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EU MRV and EU ETS – “offshore vessel” has been defined

Offshore vessels above 400 GT, will from 1 January 2025 be required to report their GHG emissions data in accordance with the EU MRV regulation. From 1 January 2027, offshore vessels above 5000 GT, will be included in the EU ETS. Whether offshore vessels between 400 and 5000 GT will be included, will be reviewed by 31 December 2026.
| Article | Written by Tone Tafjord Seth and Yannis (Ioannis) Litinas
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The uncertainty regarding what qualifies as an “offshore vessel” has now been resolved, as the European Commission on 16 October 2024 adopted a Delegated Regulation amending the EU MRV Regulation 2017/757. This will also apply for the EU ETS.

In its introduction to the new Delegated Regulation, the Commission has acknowledged that multiple players in the industry argued for a negative definition where only those vessels not included should be listed. However, the Commission has found that this will make it too broad and has instead provided a comprehensive list over the vessel types to be included.

The following vessels “designed or certified to perform services activities offshore or at offshore installations”, are covered:

Thus the focus is not on the actual activity of the vessel, but what the vessel is designed or certified to do.  In the determination of type of vessel, it is relevant to review the vessel’s statutory certification, class notation and any other relevant documents.

It seems that Platforms, rigs (including jack-ups and semi-submersible), tugs and icebreakers are not included in this list. In our opinion, it is likely that we will see certain discussions on how to interpret the vessel types set out in the list.

It is expected that the European Commission will also follow up with further guidance as there are still uncertainty on certain matter such as how terms such as “port calls” and “voyages” should be understood for offshore vessels.


The responsible party
The responsible party under the MRC Regulation is the owner unless it has been explicitly mandated to the ISM company and notified to the relevant authority.


What now?
Owners of offshore vessels falling within the definition must

  • If required, delegate the responsibility for reporting to the ISM company and notify the relevant authority.
  • By 31 December 2024, develop a monitoring plan and have this verified – by 31 December 2024.
  • Within three months after its first port call to the EEA, submit its monitoring plan.
  • 1 January 2025, start emissions data collection.
  • By 30 March 2025, verity data collected in 2025.
  • Before 1 January 2027, for offshore vessels falling within EU ETS, opening of a Maritime Operator Holding Account (MOHA) account or ensure that the responsibility is properly delegated to the ISM company.

 

Read more in this article from DNV.