Feb. 10 2020

Based on the discussions held in Brussels on 23/1/2020 among competent DG Clima officials and authorized Verifiers’ representatives, you are strongly encouraged to draw the following into consideration for your future scheduling and actions:

1.- All CO2 emission reports that will be made available to the Commission’s services after the regulatory deadline (30/4/2020) will be considered as non-compliant and hence the validity of the DoCs issued by the verifying entities concerned after that date might be questioned by EU M-S authorities concerned with potential administrative & commercial repercussions.

Guidance Note: In the light of the above Emissions Reports for 2019 shall be submitted to our office the soonest and will be treated on a FCFS basis.   

2.- By reference to the provisions contained on page L123/57 item 22 of said Regulation, the purchasing Company’s obligations under EU Law are to be adhered to; namely, the new Company has to get from the selling company: (i) a copy of the last Monitoring Plan (ii) all associated CO2 emission data collected for the period under the selling company’s management (iii) original DoC (if issued by the verifying body for the verification due under the previous management). These are of paramount importance since the acquiring, i.e. the new, managers are considered liable for submitting the whole batch of emissions data subject to verification (a fact that implies that partial emission data referring solely to the period of the new ship’s managers will be considered as non-compliant by the Commission’s services (and as of yet no requirements were communicated for second hand tonnage acquired by means of auctions, etc.)). 

Guidance Note: A minimum provision in the MoA on the seller’s obligation for the timely submission of the accumulated ship’s emission data- in the context of the Regulation- is to be sought by the purchaser.  


It is highly probable that EU Parliament will embark in amending the EU Monitoring Reporting and Verification regime so as for vessels under MRV to cut their carbon emissions per work of transport unit by 40% by 2030 compared with 2018, and in including international shipping in the ETS, whilst
Green EU parliamentarians expressed the wish for EU to give EMSA the authority & resources to check the emissions reported by the accredited verifiers.