EU has for long worked as an advocate of reducing GHG emissions from international shipping. Because of this, EU not only supported the IMO regulatory developments but also has kept one step ahead in pushing forward the GHG reduction agenda. Generally, the EU plan of action is a phased approach to regulating CO2 emissions as follows:

  • Phase 1: Establish an agreed global energy efficiency standard as part of the IMO regulatory framework.
  • Phase 2: Implement an MRV scheme to establish the fuel consumption and CO2 emissions from international shipping, preferably within the IMO framework.
  • Phase 3: Identify whether the efficiency standards are achieving the EU’s desired absolute CO2 emissions reductions from shipping, and if not, determine what else should be done, e.g. introduction of a Market Based Measure (MBM).

Each company will be required to produce a monitoring plan which will be used to monitor data on a per-voyage basis. This data will be aggregated annually and reported for all voyages conducted into, out of and between EU ports. The differing requirements for monitoring and reporting on a per voyage basis and on a yearly basis are shown in table below.

Figure 20: EU MRV monitoring requirements (MariEMS 2017).

The most critical data in table above is CO2 emissions measurement and reporting. The overall EU MRV processes are shown in figure below schematically.

Figure 21: MRV scheme overview (MariEMS 2017).

As indicated in figure above, CO2 emissions will be calculated based on:

  • Either fuel consumption measurement (by (1) bunker delivery notes or (2) use of tank sounding or (3) use of fuel flow meters) and use of appropriate fuel related CO2 emission factor for the fuel type being consumed;
  • Or by direct emissions monitoring/measurement, with a back-calculation of the fuel consumption using the relevant emissions factor (MariEMS 2017).

Tasks related to the check of monitoring plans, emission reports, communication with ship owners and operators and the issuance of Document of Compliance (DOC) will be done by accredited third party verifiers which most likely include classification societies. The EU Directive sets out guidance on the requirements for verification and the main such requirements are summarised as follows:

  • Verifying conformity of the monitoring plan against the requirements laid out in the regulation;
  • Verifying conformity of the emission report with the requirements laid out in the regulation and issuance of verification report;
  • Ensure that emissions and other climate-related data have been determined in accordance with the monitoring plan;
  • Determining and making recommendations for improvement to the monitoring plan (MariEMS 2017).


Upon satisfactory verification of the emission report, the verifier will then issue a Document of Compliance (DOC) to the company. The EU MRV regulations will not be a flag State requirement; instead it will be enforced through Port State Control within European ports (MariEMS 2017).