carbon marketcarbon priceEmissionseu carbonEU ETSEuropean Commissionshipping companiesverified emissions
3 min read

Clearly defining responsibility

Shipping companies need to establish clear lines of responsibility both for reporting emissions under the EU’s MRV (Monitoring, Reporting and…

OceanScore
OceanScore’s review of BIMCO’s FuelEU Maritime clause and its challenges.

Shipping companies need to establish clear lines of responsibility both for reporting emissions under the EU’s MRV (Monitoring, Reporting and Verification) regime and surrendering EU Allowances (EUAs), or carbon credits, to the authorities.  

 

 

Currently, the technical manager is typically the designated Document of Compliance (DoC) holder who is responsible for MRV reporting of fleet emissions data. However, the EU has now ruled that the registered shipowner is the default responsible legal entity for emissions monitoring and reporting, and surrendering of EUAs, effectively making the owner the DoC holder. 

 

 

The same company must be responsible both for emissions reporting and EU ETS compliance through surrender of EUAs. This responsibility can be delegated to the technical manager provided there is an agreement in place with the owner along these lines. Some practical aspects related to monitoring and reporting – such as developing a monitoring plan and emissions reports – can still be outsourced to the manager, while the owner retains legal responsibility as DoC holder. 

 

 

An updated monitoring plan must be submitted to the authorities by 1 April 2024. This has been expanded to cover additional obligations under the MRV and EU ETS, including elements such as emission factors for methane and nitrous oxide, as well as CO2, and procedures for data flow and risk assessments. 

 

 

Annual emissions reported under MRV will form the basis of a verified emissions report that will determine the volume of allowances to be purchased and surrendered to the authorities each year. 

 

 

We strongly advocate for a clear demarcation and straightforward structure where either the manager or the owner is responsible for both MRV emissions reporting and surrendering EUAs, as combined set-ups only add unnecessary complexity. 

 

 

A key consideration in this regard is who is best positioned with the resources and know-how: does the owner or manager have access to the relevant data, can implement corrections and discuss complex questions with the verifier? In most cases, this will favour the manager as the one taking on EU ETS responsibility.  

 

 

If the manager is entrusted with overseeing a vessel’s EU ETS processes, the structure of the Shipman management agreement should mirror that responsibility with simple rules for emissions reporting. Ideally, the Shipman should allow the manager to procure EUAs as needed without cumbersome approval procedures. We therefore advocate a simpler Shipman framework than that recommended by Bimco to avoid intricate processes for procurement of EUAs required from owners for off-hires and periods of unemployment.  

Related posts

3 min read

EU ETS and FuelEU Maritime: Challenges and Opportunities for Asian Shipping

Asian shipowners face unique challenges as EU ETS and FuelEU Maritime take full effect. Fewer European voyages, complex Union Registry…

OceanScore
carbon pricecost effectiveemission reductionsemissions trading system eueu emissions trading systemeuropean unionshipping companies
1 min read

Tackle EU ETS Carbon Market with Confidence

As 2024 draws to a close, it marks a pivotal year for the EU ETS Carbon Market, especially with the…

OceanScore
cap and trade systemco2 emissionseu emissions trading systemincluded in the eushipping companiesverified emissions
5 min read

One Year of EU ETS – What Have We Learned, What Lies Ahead?

EUAs can be purchased at a fixed price at auctions arranged during the year by the European Energy Exchange. They…

OceanScore
FuelEUpooling
4 min read

FuelEU Maritime Pooling: A Viable Strategy

FuelEU allows for pooling compliance deficits and surpluses as one way to secure compliance. OceanScore analyses continues to show that…

OceanScore
BIMCOClausecompliance deficitcompliance managerFuelEUlong termmaritime regulationOfficial Statementpooled compliancereporting periodTime Charter Parties
4 min read

OceanScore reviews BIMCO FuelEU Clause for Time Charter Parties 

EUAs can be purchased at a fixed price at auctions arranged during the year by the European Energy Exchange. They…

OceanScore
EU ETSeu ets managementFuelEUmaritime datamaritime operationsoceanscoreshipping companies
5 min read

OceanScore sees surge of new clients for EU ETS management solution driven by industry action for compliance

A collaboration agreement has been signed between a classification society ClassNK and a maritime data and technology firm OceanScore to…

OceanScore
data technologyEU ETSEUAsmaritime datamaritime operationssupply chain
5 min read

ETS data tracking and transparency key to managing compliance risk as EU ETS deadline looms, says OceanScore

OceanScore helps shipping companies navigate EU ETS and FuelEU Maritime compliance with real-time exposure tracking, automated compliance management, and ERP-based…

OceanScore
BudgetingFuelEUfueleu plannerlaunchmaritime operations
4 min read

OceanScore pulls crowd with launch of FuelEU Planner amid SMM in countdown to compliance

OceanScore launches the FuelEU Planner, a tool to help shipping companies optimize compliance with FuelEU Maritime, offering simulations and budgeting…

OceanScore
Shipping companies managing EU ETS carbon credit trading and compliance risks.
emissions trading system eueu allowance euaeu carbonEU ETSeu ets management
7 min read

Trading places: shipping must manage new financial risks with transition to EU ETS, says OceanScore

A collaboration agreement has been signed between a classification society ClassNK and a maritime data and technology firm OceanScore to…

OceanScore
FuelEUFuelEU Pooling
5 min read

FuelEU Maritime Compliance: Why Pooling Is Infinitely Better Than Paying the Penalty

As global trade grows and decarbonization pressures increase, the shipping industry is facing heightened scrutiny over its environmental impact. At…

OceanScore
Turn obligation into opportunity

Turn obligation into opportunity

Explore our maritime emissions compliance solutions designed to meet evolving regulations like EU ETS and FuelEU Maritime.

our clients and partners