The 81st session of the Marine Environment Protection Committee (MEPC 81) was held in person in London (18-22 March 2024) with hybrid facilities allowing remote participation.

MEPC 81 agreed that the discussions to set up technical and economic mid-term measures to implement the Strategy will be developed through different channels. A dedicated GESAMP working group was established to provide best possible scientific and technical assessment of issues related to the implementation of LCA Guidelines. A GHG Expert-Workshop will lead the following works on the basket of mid-term measures (modelling the collecting and the distribution of revenues) in line with the CIA task force “without engaging policy discussions”. An outline of the “IMO net-zero framework” was drafted to integrate possible amendments to MARPOL Annex VI (new Chapter 5).

MEPC 81 adopted:

• Amendments to Ballast Water Management Convention regarding the use of electronic water record books
• Amendments to MARPOL Protocol I Article V for the reporting procedures of lost containers
• Amendments to MARPOL Annex VI on low-flashpoint fuels and other fuel oil related issues; marine diesel engine replacing a steam system; accessibility of the data in the IMO Ship Fuel Consumption Database (IMO DCS) ; inclusion of data on transport work and enhanced level of granularity in the IMO Consequential amendments to SEEMP 2022 Guidelines.
• Draft amendments to the 2021 Guidelines on the shaft/engine power limitation system to comply with the EEXI requirements and use of a power reserve
• Amendments to the unified interpretations of regulations 2.15 and 2.2.18 of MARPOL Annex VI
• Amendments to circular BWM.2/Circ.43/Rev.1 on the approval process for the modifications of a system that has already received type approval
• Interim guidance for ports with challenging water quality
• 2/Circ.82 on Guidance for the temporary storage of treated sewage and/or grey water in ballast tanks
• Circular on recommendations for the carriage of plastic pellets by sea in freight containers

MEPC 81 approved:

• Designation of ECAs in the Canadian Arctic waters and the Norwegian Sea, for adoption at MEPC 82
• An action plan to address barriers to the uptake of the Guidelines on reduction of underwater noise from shipping (MEPC.1/Circ.906) with an experience-building phase set to three years, up to 2026

MEPC 81 discussed the following matters:

• Ballast Water Management Convention Review
• Regulations on Black Carbon emissions from international shipping impacting the Arctic, for consideration at MEPC 82
• Guidance on the carriage requirements of biofuels and biofuel blends by bunker vessels, for consideration by ESPH group
• Guidance for the use of biofuels and biofuels blends, for consideration at MSC 108
• Guidance on consistent reporting of VLSFO, ULSFO, biofuels and e-fuels to the IMO DCS, for consideration at MEPC 82

A summary table of finalized/adopted texts is provided in the appendix of this report (see page 13).

DECISONS OF OTHER BODIES

MEPC 81 considered the outcomes of other IMO Committees such as the Maritime Safety Committee and Sub- Committees, on matters of relevance to its work.

Considering MSC 107 urgent outcome in respect of fuel sampling, MEPC 81:

• approved the draft MSC-MEPC circular on guidelines for the sampling of fuel oil for determination of compliance with MARPOL Annex VI and SOLAS Chapter II-2, with view to approval by MSC 108 (May 2024). The Committee clarified the definition of “fuel oil” as set up in regulation MARPOL Annex VI, including “oil fuel” as defined in MARPOL Annex I for the application of regulation 4.2.1. of SOLAS Chapter II-2;
• revoked resolution 182(59) on the 2009 Guidelines for the sampling of fuel oil for determination of compliance with the revised MARPOL Annex VI when the joint MSC-MEPC circular is issued.

CONSIDERATION AND ADOPTION OF AMENDMENTS TO MANDATORY INSTRUMENTS

Ballast Water Management Convention regarding the electronic ballast water record book

Following the adoption at MEPC 80 of resolution MEPC.372(80) on Guidelines for the use of electronic record books under the BWM Convention, MEPC 81 adopted consequential amendments to regulation A-1 and B-2 of the BWM Convention for providing a definition of an electronic record book as well as associated approval requirements by the Administration.

