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F.A.Q.

1. What is the scope of the regulation?

The EU MRV Regulation applies to all ships above 5,000 GT regardless of flag on all voyages to, from and between EU ports (including ports located in the EU outermost regions). The EU MRV also applies to voyages between Norway / Iceland and third countries.
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2. Who is responsible for compliance?

The shipowner or any other organisation or person, such as the manager or the bareboat charterer, which has assumed the responsibility for the operation of the ship from the shipowner is responsible for compliance.
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3. What are the key deadlines?

The most imminent deadline associated to the EU MRV is the 31 August 2017: ship operators must by then submit the Monitoring Plan of every individual ship they operate to an independent accredited verifier for assessment.
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4. What is a monitoring plan?

By 31 August 2017, companies must submit  a monitoring plan to their verifier for each of their ships. The plan will  indicate the method chosen to monitor and report CO2-emissions as well as any other relevant information.
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5. When must the monitoring plan be modified?

Companies must check regularly, and at least annually, that  a ship's monitoring plan reflects the nature and operations of the ship and whether the monitoring methodology could be improved.
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6. Which data and information must be monitored ?

Some information and data must be monitored on a per voyage basis while other information and data must be monitored on an annual basis
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7. Which methods can be used to calculate fuel consumption?

Actual fuel consumption for each voyage shall be  calculated using one of the four allowed methods.
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8. What other relevant information must be monitored?

Some information and data must be monitored on a per voyage basis while other information and data must be monitored on an annual basis
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9. What is the content of the emissions report?

From 2019, by 30 April of each year, companies must submit a verified emissions report to the Commission and to the Flag State, detailing CO2 emissions and any other relevant information, covering the entire reporting period for each ship under their responsibility.
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10. What is the scope of verification?

The approval of monitoring plans, the verification of emission reports, the communication with shipping companies and the issuance of compliance certificates are the responsibility of accredited independent third party verifiers such as Verifavia.
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11. How are the verifiers accredited?

In order to ensure impartiality, verifiers should be independent and competent legal entities and should be accredited by national accreditation bodies established pursuant to Regulation (EC) No 765/2008 of the European Parliament and of the Council
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12. What is the content of the document of compliance?

By 30 June of the year following the end of a reporting period, ships arriving at, within or departing from a port under the jurisdiction of a Member State, and which have carried out voyages during that reporting period, shall carry on board a valid document of compliance.
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13. How is compliance with the regulation enforced?

Member States will set up a system of penalties for failure to comply with the monitoring and reporting obligations and will  take all the necessary  measures to ensure that those penalties are imposed. The penalties provided will be effective, proportionate and dissuasive.
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14. What information will be published by the European Commission?

By 30 June each year, the Commission will  make publicly available the information on CO2 emissions reported
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15. What are the requirements regarding uncertainty of fuel measurements?

The Regulation requires operators to provide information regarding the level of uncertainty related to the fuel monitoring method(s) selected in their Monitoring Plan. The draft Implementing Acts specify that the use of default values or ship-specific estimate is possible.
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16. Which on-board emission sources should be considered?

The Regulation lists the sources of emission on-board for which fuel and emissions must be monitored and reported under the EU MRV: main engines, auxiliary engines, boilers, turbines and inert gas generators (for tankers only).
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17. What is classed as a voyage?

A voyage is defined in the Regulation as “any movement of a ship that originates from or terminates in a port of call and that serves the purpose of transporting passengers or cargo for commercial purposes”. 
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18. What is meant by departure and arrival?

The Delegated Act on Monitoring Methods clarify that the time spent at sea and distance travelled shall be calculated on a ‘berth-to-berth’ basis.
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19. Which parameter should be used to monitor cargo on-board?

The relevant cargo parameters to monitor and report transport work vary on a ship type basis, and the Implementing Act on Cargo Parameters indicates which parameters must be considered for every type of ship.
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20. What is meant by site visit and is it mandatory?

Verifiers are required to carry out a site visit in order to validate the accuracy of the procedures described in the Monitoring Plan. The location of the site visit is where the critical mass of data is kept. The verifier may waive the site visit providing adequate justification.
 
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21. Which emission factors shall be used?

The draft Delegated Act on Monitoring Methods specifies that the default emission factors for various types of fuels should be taken from the IMO Resolution MEPC 245 (66) 2014.
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22. What is the role of verification?

The assessment of Monitoring Plans, verification of Emission Reports, communication with ship operators and the issuance of Documents of Compliance (DoC) are the responsibility of accredited independent third party verifiers such as Verifavia.
 
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23. What are the permissible languages for monitoring plans?

Monitoring Plans are in principle documents between company and verifier not to be submitted to any competent authority not to the Commission so they can be established in any language.
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24. What are the penalties for non-compliance in the UK?

The EU Regulation is already in force and binding but the precise enforcement process is left to Member States. The UK Government has published the draft Merchant Shipping (Monitoring, Reporting and Verification of Carbon Dioxide Emissions) Regulations 2017 (the “draft UK Regulations”).
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25. How are "ship to ship transfers" considered?

"Ship to ship" transfers carried out outside ports are covered by the Regulation as part of a voyage calculated from the last port of call to the next port of call. 
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26. How shall emissions within EEA ports be reported?

CO2 emissions occurred within EEA ports of call are covered and are to be reported annually as an aggregated annual figure and a separate item under the emissions report. 
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27. What if a ship starts calling in EU after 31 August 2017 deadline?

For ships which call into EEA ports for the first time after the deadline for submitting monitoring plans (set on 31st August 2017), MRV companies should submit a monitoring plan to an accredited verifier without delay, and no later than two months after the ship's first call at an EEA port.
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28. What about ships that do not call in EU for a calendar year?

A ship which has not carried out any EEA-related voyages during a whole reporting period (calendar year X) will not be required by Member States' authorities to have a Document of Compliance on board showing compliance for that specific reporting period (year X), when calling at EEA ports between 30th June of year X+1 and 29th June of year X+2.
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29. Under which conditions can ships benefit from per-voyage monitoring exemption?

A MRV company is exempt from the obligation to monitor a specified ship on a "per-voyage basis", if according to schedule all of the ship's voyages during the reporting period are EEA-related voyages and the ship performs more than 300 voyages during the reporting period.
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