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Who is responsible for compliance?

MRV obligations are to be fulfilled on a "per ship" basis. The company fulfilling the MRV obligations is called the "MRV company".

Any company with responsibility for an entire reporting period over a ship performing shipping activities should be considered responsible for all monitoring and reporting obligations arising in relation to that reporting period, including the submission of a satisfactorily verified emissions report.

Company’ means 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.

In the event of a change of company, the new company should only be responsible for the monitoring and reporting obligations related to the reporting period during which the change of company has taken place. To facilitate the fulfilment of these obligations, the new company should receive a copy of the latest monitoring plan and document of compliance, if applicable. Changes of MRV company are to be properly reflected in the monitoring plan.

The EU MRV Regulation allows the parties involved in the operation of each ship subject to the Regulation to determine, who assumes the MRV monitoring and reporting obligations. From a practical point of view, and if necessary, a relevant clause could be inserted in the charter party (C/P) so as to clarify who is doing what in relation to the MRV Shipping Regulation. In this context, the company mentioned in the SOLAS Safety Management Code could be responsible for MRV requirements.

Source: Regulation 2015/757 §22 & Art. 3 & Commission's FAQ

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