Scope of application

• Entry into force: 1 October 2025
• Application: all ships covered by the BWM Convention

Amendments to Article V of Protocol I of MARPOL for the reporting procedures of lost containers

MEPC 81 adopted the amendments to Article V of Protocol I of MARPOL concerning revised reporting procedures for the loss of containers. In case of loss of containers, reporting shall be done in accordance with SOLAS regulations V/31 & V/32 on danger messages:

• Regulation 31 states that every master shall be responsible to pass on information about navigation dangers to ships around and competent authorities by all means at his disposals;
• Regulation 32 gives details of information required in danger

Scope of application

• Entry into force: 1 January 2026
• Application: all ships

Amendments to MARPOL Annex VI

MEPC 81 adopted the following amendments to MARPOL Annex VI on:

· low-flashpoint fuels and other fuel oil related issues

• New definitions on “fuel oil” and “gas fuel” in regulation 2
• Requirements in regulation 14 paragraph 12 regarding In-use fuel oil sampling point
• Requirements in regulation 18 regarding Fuel oil availability and quality
• Modifications of the IAPP Certificate Form in Appendix I

· marine diesel engine replacing a steam system

• modifications in regulation 2.2 regarding Tier requirements for a major conversion
• revised MEPC resolution on associated guidelines in respect of non-identical replacement engines not required to meet the Tier III limit (including template for reporting)

· accessibility of the data in the IMO Ship Fuel Consumption Database (IMO DCS)

• New paragraph 14 in regulation 27 allowing the IMO to share data with analytical consultancies and research entities, under strict confidentiality rules and on an ad-hoc
• New paragraph 15 in regulation 27 allowing a company to share non-anonymized data on their fleet’s fuel consumption reports to the general public

· inclusion of data on transport work and enhanced level of granularity in the IMO DCS

• New requirements in Appendix IX: total transport work, laden distance travelled (nm) (on a voluntary basis), total amount of onshore power supplied (kWh), installation of innovative technology (if applicable), fuel consumption by fuel oil type per consumer type and fuel oil consumption while the ship is not under way.

Scope of application

• Entry into force: 1 August 2025

o Early implementation from 1 January 2025 was considered necessary in order to avoid double collecting and reporting, as it was recognized that the entry into force on 1 August 2025 may impact the granularity of data to be collected before and after that date.

• Application: all ships

HARMFUL AQUATIC ORGANISMS IN BALLAST WATER

Ballast Water Management Convention Review

MEPC 80 previously established a Correspondence Group (CG) on the Review of the BWM Convention to define objectives for changes to specific Convention provisions, or the need for new provisions, to address the issues addressed in the BWM.2 circular on the Convention Review Plan under the experience-building phase associated with the BWM Convention. It is expected that the amendments to the Convention should be ready for adoption at MEPC 85 (autumn 2026) and entry into force in 2027. The CG was re-established to continue the work and will submit a report at MEPC 83.

Amendments to the Guidance for Administrations on the type approval process for ballast water management systems (BWM.2/Circ.43/Rev.1)

Several delegations noted the lack of harmonized and swift approval process for the modification of the components of an already type approved ballast water management system by its manufacturer. In that sense, it was suggested to amend circular BWM.2/Circ.43/Rev.1 adding a section dedicated to harmonizing the recommendations pertaining to the approval process for the modifications of a system that has already received type approval.

Delegations are invited to work intersessionally to submit concrete proposals to MEPC 82.

Interim Guidance on the application of the BWMC to ships operating in ports with challenging water quality

It is recognized that the water quality in ports may be challenging for some ballast water treatment systems (BWTS). MEPC 81 finalized an Interim Guidance on the application of the BWM Convention to ships operating in challenging water quality (CWQ).

It is designed to guide ships and Administrations in planning for operations in CWQ by including principles, definitions, a process for managing CWQ (that includes BWMS bypass as a last resort), a recommended procedure for decontaminating ballast tanks, as well as guidance on record-keeping and communication. It also includes guidance for BWMS manufacturers in supporting this planning, and guidance for port State control in assessing compliance with the Convention after operations in CWQ.

Guidance on temporary storage of treated sewage and/or grey water in ballast tanks

The industry is aware that ships may store treated sewage and/or grey water in their ballast tanks. While it is a common practice, it is not clear whether it complies with the BWMC or not. The question was raised at MEPC 78, without consensus, and the discussion was deferred to MEPC 81.

MEPC 81 finalized the guidance on temporary storage of treated sewage/ grey water in ballast tanks. The following elements were considered such as separation of grey and/or treated sewage with ballast water, discharge of treated sewage compliance with MARPOL Annex IV, development of uniform procedures (particularly the D-2 standard), recording in the Ballast Water Record Book…

Other matters

MEPC 81 also considered:

• As part of the BWM Convention review, challenges encountered by ships engaged in short voyages in water bodies shared by Parties to the BWM Convention, where compliance with the Convention becomes impractical due to the inability to conduct ballast water exchange or treatment;
• Matters related to the frequency and the type of sampling and analysis of ballast water discharge at flag State surveys to ensure ballast water management systems (BWMS) meet regulation D-2.

