In the first article in our new series on environmental shipping law we considered the EU’s new monitoring, reporting and verification (MRV) obligations for voyage emissions within the EU which came into full effect from 1 January 2018.

In this article we take a look at the IMO’s own parallel emissions monitoring regime, known as the IMO fuel consumption data collection system or ‘DCS’. This article will consider the key requirements of IMO DCS (part one) and will also compare the IMO DCS regime with the EU MRV regime (part two).

Both regimes are geared towards achieving similar ends, namely the reduction of greenhouse gases (GHGs) and carbon dioxide emissions in shipping. The IMO’s recent briefing of 5 March 2018 confirms that: ‘the new mandatory data collection system is intended to be the first in a three-step approach in which analysis of the data collected will provide the basis for an objective, transparent and inclusive policy debate in the MEPC [the IMO’s Marine Environment Protection Committee], under a roadmap (through to 2023) for developing a ‘comprehensive IMO strategy on reduction of GHGs emissions from ships’. The roadmap was agreed in 2016.”

In October 2016, at the 70th session of the IMO’s Marine Environment Protection Committee (MEPC70), the MEPC adopted mandatory MARPOL Annex VI requirements for ships to record and report their fuel oil consumption. Under the amendments, ships of 5,000 gross tonnage and above will be required to collect consumption data for each type of fuel oil they use, as well as other, additional, specified data. The amendments, found at new Regulation 22A to MARPOL Annex VI, entered into force on 1 March 2018 with the data collection to commence from 1 January 2019. MEPC70 also adopted the IMO 2016 ‘Guidelines for the development of Ship Energy Efficiency Plan’ (SEEMP) which, amongst other things, provides a methodology for collecting the required data.

IMO development of DCS framework

  • MEPC69: agreement on a global mechanism for mandatory recording and reporting of data on fuel consumption
  • MEPC70: mandatory data collection requirements adopted as modifications to MARPOL Annex VI
  • Addition of new regulation 22A of MARPOL Annex VI
  • MEPC70: 2016 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) adopted

The requirements: data collection and reporting

Pursuant to new regulation 22A of MARPOL Annex VI ships of 5,000 gross tonnage and above will be required to collect data on fuel oil consumption (by fuel type and in metric tonnes), as well as distance travelled and time at sea from berth to berth. The data should be collected in accordance with the methodology included in the SEEMP.

Under the IMO DCS regime, data collection will commence from 1 January 2019. Before 31 December 2019, shipping companies will need to have in place a data collection plan in accordance with Part II of SEEMP. This essentially involves updating the existing mandatory SEEMP plan to include a description of the methodology used to collect the data required by regulation 22A and the processes that will be used to report the data.

The data in aggregate must be submitted in annual reports to the relevant ship’s administration, in other words – the ship’s flag state, after each calendar year. The data reporting must be verified by the flag state before a statement of compliance is issued to the ship.

Administrations are then required to submit aggregated data to the IMO which aggregates all data submitted by the flag states/recognised organisation and publishes in anonymised form on the IMO ship fuel oil consumption database.


As noted in our first article, for the EU MRV to be applicable and for the data collection requirements to apply, the voyage must be from, between or to a port located within the EU territory, including Norway and Iceland.

The IMO DCS, however, is global in its application and applies to international shipping. Accordingly, ships in EU territory ports will need to comply both with the EU MRV regime and the IMO DCS regime, at least that is, until the two systems are properly aligned. In circumstances where the voyage is domestic only then the IMO DCS does not apply; the voyage must be international for IMO DCS.

Data and parameters

From 1 January 2019 under IMO DCS, shipping companies must begin the monitoring of fuel consumption and other required data.

The following data must be reported:

  1. IMO number
  2. Ship specifications:

- ship type - gross tonnage - net tonnage - deadweight tonnage - power output of main and auxiliary engines

  1. EEDI (if applicable)
  2. Ice class
  3. fuel oil consumption by oil type
  4. distance travelled over ground
  5. hours underway

The IMO DCS reporting parameters are therefore considerably less detailed than those under EU MRV.


Data should be submitted to the flag state or any organisation authorised by the flag state. It is therefore not necessarily the case that an independent verifier accredited for the purposes of MRV verification will be authorised for the purposes of IMO DCS verification.

The flag state or duly authorised organisation, provided it is satisfied that the data has been collected and reported in accordance with the requirements of regulation 22A, should issue a statement of compliance within two months of receiving the data.

The ship is required to keep the statement of compliance on board.

Publication and disclosure

Under IMO the flag state or recognised organisation receives the data from the ship, aggregates the data and sends to the IMO. The IMO makes the data available on the IMO ship fuel oil consumption database but, significantly, the data is anonymised to the extent that the ships cannot be identified.

This practice contrasts with the EU MRV regime where the data, including references to ships is to be made available to the public in annual reports.