Statutory compliance for the maritime industry

EU Monitoring, Recording and Verifying CO₂ emissions (MRV) regulation covers the monitoring, reporting and verification of CO₂ emissions, cargo carried, miles travelled and time spent at sea. It is applicable to vessels of all flags conducting commercial voyages into, out of and between EEA ports (the EU  plus Norway and Iceland) and will require the submission of a verified ship annual emissions report to a central database and an annual public disclosure of the data on a ship basis.

Irrespective of flag, the regulation applies to ships greater than 5,000 GT (with some exceptions as listed below) undertaking one or more voyages into, out of and between ports that are under the jurisdiction of a EEA Member State. It requires the per-voyage and yearly monitoring of CO₂ emissions, as well as the monitoring of other parameters, including the quantities of cargo carried, distance travelled and time spent at sea.

Learn how we can help with EU MRV

The EU ETS (Emissions Trading System) is a key tool being applied within the EU to reduce GHG emissions across the region. It is a cap-and-trade system where a limit is put on how many GHG emissions are permitted to be released into the atmosphere from industries. Companies falling under the scope of EU ETS can purchase emission allowances or trade emission rights. Those who emit fewer emissions can trade their permitted allowance to industries that emit more than permitted. Those companies that emit more than their allowance and cannot buy additional allowance from the market or other companies must pay a financial penalty to the EU ETS.

Learn more about ETS

Alternative Fuels Infrastructure Regulation ensuring that alternative fuels are available for bunkering and that zero-emissions energy is available whilst some ships are at berth.

Aim: Increase the use of sustainable alternative fuels by addressing market barriers

This includes requiring action by EEA member states (the EU plus Norway and Iceland) as well as commercial actors. By 2025, EEA member states will have to submit their own national policy frameworks (NPFs) with their national targets for rolling out infrastructure to support the uptake of renewable and low-carbon fuels.

The intent is to ensure that the uptake of the alternative fuels needed for decarbonisation is not prevented by a lack of delivery infrastructure. In this way, it supports ship owners and operators in their compliance with FuelEU Maritime.

AFIR covers multiple transport modes and includes some maritime-specific aspects. This includes shipping and inland waterways. AFIR applies to major EEA ports, both coastal and inland. It covers the core ports under the established TEN-T network (Trans-European Networks).

Under the EU Fit For 55 package, the existing Alternative Fuels Infrastructure Directive (Dir 2014/94/EU) is being revised and recast as a Regulation in EU law.

Learn how we can help with AFIR

The Renewable Energy Directive (known as RED II) sets a binding target on the share of renewable energy sources to be used as part of the gross energy use in the European Union (EU) of at least 32%. The recently provisionally agreed amendments to the Directive (to be RED III) change that to 42.5% with an aim that could take it to 45% by 2030.

How does this affect shipping?

For the transport sector the provisional agreement allows member states to choose between:

• a binding target of 14.5% reduction of greenhouse gas intensity in transport from the use of renewables by 2030; or
• a binding target of at least 29% share of renewables within the final consumption of energy in the transport sector by 2030, when setting targets in their national legislation.

Learn how we can help with RED

The SOLAS Convention sets out the minimum standards for how ships should be built, equipped, and operated to ensure their safety. This includes guidelines for the structure, machinery, electrical equipment, fire protection, life-saving appliances, radio communications, navigation safety, and cargo carriage.

SOLAS Chapter II-2 – PFOS Ban – Use or storage of fire extinguishing media containing perfluorooctane sulfonic acid (PFOS) shall be prohibited not later than the date of the first survey* on or after 1 January 2026. SOLAS amendment introduced by IMO resolution MSC.532(107). *Refer to the Unified interpretation of the term "first survey" referred to in SOLAS regulations (MSC.1/Circ.1290).
 
New SOLAS reg. II-1/3-13 – Lifting appliances and anchor handling winches – the amendments introduced by IMO resolution MSC.532(107) contain requirements for equipment installed on or after 1 January 2026.  There are also requirements for equipment installed before  1 January 2026, to be complied with no later than the date of the first renewal survey on or after 1 January 2026.  Detailed requirements are contained in Guidelines for anchor handling winches (MSC.1/Circ.1662) and Guidelines for lifting appliances (MSC.1/Circ.1663).
 
New SOLAS reg. V/19.2.12 – the amendments introduced by IMO resolution MSC.532(107) contain a requirement for containerships and bulk carriers of 3,000 GT and upwards, constructed on or after 1 January 2026, to be fitted with an electronic inclinometer, or other means, to determine, display and record the ship's roll motion.
 