AIR POLLUTION PREVENTION

Clarification regarding Engine International Air Pollution Prevention (EIAPP) Certificate re- issuance at change of flag of a State

The reissuance of an EIAPP Certificate (NOx Reg 13, Annex VI) at the time of change of flag is required by the Administration which is responsible for surveying the validity of the certificate. Despite arguments (one-time certification unless any major reconversion), the request to consider as valid the initial certificate was not accepted.

Amendments to the 2021 Guidelines for Exhaust Gas Cleaning Systems (resolution MEPC.340(77))

The Committee decided that there was no sufficient support for the proposed amendments to the 2021 Guidelines for exhaust gas cleaning systems (resolution MEPC.340(77)) and invite interested Member States and international organizations to submit proposals to a future session.

ENERGY EFFICIENCY OF SHIPS

MEPC 81 considered reports of Correspondence Groups and established a Working Group to finalize work and progress on other matters.

Carbon Intensity Indicator (CII) review

Several delegations expressed the view that the CII system should be considered in its interim form while the review is completed, however the Committee turned down the request recalling the agenda of the review to be finished by 1 January 2026.

Editorial corrections in the CII Guidelines

The Committee requested the Secretariat to issue a corrigendum amending the definition of “capacity” in paragraph 4 of the CII Guidelines, G5 (attained annual operation CIII formula – resolution MEPC.355(78)), using DWT or GT to be in line with that used in the CII Guidelines, G1 (resolution MEPC.352(78)), taking into account that the CII Guidelines, G5 are an extension of the CII Guidelines, G1.

Review of the data quality and integrity of the IMO DCS for the implementation of current and future regulatory GHG measures

Concerns were raised regarding the data quality, integrity and the verification process of the IMO DCS which could be a source of potential risks and vulnerabilities for the enforcement of short-term measures and future mid- term measures. The Secretariat was tasked to conduct a review of the suitability of IMO DCS focusing and suggest possible solutions to address them.

Amendments to SEEMP 2022 Guidelines and related guidelines regarding IMO DCS granularity reporting

MEPC 81 adopted the following draft amendments:

Amendments to 2022 Guidelines SEEMP for the development of a Ship Energy Efficiency Management Plan (SEEMP) reflecting amendments to appendix IX of MARPOL Annex VI on enhanced granularity of the IMO DCS:

• transport work metrics should be reported for each ship type (tables for calculation were provided)
• the term «combustion system» was replaced with «consumer type» (amendments to appendix IX of MARPOL Annex VI):

• definition of “consumer type” was added in section 2
• amendments to section 7 of the SEEMP guidelines to identify possible methods for the collection of fuel oil consumption per consumer type (BDN, flow meters, bunker fuel tank monitoring onboard)
  • regarding the total amount of onshore power supplied, paper-based documents are allowed to include the information provided by the port or electricity provider in electronic record.

Amendments to 2022 Guidelines for administration verification of ship fuel oil consumption data and operational carbon intensity (resolution MEPC.348(78)):

• regarding the sample format of the collected data summaries, to reflect the enhanced granularity of IMO DCS

Amendments to the 2021 Guidelines on the shaft/engine power limitation system to comply with the EEXI requirements and use of a power reserve

Emerging risks associated with the use of shaft or engine power limitation systems on ships were addressed based on the experience of maritime pilots. Therefore, MEPC 81 agreed to:

• modify technical requirements to allow for a shaft power limitation system where there is no physical shaft power limitation. Instead, if the power limit is exceeded, a bridge alarm will be triggered, and data recording commences;
• allow immediate use of power reserve by pre-emptively un-limiting the SHaPoLi/EPL when hazards are

MEPC 80 had agreed that Administrations should annually report uses of a power reserve to IMO according to a reporting procedure. In that sense, MEPC 81 approved the draft MEPC Circular on procedure prepared by the Secretariat.

Amendments to the unified interpretations of regulations 2.2.15 and 2.2.18 of MARPOL Annex VI

Amendments to the unified interpretations to regulation 2.2.18 of MARPOL Annex VI

It was agreed to modify the unified interpretations to regulation 2.2.18 of MARPOL Annex VI to explicitly specify the applicable required EEDI of each Phase for the five ship categories: LNG carrier, cruise passenger ship, ro- ro passenger ship, ro-ro cargo ship (vehicle carrier) and ro-ro cargo ship, delivered on or after 1 September 2019, to ensure unified implementation of the EEDI requirements of MARPOL Annex VI.

