In case of a change in ownership or in operating company for a ship engaged in EU MRV voyage during a reporting period, who is responsible for the reporting under EU MRV ?
According to Art. 11 § 2 of the EU MRV Regulation 2015/757 : "Where there is a change of company, the new company shall ensure that each ship under its responsibility complies with the requirements of this Regulation in relation to the entire reporting period during which it takes responsibility for the ship concerned."
Reg. 2016/2072 Art. 10.4 says "In the event of a change of company, the companies involved shall exercise due diligence to provide the verifier with the above-mentioned supporting documents or information relating to the voyages performed under their respective responsibilities." This means that the two companies should collaborate to ensure the MRV reporting for the full reporting period, without gaps.
Concretely, a company which purchased a ship on 1st Sept. 2018 is responsible for the ship's EU MRV reporting for the full year 2018. This means that the new owner must have access to the ship's MRV data for the first part of the year (when the previous company was responsible for operations) so that a complete EU MRV report for the whole year 2018 can be submitted before 30 April 2019. Adequate agreements / clauses should be included in contracts so that this requirement can be fulfilled by the new owner. There are various options :
1/ Requesting an "interim" MRV report from the previous owner, with the adequate verification report from an accredited independent verifier.
2/ Requesting the MRV activity data from the previous owner so that the verification of the full reporting period can be performed by the new owner's independent verifier.
3/ In case of missing data, data gap approaches can be used to complete the gaps (such as AIS-based fuel estimates, etc.).
In all cases, and in order to facilitate compliance with the EU MRV requirements, the new owner / operator should systematically request from the previous owner the vessel's approved Monitoring Plan (along with the official approval document) as well as the Document Of Compliance for the previous period, if it exists.
We strongly advise ship operators to have clauses in contracts to collect MP and MP Approval along with activity data and / or Emission Report to ensure smooth transitions.
Back to all F.A.Q.
Reg. 2016/2072 Art. 10.4 says "In the event of a change of company, the companies involved shall exercise due diligence to provide the verifier with the above-mentioned supporting documents or information relating to the voyages performed under their respective responsibilities." This means that the two companies should collaborate to ensure the MRV reporting for the full reporting period, without gaps.
Concretely, a company which purchased a ship on 1st Sept. 2018 is responsible for the ship's EU MRV reporting for the full year 2018. This means that the new owner must have access to the ship's MRV data for the first part of the year (when the previous company was responsible for operations) so that a complete EU MRV report for the whole year 2018 can be submitted before 30 April 2019. Adequate agreements / clauses should be included in contracts so that this requirement can be fulfilled by the new owner. There are various options :
1/ Requesting an "interim" MRV report from the previous owner, with the adequate verification report from an accredited independent verifier.
2/ Requesting the MRV activity data from the previous owner so that the verification of the full reporting period can be performed by the new owner's independent verifier.
3/ In case of missing data, data gap approaches can be used to complete the gaps (such as AIS-based fuel estimates, etc.).
In all cases, and in order to facilitate compliance with the EU MRV requirements, the new owner / operator should systematically request from the previous owner the vessel's approved Monitoring Plan (along with the official approval document) as well as the Document Of Compliance for the previous period, if it exists.
We strongly advise ship operators to have clauses in contracts to collect MP and MP Approval along with activity data and / or Emission Report to ensure smooth transitions.
Back to all F.A.Q.