Amended SOLAS Chapter XIV – the amendments introduced by IMO resolution MSC.532(107) extend the application of the Polar Code to fishing vessels of ≥24 metres in length, pleasure yachts of ≥300 GT not engaged in trade and cargo ships of ≥300 GT and <500 GT, which operate in polar waters. The requirements apply to such vessels constructed on or after 1 January 2026.  Such vessels constructed before 1 January 2026 shall meet the relevant requirements of the Polar Code by 1 January 2027.

New SOLAS Chapter XV and IP Code - amendments entering into force on 1 July 2024: Chapter XV introduced by IMO resolution MSC.521(106), adds requirements for carriage of industrial personnel. The new chapter mandates the new International Code of Safety for Ships Carrying industrial personnel (IP Code),  introduced by IMO resolution MSC.527(106), for ship of 500GT and upwards carrying more than 12 industrial personnel on international voyages to new and existing ships. See Class News 20/2023 for further information.

Revised SOLAS Chapter IV radiocommunications - amendments entering into force on 1 January 2024: introduced by IMO resolution MSC.496(105), and applies to new and existing ships. The revised chapter IV adds references to new performance standards for newly installed GMDSS equipment (noting MSC.1/Circ.1676 relating to delays due to unavailability of new equipment) and also effectively removes the requirement for provision of high-frequency direct-printing telegraphy (HF NBDP) equipment, except it may still be used for reception of MSI and search and rescue related information (MSC.1/Circ.1645 refers).  Detailed information also available in COMSAR.1/Circ.32/Rev.2.

SOLAS regulation II-1/3-8 - amendments entering into force on 1 January 2024: Introduced by IMO resolution MSC.474(102), adds new paragraphs 7 and 8 applicable to new ships 3000gt and above, and adds new paragraph 9 which applies to new and existing ships. See also Class News 14/2022 and Class News 15/2023.

Learn how we can help with SOLAS

The International Convention for the Prevention of Pollution from Ships (MARPOL) is the main international convention covering prevention of pollution of the marine environment by ships from operational or accidental causes and currently includes six technical annexes.

Minimizing pollution of our oceans and seas is crucial to our oceans health. The IMO developed MARPOL to address this issue. MARPOL lays down regulations that apply to all ships flying the flag of countries that have signed the agreement, no matter where they sail. Member nations are also responsible for vessels registered on their national ship registry. By adhering to these guidelines, we can help protect our planet's natural resources and ensure a safe and sustainable future for generations to come.

• Annex I – Regulations for the Prevention of Pollution by Oil
• Annex II – Regulations for the Control of Pollution by Noxious Liquid Substances in Bulk
• Annex III – Prevention of Pollution by Harmful Substances Carried in Packaged Form
• Annex IV – Prevention of Pollution by Sewage from Ships
• Annex V – Prevention of Pollution by Garbage from Ships
• Annex VI – Prevention of Air Pollution from Ships

Learn how we can help with MARPOL

The Ballast Water Management Convention or BWM Convention is a treaty adopted by the International Maritime Organization in order to help prevent the spread of potentially harmful aquatic organisms and pathogens in ships' ballast water.

From 8 September 2017, ships must manage their ballast water so that aquatic organisms and pathogens are removed or rendered harmless before the ballast water is released into a new location. This will help prevent the spread of invasive species as well as potentially harmful pathogens.

How we can help with Ballast Water Management

The 2009 IMO Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) will enter into force on 26 June 2025.

Its criteria for ratification have now been met following Bangladesh and Liberia becoming Contracting States to the convention in June 2023. 

The main aim of the HKC’s new requirements for shipping and ship recycling facilities is to ensure that the end-of-life recycling of ships is done in a safe and environmentally sound manner to minimise risks to human life and the environment.

The HKC will enter into force and operate alongside the EU Ship Recycling Regulation (EU 1257/2013). Alignments may be sought between the two pieces of legislation in the future. 

How we can help with HK Ship Recycling

The International Convention on the Control of Harmful Anti-Fouling Systems on Ships (AFS Convention) currently prohibits the use of harmful Organotins in anti-fouling paints used on ships.

The IMO has published amendments to the AFS Convention, given in Resolution MEPC.331(76), which come into force on 1 January 2023.

