MARPOL Annex VI - Application of the amendments on inclusion of data on transport work and enhanced granularity in the IMO Ship Fuel Consumption Database (IMO DCS)

In 2023, The IMO adopted amendments adopted amendments to MARPOL Annex VI relating to the inclusion of data on transport work and on an enhanced level of granularity in the data to be reported to the IMO DCS (resolution MEPC.385(81)). These amendments are expected to enter into force on 1 August 2025. Early implementation will be possible from 1 January 2025.

The DCS data list below highlights changes in the data to be collected (Annex VI, Appendix IX of the MARPOL Convention).

Application timeline

Amendments are expected to enter into force and will therefore normally be effective on 1 August 2025 with a possible early implantation on 1 January 2025.

However, the collection of DCS data is normally carried out over an entire year, from 1 January to 31 December. The entry into force of these changes on 1 August 2025 could impact the granularity of data to be collected before and after the changes take effect.

Consequently, IACS adopted IACS UI MPC 131 and IMO MEPC 82 approved MEPC.1/Circ.913 on “Guidance on the application of the amendments to appendix IX of MARPOL Annex VI adopted by resolution MEPC.385(81) on inclusion of data on transport work and enhanced granularity in the IMO Ship Fuel Consumption Database (IMO DCS)”.

Below graph summarizes the implementation timeline for ships in service :

MEPC.1/Circ.913 clarifies that :
For ships flying the flag of the Administration which implements the amendments early (1 January 2025):
.1 the SEEMP should undergo revision and verification by the Administration, or its recognized organization, to incorporate a description of the methodology intended for collecting data with enhanced granularity before 1 January 2025 or the delivery date for ships delivered on or after 1 January 2025. Those planning to retrofit flow meters or other methodologies should complete these actions within the same time frame; and
.2 data will be collected and reported with an enhanced level of granularity throughout the entire year of 2025 and beyond.
For ships flying the flag of the Administration which implements the amendments on the entry-into-force date (1 August 2025):
.1 the SEEMP should undergo revision and verification by the Administration, or its recognized organization, to incorporate a description of the methodology intended for collecting data with enhanced granularity before 1 January 2026. Those planning to retrofit flow meters or employ other methodologies should complete these actions within the same time frame;
.2 data will be collected with the existing level of granularity throughout the entire year of 2025 and, therefore, the data reported at the beginning of 2026 will be based on this consistent level. Data will be collected and reported with the enhanced level of granularity from 1 January 2026 and beyond; and
.3 ships delivered on or after 1 August 2025 should collect data at the enhanced level of granularity from the date of delivery and the data reported at the beginning of 2026 will be based on appendix IX of MARPOL Annex VI in the annex to resolution MEPC.385(81), as this provides consistent data collection and reporting for such ships on or after the entry-into-force date.

Early Implementation of revised DCS

The application of early implementation is subject to the instructions of the flag Administration.
To date, the majority of instructions from flag administrations received encourage shipowners to collect data from 1 January 2025, without making it mandatory (i.e. voluntary implementation).

Revision and Review of SEEMP Part II

As a consequential aspect of implementing the revised DCS relating to the inclusion of data on transport work and on an enhanced level of granularity (resolution MEPC.385(81)), IMO adopted resolution MEPC.388(81) on amendments to the 2022 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) 1.
1 IMO agreed on a consolidating version 2024 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) (resolution MEPC.395(82))

All SEEMP Part II shall be revised, in a timely manner and submitted for review (i.e. refer to the above provisions of MEPC.1/Circ.913), to describe the methodology that will be used to collect:
- Fuel oil consumption per consumer type
- Other additional data (mandatory & voluntary)

Note: 2022 Guidelines for the development of a Ship Energy Efficiency Management Plan (SEEMP) (resolution MEPC.346(78), as amended by resolution MEPC.388(81)), provide methods for collecting information for the purpose of compliance with appendix IX of MARPOL Annex VI. These methodologies primarily rely on either the use of flow meters or fuel oil tank monitoring on board. Those opting to rely on retrofitting flow meters and/or fuel oil tank monitoring on board will need to allocate additional time for their installation and amendment of procedures.

Ship owners and managers are invited to take all appropriate actions including the revision of their procedures and management plan in due time.