Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels
Effective Dates:
Amendments enter into force: 1 August 2025
Existing ships must comply: from 1 January 2026
New ships delivered after 1 August 2025: compliance from entry into service
IMO has updated the Data Collection System (DCS) under MARPOL Annex VI to improve the accuracy and granularity of fuel consumption and efficiency data. Key changes include:
Detailed Fuel Reporting
Fuel consumption must now be recorded per consumer type (main engines, auxiliary engines, boilers, etc.) and per fuel type.
Fuel used while the ship is not under way (e.g., at berth, drifting, or during ship-to-ship operations) must also be included.
Onshore power usage, installation of energy-saving technologies, and total transport work must also be reported.
Voyage-Based Reporting
Distance travelled and hours under way are only recorded when the ship is “under way” (FAOP → EOSP).
Fuel consumption while not under way is reported as a total for that period, without distance or hours.
This replaces traditional daily reporting to improve accuracy and simplify submissions.
SEEMP Part II Updates
The Ship Energy Efficiency Management Plan (SEEMP) Part II must be updated and reviewed by the flag Administration or Recognized Organization.
Existing ships: review before 1 January 2026
New ships delivered after 1 August 2025: review before entering service
Methods for Data Collection
Primary methods: flow meters and bunker tank monitoring (recommended for accuracy)
Secondary methods: subtraction or estimation (require justification and approval)
Why These Changes Were Made
To improve accuracy of fuel consumption and emissions reporting.
To incentivize ships to reduce idle fuel consumption at ports or during anchoring.
To align reporting with Carbon Intensity Indicator (CII) and IMO decarbonization goals.
Implications for Shipowners and Managers
Ensure equipment and procedures for fuel monitoring are in place.
Update SEEMP Part II and submit for review before the deadlines.
Transition to voyage-based reporting, separating “under way” and “not under way” fuel consumption.
Train crews and shore staff on new definitions and reporting methods.
Key Dates to Remember
Deadline for SEEMP Update & Data Collection for existing ships: 1 January 2026
Deadline for SEEMP Update & Data Collection for new ships: Before entry into service (after 1 Aug 2025)
In Summary:
From 2026, all ships will report more granular fuel consumption and energy efficiency data. Fuel used at berth or during idle operations still counts, but distance travelled and hours are only reported when underway. Voyage-based reporting ensures clarity, consistency, and compliance with IMO’s latest guidelines.
For further guidance or support with SEEMP updates and data collection systems contact us at mes@phrs.gr.
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