6 | RISK WATCH | REGULATIONS RISK WATCH | REGULATIONS | 7 WITH INCREASING GLOBAL FOCUS ON SUSTAINABILITY, NEW REGULATIONS ON EMISSIONS AND ENVIRONMENTAL COMPLIANCE ARE SET TO IMPACT THE MARITIME INDUSTRY. RECOGNISING THE IMPORTANCE OF REGULATORY COMPLIANCE, BRITANNIA P&I, IN COLLABORATION WITH HFW, HAS DEVELOPED COMPREHENSIVE GUIDANCE DOCUMENTS COVERING CII, EEXI, EU ETS, FUEL EU REGULATIONS. THESE RESOURCES PROVIDE SHIPOWNERS AND CHARTERERS WITH CLEAR REGULATORY OVERVIEWS AND PRACTICAL COMPLIANCE GUIDANCE. WE ENCOURAGE ALL MEMBERS TO STAY AHEAD OF THESE CHANGES, AND WE WILL CONTINUE TO PROVIDE TIMELY UPDATES AND EXPERT INSIGHTS. DALE HAMMOND, FD&D DIRECTOR, BRITANNIA P&I, LONDON RESPONDING TO EVOLVING MARITIME EMISSIONS REGULATIONS These fuel regulations articles were written in consultation with leading global law firm HFW. Whilst care has been taken to ensure the accuracy of this information at the time of publication, the information is intended as guidance only. It should not be considered as legal advice. CII (CARBON INTENSITY INDICATOR) REGULATIONS: CII and EEXI (Energy Efficiency Existing Ships Index) have global effect and are imposed by MARPOL in accordance with Marine Environment Protection Committee (MEPC) 328(76). WHAT? An ongoing operational tool used to measure the carbon intensity generated by the operational performance/commercial activities of individual ships (e.g. CO 2 emissions per deadweight ton miles in accordance with the Annual Efficiency Ratio (AER) Metric). WHEN? • A ship is required to develop, and keep updated, an enhanced Ship Energy Efficiency Management Plan (SEEMP). • Ships collect and report fuel consumption data during the annual reporting period. • By 31 March in the subsequent verification period, the consumption data is verified. • After 30 April in the verification period, the verified consumption data is compared to the required baseline carbon intensity for the ship and an annual CII Rating of “A” to “E” will be allocated to ships. • The benchmark for carbon intensity (required CII) reduces by 2% each year until 2026, after which the IMO will consider revisions to the benchmark and the AER Metric. HOW? Ships can implement operational changes to improve carbon intensity. These changes include consumption of low carbon fuels, technical energy efficiency measures, ship speed optimisation, weather routing, route planning, and just in time arrival. EEXI REGULATIONS: WHAT? A technical measure which requires ships to meet a target energy efficiency design parameter. WHEN? EEXI is a singular obligation, where ships need to certify that they meet the target UPDATED 1 JANUARY Monitoring of GHG emissions (CO2, CH4 and N20) by cargo or passenger ships of 5000 gt or above on qualifying voyages to EEA ports of call under MRV. Liability for cargo or passenger ships of 5000gt or above to surrender EUAs for 40% of verified GHG emissions. 31 DECEMBER End of the Reporting Period One. List of shipping companies published attributing administering authorities. 31 JANUARY 27 MARCH For shipping companies listed, earliest deadline for opening a Maritime Operator Holding Account (MOHA). For shipping companies not listed, the deadline for opening a MOHA is 65 working days from the first qualifying port call. Submission of updated verified monitoring plan through THETISMRV covering CH4 and N2O emissions. Where a ship is yet to make a qualifying port call in 2024, no monitoring plan needs to be submitted until three months