What is SEEMP Part III?

To support ships’ energy performance and efficiency objectives, the International Maritime Organization (IMO) has developed the Ship Energy Efficiency Management Plan (SEEMP). This three-part operational measure establishes a cost-effective mechanism for improving ship energy efficiency over time. 

The SEEMP is also a key tool in enabling shipowners to determine their vessels’ carbon intensity profiles and meet IMO emissions reduction targets. 

Now, to support the new operational carbon intensity reduction requirements as per MARPOL Annex VI reg.28, owners must develop a ship operational carbon intensity plan (SEEMP Part III).

What is the deadline for developing and the verifying SEEMP part III?

SEEMP part III has to be developed by the shipping company or owner and verified by the ship’s administration, before 1 January 2023. This applies equally to existing vessels or to newbuilds before they come into service. Verification may also be undertaken by an organization authorized by the administration.  

SEEMP part III timeline

Development of SEEMP Part III

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    What are the three parts of the SEEMP? Which have to be reviewed or verified by the administration?

    Shipping companies are required to develop a three-part SEEMP that is compliant with IMO guidelines for each of their ships:

    SEEMP Part I

    • Came into force on January 1, 2013. 
    • Required all ships over 400 GT and making international voyages to have SEEMP documentation onboard. 

    SEEMP part II 

    •  Came into effect on January 1, 2019 as part of the IMO Data Collection System (IMO DCS). 
    • Required every ships over 5,000 GT to collect data and report on their fuel oil consumption. 
    • SEEMP part II must be verified by the relevant flag administration or any organization duly authorized by it.



    SEEMP part III

    •  Will come into effect on January 1, 2023, and concerns ships’ Carbon Intensity Indicator (CII) and ratings. 
    • Will require ships over 5,000 GT (that fall into one of the categories listed in regulation 26) to describe and support ship’s carbon intensity objectives, using data from the IMO DCS to assess their performance. 
    • SEEMP part III will contain a ship’s CII calculation methodology, the required CII values for the next three years, a three-year implementation plan, and self-evaluation and improvement procedures. 
    • SEEMP part III must be verified by the relevant flag administration or any organization duly authorized by it.
    Sebastien Crouzet

    International Statutory Affairs Manager

    Bureau Veritas M&O

    As requirements for SEEMP expand, owners and operators are playing catch-up, reworking their SEEMP to maintain compliance. Bureau Veritas takes the burden off clients, using our industry experience, regulatory expertise, and knowledge of energy-saving devices to help create, improve and approve SEEMP.

    Bureau Veritas services for SEEMP part III

    All SEEMP are ship-specific, providing ship owners and operators with a tailored approach to managing operations and improving energy efficiency. As a classification society, Bureau Veritas has longstanding experience working with all vessel types and a deep understanding of clients’ needs and operations. We provide independent regulatory services for shipowners looking to comply with SEEMP part III requirements, including the intermediary and final verification of technical files. Our experts are by your side at all times, from SEEMP part III development, to verification, to optimization.

    VeriSTAR Green, is our web application to aid the development of  SEEMP part II and part III, guiding shipping companies through the requirements of energy efficiency management regulations. It is an efficient tool both for reporting the fuel oil consumption for IMO DCS and calculating values for CII.

    Support and technical advisory services

    Bureau Veritas Solutions – Marine & Offshore is a wholly owned subsidiary of Bureau Veritas that offers crucial SEEMP support. Our experts offer pre-assessment services, CII, and technical documentation review. With the help of BV Solutions M&O, operators can identify technical and operational improvement methods, and successfully implement them onboard.

    SEEMP part III FAQs

    • What is the role of SEEMP part III in the new IMO Operational Carbon Intensity Mechanism?

      The operational carbon intensity reduction requirements are based on a new operational CII.
      Every year from 2023 onwards each ship needs to calculate and report its attained annual operational CII. They will then be given a CII rating from 2024 onwards.
      In accordance with MARPOL Annex VI regulation 26.3.1., the SEEMP part III must be developed by the shipping company to be reviewed by the relevant authority or delegated verifier.

    • Does MARPOL Annex VI regulation 22 or 26 cover SEEMP?

      From 1 November 2022, amendments to MARPOL Annex VI entered into force, which included the renumbering of several regulations and paragraphs. Previously regulation 22 covered SEEMP, but in the 2021 Revised MARPOL Annex VI this topic is now under regulation 26.

    • Which ships are required to develop and maintain SEEMP Part III?

      Every ship of 5,000 GT and above covered by one or more of the categories in the regulations listed below and by MARPOL Annex VI chapter 4.


      Ship type


      Bulk carrier


      Combination carrier




      Cruise passenger ship


      Gas carrier


      General cargo ship


      LNG carrier


      Refrigerated cargo carrier


      Ro-ro cargo ship


      Ro-ro cargo ship (vehicle carrier)


      Ro-ro passenger ship



    • What has to be included in the initial SEEMP part III?

      At minimum, a ship’s SEEMP part III must include:

      • A description of the methodology to calculate the ship's attained annual operational CII as required by MARPOL Annex VI regulation 28 and the processes to be used to report this value to the ship's Administration
      • The vessel’s required annual operational CIIs for the next three years, as specified in MARPOL Annex VI regulation 28
      • An implementation plan documenting how the required annual operational CIIs will be achieved during the next three years
      • A self-evaluation and improvement procedure
    • Should SEEMP part I be amended in connection with the development of SEEMP part III?

      Ships that are subject to SEEMP part III and CII are strongly encouraged to review and revise SEEMP part I to reflect the actions taken to achieve CII compliance. They will have to ensure the goals set in SEEMP part I are consistent and that their required CII for the next three years is included.

    • What statutory document attests to SEEMP part III verification?

      Before 1 January 2023, all ships to which regulation 28 applies must have it ensured that their SEEMP complies with regulation 26.3. The SEEMP will be assessed by the administration or a delegated verified, who will issue a Confirmation of Compliance (CoC) if the assessment is satisfactory.

    • What is the verification regime of the SEEMP Part III?

      SEEMP Part III is a dynamic plan that must be adapted over time – at least every three years – according to the effectiveness of the measures implemented. SEEMP part III therefore has a more elaborate survey regime than SEEMP Part II.

      The verification and audit process for the SEEMP Part III should normally – over a three-year cycle – involve:  

      • Initial verification
        Before 1 January 2023, each ship must develop a SEEMP that complies with MARPOL Annex VI regulation 26.3.1. This should also document how the required CIIs will be achieved during the next three years.
      • Additional verification
        The ship may be subject to an additional survey each year. If the ship is rated D for three consecutive years or rated E once, a plan of corrective actions has to be developed and included in the SEEMP Part III. This plan will be subject to verification and re-issuance of the CoC.
      • Periodical verification
        The implementation measures shall be provided in the SEEMP Part III for the next three year and therefore every 3 year the SEEMP Part III is subject to a periodical verification.
      • Company audit
        The ship may be subject to periodical company audit to verify the correct implementation of the measures contained in the plan.

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      SEEMP Part III Verification

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