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Thursday, February 25, 2021 

Classification society DNV GL has issued a reminder to its clients that with the second DCS reporting year recently ended, it is again time for reporting data on fuel oil consumption, to DCS verifiers, as required under MARPOL Annex VI regulation 22.

To ensure a Statement of Compliance (SoC) is issued in due time before 31 May 2021 as required, the deadline for reporting 2020 data for verification is 31 March 2021. Regulation 22A of MARPOL Annex VI requires ships to collect and report data on their fuel consumption following a yearly cycle. Compliance is evident through the SoC issued annually on behalf of the flag, confirming that the required data for the previous year was submitted in accordance with the methodology and process in the ship’s SEEMP. Flag administrations have an obligation towards the IMO to ensure their ships comply. Hence, not having a valid SoC may not only be an issue with PSC, but also directly with the flag administration.

For ships to which this regulation applies, it is important that a valid SoC is readily available on board for inspection, together with the Confirmation of Compliance (CoC) for the SEEMP Part II. For vessels verified by DNV GL, data for 2020 needs to be submitted as soon as possible, at the latest on 31 March 2021, to ensure that an SoC is issued on time before 31 May 2021 as required.

DNV GL verification includes access to data in the Emissions Insights dashboard on the Veracity data platform. Emissions Insights is a monitoring tool and a smart solution for environmental emissions management, providing data sharing, monitoring, benchmarking and suggestions for improvement of individual ships and on a fleet level.

Equally important is EU MRV reporting, required in addition to the DCS reporting for vessels calling at EU ports. By 30 April 2021, companies need to submit the verified MRV Emissions Report to the EU Commission (Thetis). To ensure timely verification, companies should submit MRV Emissions Reports for verification no later than 31 March 2021.

If there are outstanding issues for any reason concerning the data reporting for 2020, or other reasons to believe that the SoC may not be issued before the deadline, DNV GL encourages ship owners/managers to contact their DCS verifier to avoid becoming non-compliant on 1 June 2021.

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