These amendments introduce new requirements that ban the future installation of anti-fouling systems which contain a toxic substance called cybutryne (CAS No. 28159-98-0). The amendments also include requirements for ships that already have installed an anti-fouling system containing cybutryne.

How we can help with the AFS Convention

The International Management Code for the Safe Operation of Ships and for Pollution Prevention (ISM Code) is a management systems model designed to encourage safety and pollution prevention. Compliance is mandatory for passenger ships and other ships of 500GT and upwards engaged on international voyages, although individual flag administrations may add to these minimum requirements.

In general terms, the Code requires that safeguards be established against the safety and pollution risks involved in shipboard operations. Responsibility for this is placed firmly on the companies charged with the ships management.

View our ISM training courses 

ISM and the Lead Auditor

Like safety, maritime security is of paramount importance to the operation of a vessel. The International Ship and Port Facility Security (ISPS) Code came into force on July 1, 2004 and is applicable to all vessels over 500GT operating on international trades, as well as the ports that service them.

We have played a proactive role in helping the industry to implement the ISPS Code and offers a full range of statutory certification services to help you maintain compliance. We also offer ISPS training courses.

The ISPS Code provides a framework through which ships and port facilities can co-operate to detect and deter acts which pose a threat to maritime security. The Code:

• enables the detection and deterrence of security threats within an international framework
• establishes roles and responsibilities
• enables collection and exchange of security information
• provides a methodology for assessing security
• ensures that adequate security measures in place.
• It requires ship and port facility staff to:
• gather and assess information
• maintain communication protocols
• restrict access, prevent the introduction of unauthorised weapons, etc.
• provide the means to raise alarms
• put in place vessel and port security plans and ensure training and drills are conducted.
• The regulatory provisions do not extend to the actual response to security incidents or to any necessary clear-up activities after such an incident.

Learn how we can help with ISPS Code

View our ISPS Code training courses

ISPS Code: Company and Ship Security Officer

ISPS Company Security Officer

ISPS Port Facility Security Officer

ISPS Ship Security Officer

ISM ISPS Internal Auditor training

Carrying solid bulk cargoes involves serious risks, which must be managed carefully to safeguard the crew and the ship. These risks include reduced ship stability, and even capsizing, due to cargo liquefaction; fire or explosion due to chemical hazards; and damage to ship structures due to poor loading procedures.

The main legislation governing safe carriage of solid bulk cargoes is the International Maritime Solid Bulk Cargoes (IMSBC) Code, which became mandatory on 1 January 2011, under the SOLAS Convention.

Learn how we can help with IMSBC Code

The UK legislation establishing the new UK MRV regime (SI 2018/1388) is now in place and can be accessed here.

On the 17 September 2021 the UK Government released its guidance on the application of the UK scheme for monitoring, reporting and verifying (MRV) carbon dioxide (CO₂) emissions as Marine Information Note 669. Please click here for more information.

On the 5th of May 2023 this publication was withdrawn. This Marine information note has been superseded by MIN 669 (M+F) Amendment 1 - Reporting emissions data into the UK MRV regime.  This MIN expires 31st December 2024.

Where does it apply 

The type of vessels within scope of the UK MRV regime and type of emissions data for collection are the same as those under the EU MRV regime.

The only emissions data required to be reported under the UK MRV regime are for the following voyages:

• Voyages between two UK ports
• Voyages between a UK and non-EEA port
• Emissions generated within a UK port
• Emissions generated for voyages between a UK and non-EEA port
• Voyages between a port in the UK and a port in one of the UK Overseas Territories or Crown Dependencies

How we can help with UK MRV

As of 1 January 2021, the United Kingdom has finished its transition period to leave the European Union. The UK Ship Recycling Regulation (UK SRR) now retains the requirements of the EU Ship Recycling Regulation 1257/2013 (EU SRR) in UK domestic legislation. Note that the EU SRR applies in the European Economic Area (EEA) (EU countries plus Iceland and Norway).ⁱ

This Class News summarises the information contained in MGN 633 (M+F) Amendment 1 regarding requirements for final surveys and ship recycling facilities under the UK SRR, as well as further direct correspondence with the UK Administration.

The UK SRR does not apply to:

• Ships of less than 500 GT;
• UK ships operating throughout their life only in UK waters; and
• Any warships, naval auxiliary, or other ships owned or operated by a state and used, for the time being, only on government non-commercial service.

Note that the EU SRR still applies to UK ships operating throughout their life only in UK waters when they go to a recycling facility in an EEA member stateⁱ.

Read more in Class News 04/2021