Interferry recommends early dialogue with flag states, class societies over Carbon Intensity Indicator concerns

During June 6-10, the IMO Marine Environment Protection Committee (MEPC) held its 78th session.

Please note the summary report from our friends at DNV.

Regarding the issues at the forefront for Ro-Ro cargo and Ro-Ro passenger ship operations, MEPC 78 finalised the Energy Efficiency Existing Ships Index (EEXI), the Carbon Intensity Indicator (CII) and the Ship Energy Efficiency Management Plan (SEEMP) regulations, all entering into force in 2023. These instruments have been developed in Correspondence Groups and through a large number of virtual inter-sessional meetings. Effectively, the regulations were agreed in principle six months ago and MEPC 78 concluded on the supporting calculation guidelines.

Interferry members report that compliance with the EEXI requirements seems reasonably feasible. All ships need to have their EEXI technical file approved before the first annual, intermediate or renewal International Air Pollution Prevention Certificate (IAAP) survey or the initial International Energy Efficiency Certificate (IEEC) survey on or after 1 January 2023.

For the CII, the capacity parameter for Ro-Ro cargo ships was aligned with that for Ro-Ro passenger ships and changed to gross tons – on Interferry’s request.

The first reporting of the CII based on 2023 data is due no later than March 31, 2024, after which corrective action should be taken by D- and E-rated ships. However, as expressed numerous times by Interferry, the CII is not well suited for diverse segments such as ours. We see a pronounced spread, particularly in the Ro-Pax fleet, with a large number of individual ships falling into the D- or E-rating band – thereby forcing corrective actions that we deem unrealistic for such vessels.

Fortunately, Member States seem to have caught up to the shortcomings of this regulation, which blindly tries to establish how much fuel a given ship should consume and goes on to retroactively penalise those that do not fit this narrow template.

Interferry therefore recommends its members to stay in close connection with their Classification Societies and Flag States and establish early dialogue on their expectations for the CII’s initial three-year stint, pending the review that has already been announced for 2026.

Finally, and as a testament to how all-encompassing the Green House Gas deliberations have been for the past three years, MEPC 78 also approved a proposal for a Sulphur Emission Control Area (SECA) to be established in the Mediterranean Sea, an issue that has barely been noticed by most. The final go-ahead for a Med SECA is tasked to MEPC 79 in December.

Johan Roos

Johan Roos is Director of Regulatory Affairs for worldwide ferry industry association Interferry.