IMO fuel oil consumption data collection system (IMO-DCS) in effect

Standard Club has notified members that the IMO’s introduction of the Data Collection System (IMO-DCS), which runs in parallel to the European Union Monitoring, Reporting and Verification (EU-MRV) regulation, but on a different timeline, was now in effect.

IMO-DCS became operative on March 1st 2018, with first data ‘calendar year’ beginning January 1st 2019. It requires ships of 5,000 gt or more to submit to their Administration annual reports on fuel oil consumption. This requirement was added to chapter 4 of MARPOL Annex VI under Regulation 22A.

Standard Club noted that, in essence both EU-MRV and IMO-DCS had been developed in the context of reduction of greenhouse gases (GHG)/carbon dioxide emissions; with a target to measure and potentially reduce the CO2 emissions in the maritime industry.

The schemes overlapped in various areas; however, the Club said that two new sets of regulations, running on two different timescales, might pose some challenges for the members. It therefore created a table to compare the core components of the two systems.

ApplicabilityShips ≥ 5000 GTShips ≥ 5000 GT
ExemptionsWarships, naval auxiliaries, fishing vessels, wooden ships of primitive build ships not propelled by mechanical means and government ships used for non-commercial purposes.TBD
Monitoring voyagesVoyages to/from EU portsGlobal
Shipboard PlanEU Monitoring PlanSEEMP with amendment
Monitoring periodStarting 1 January 2018Starting 1 January 2019
Range for monitoringPer-voyageNot specified
Data of cargo carriedActual amount of cargoDesign deadweight (DWT)
ParametersFuel consumption & CO2 emissionsFuel consumption & CO2 emissions
 Distance & TimeDistance & Time
 Transport work (based on actual cargo carried)
VerificationRobust verification procedures based on ISO 14064Practical verification procedures considering the administrative burden (under discussion)
VerifierAccredited by European national accreditation bodiesFlag State or Recognised Organisation
Reports toEuropean CommissionFlag State
CertificationDocument of Compliance (June 2019)Statement of Compliance
Centralized database‘THETIS MRV’ operated by EMSAShip fuel oil consumption database managed by IMO
PublicationAnnual reporting data including the individual ship information will be made available to the publicAnonymous data will be made available to IMO member states

Standard Club recommended members to streamline the procedures, systems and responsibilities to ensure common and consistent set of procedures valid for both EU-MRV and IMO-DCS.

Members were encouraged to start considering the methodology for collecting the fuel oil consumption data that was most appropriate for each ship.

The Ship Energy Efficiency Management Plan (SEEMP) shall be amended using the template outlined in Appendix 2 of MEPC.282 (70); and data collection plan should be submitted to the Flag State (or Class) for approval by December 2018.