Amendment to the unified interpretation to MARPOL Annex VI to regulation 2.2.15 of MARPOL Annex VI to clarify the term «heavy load carrier» with IACS Recommendation.170

It was agreed to include the recommendations in IACS Rec.170 and maintain the discretion of Administrations in determining whether a ship can be considered as a «heavy load carrier», taking into full account the complexity of the ship types that may be covered under «heavy load carrier».

The IACS Rec.170 recommends three types of ships to be considered as «heavy load carrier» in the context of regulation 2.2.15: (Heavy Load) Deck Carriers, Semi-submersible Project Cargo Carriers and Semi-submersible (Heavy load) Deck Carriers (including dock lift ships). In addition, three types of ships are also recommended to be   considered   as   «heavy   load   carriers»   subject   to   endorsement   by    the    flag    Administration: Heavy Lift Multi-Purpose ships, Premium Project carriers and Project Cargo Carriers.

The new circular will be circulated as MEPC.1/Circ.795/Rev.9.

Guidance on the carriage requirements of biofuels and biofuel blends by bunker vessels

It was recalled that MEPC 78 agreed to a unified interpretation allowing biofuel blends with up to 30% biofuel to be used on board ships, however ships certified under MARPOL Annex I for the carriage of oil products may only carry biofuel blends with up to 25% biofuel. This draft guidance would allow the conventional bunkering vessels certified for the carriage of oil fuels under MARPOL Annex I to transport up to B30 biofuels.

It was agreed that this matter does not fall under the scope of MARPOL Annex I without a revision of the IBC Code and therefore invited the Evaluation of Safety and Pollution Hazards of Chemicals (ESPH) group to further consider this matter at its next session (14-18 October 2024).

Guidance for the use of biofuels and biofuels blends

Following the adoption by MEPC 80 of the Interim guidance on the use of biofuels under regulations 26, 27 and 28 of MARPOL Annex VI (DCS and CII) (MEPC.1/Circ.905), several delegations addressed safety issues such as the sulfur and water content (HVO), crew familiarization, fuel handling. The proposed guidance for the use of biofuels and biofuels blends was considered and shall be transmitted to MSC 108 (May 2024).

Recategorization of LNG carriers considered as gas carriers into the LNG carriers category in the IMO DCS and CII

MEPC 81 agreed that all LNG carriers currently categorized as gas carriers should be reported as LNG carriers for DCS reporting and CII. The Secretariat was requested to recalculate the AER of the LNG and gas carrier fleet for 2021 and 2022 once the recategorization was completed. It was also noted that this recategorization should not be interpreted to affect the ship type indication on a ship’s IEEC and should not pre-judge the possible outcome of the CII review process.

Guidance on consistent reporting of VLSFO, ULSFO, biofuels and e-fuels to the IMO DCS

The proposed guidance considers that for biofuels that meet the requirements of MEPC.1/Circ.905, only the mass of the bio component as identified in the Proof of Sustainability should be reported to the IMO DCS as a biofuel, and that if any biofuel is used that does not meet the requirements of MEPC.1/Circ.905, consideration should be given to reporting such biofuels separately from both fossil fuels and biofuels.

The Committee invited interested Member States and international organizations to submit proposals for unified interpretation for the consistent reporting of VLSFO, ULSFO biofuels and e-fuels to MEPC 82.

REDUCTION OF GHG EMISSIONS FROM SHIPS

MEPC 81 considered that further work was required for the development of the basket of mid-term measures and therefore (re)established the following intersessional experts working groups:

• GESAMP Working Group on Life Cycle GHG Intensity of Marine Fuels (GESAMP-LCA WG);
• Fifth GHG Expert Workshop on the further development of the basket of mid-term measures (GHG-EW 5) (a two-day expert workshop in July);
• ISWG-GHG 17 (23-27 September 2024);
• Correspondence group on LCA (submit report to MEPC 83 in April 2025).

LCA Guidelines

MEPC 81 adopted the draft MEPC resolution on the 2024 Guidelines on Life cycle GHG intensity of marine fuels (MEPC.391(81)). The amendments mainly include more detailed requirements regarding the calculation of the default emission factors as well as considerations related to onshore power supply.

The Correspondence group on LCA Guidelines was re-established to work on other social and economic sustainability themes/aspects of marine fuels and report to MEPC 83.

Additionally, MEPC 81 agreed to establish a GESAMP Working Group on Life Cycle GHG Intensity of Marine Fuels (GESAMP-LCA WG) for a scientific review of the LCA Guidelines and submit a report to MEPC 82. In parallel, the working group on Air pollution and Energy Efficiency at MEPC 81 discussed various topics such the measurement and verification of Tank-to-Wake emissions of methane (CH4), nitrous oxide (N2O) and other GHGs, engine certification issues and the quantification of onboard methane slip. A Correspondence group was established to further consider matters related to measurement and verification of CH4 and N2O emissions and onboard carbon capture. Special attention was given to the need to ensure coordination between these workstreams (GESAMP-LCA WG and CG on LCA) to avoid any overlaps and duplication.

