in accordance with the requirements before issuing a Statement of Compliance to the ship.  Flag States will be required to subsequently transfer this data to the IMO Ship Fuel Oil Consumption Database.

The IMO Secretariat would be required to produce an annual report to MEPC, summarising the data collected. Data would be anonymized so individual ship data would not be recognised.

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