Proposals related to onboard carbon capture

MEPC 81 considered several proposals related to onboard carbon capture and the use of onboard carbon capture (OCC) technology onboard ships. MEPC 81 agreed establish a Correspondence group to develop a work plan on the development of a regulatory framework for the use of onboard carbon capture. A report will be submitted to MEPC 83.

The GESAMP-LCA WG will consider system boundaries of the LCA Guidelines in relation to onboard carbon capture.

FOLLOW-UP WORK EMANATING FROM THE ACTION PLAN TO ADDRESS MARINE PLASTIC LITTER FROM SHIPS

It was recalled that resolution MEPC.310(73) adopted in October 2018 agreed to keep the Action Plan to address marine plastic litter from ships (Action Plan) under review to ensure the effectiveness of the actions. The review of the actions within the Action Plan is also referred to in resolution MEPC.341(77) which should precede a review of the Strategy to Address Marine Plastic Litter from Ships in 2025 to achieve zero plastic waste discharges to sea from ships. The review was deferred to MEPC 82 for consideration.

POLLUTION PREVENTION AND RESPONSE

Detailed information on PPR work is available in BV Summary for PPR 11, February 2024.

Due to the proximity of PPR 11 and MEPC 81, the outcome of PPR 11 will be submitted to MEPC 82 for consideration with the exception of one urgent matter regarding the approval by MEPC 81 of the draft MEPC circular on recommendations for the carriage of plastic pellets by sea in freight containers.

MEPC 81 took note of the legal advice on the use of exhaust gas cleaning systems (EGCS) done by Secretariat as an alternative compliance mechanism under MARPOL Annex VI and its relationship with the legal framework of the UN Convention on the Law of the Sea (UNCLOS) and deferred for consideration at MEPC 82.

REPORTS OF OTHER SUB-COMMITTEES

MEPC 81 considered reports of Sub-committees III 9 (implementation of IMO instruments), CCC 9 (carriage of containers and cargoes).

In relation to work finalized by SDC 10, MEPC 81 approved an action plan to address barriers to the uptake of the Guidelines on reduction of underwater noise from shipping (MEPC.1/Circ.906) with an experience-building phase» (EBP) set to three years, up to 2026.

Identification and protection of Special Areas, ECAs and PSSAs

Designation of ECA in the Canadian Arctic waters

MEPC 81 agreed to the draft amendments to MARPOL Annex VI to regulations 13 and 14 and appendix VII (Emission Control Areas) to designate Canadian Arctic waters as an ECA for the control of nitrogen oxides (NOx), sulphur oxides (SOx) and particulate matter, with a view towards adoption at MEPC 82. The earliest entry-into-force date of the amendments would then be 1 March 2026 (16 months after adoption date).

Designation of ECA in the Norwegian Sea

MEPC 81 agreed on the proposed amendments to MARPOL Annex VI to regulations 13 and 14 and appendix VII (Emission Control Areas) for the designation of the Norwegian Sea as an emission control area for nitrogen oxide (NOx) and sulphur oxides (SOx). It will be further discussed at MEPC 82. The earliest entry-into-force date of the amendments would be 1 March 2026 if adopted at MEPC 82. The geographical delimitation of the proposed ECA area is shown in the figure below.

ANY OTHER BUSINESS

Implementation of the Hong Kong Convention

 

The entry-into-force conditions of the Hong Kong Convention were met on 26 June 2023 and, therefore, the Convention will enter into force on 26 June 2025.

MEPC 81 approved the reporting formats under Article 12 of the Hong Kong Convention and the development by IMO of a new GISIS module on ship recycling for Parties to the Convention to fulfil their obligation of communication of information required by the Convention. The Committee also agreed to inform the Executive Secretary of the Basel, Rotterdam, and Stockholm Conventions about the Hong Kong Convention’s impending entry into force and requested further consideration on their interplay.

Parties to the Hong Kong Convention are invited to submit to the Organization, by email (med@imo.org), the information on ship recycling facilities and the two annual lists of ships required to be reported in accordance with sub-paragraphs 1, 4 and 5 of Article 12 of the Hong Kong Convention, until the GISIS ship recycling module has been released.

 

This summary report has been prepared on the closing day of the Committee meeting, based on IMO Working papers and Plenary comments. Resolutions, Circulars and other IMO references may be rectified on publication of final versions by the IMO Secretariat.

 

 

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