info@etsdesk.com - December 18, 2023
Step 1: Understand the new requirements and adapt your contract(s)
Where can I access the final legislative texts?
Will the Commission provide standard clauses to be inserted in
contracts?
No. Relevant stakeholders will have the flexibility to draft clauses
with regard to the transfer of costs arising from the surrendering
of EU ETS allowances, subject to applicable laws.
Will the Commission provide support if shipping companies have
questions on the new requirements?
Yes. The Commission and the European Maritime Safety Agency are
available to answer any queries from stakeholders in relation to the
new requirements under the revised MRV Maritime Regulation and the
EU ETS Directive. Please contact
fitfor55@emsa.europa.eu
for any question you may have.
Step 2: Find out which administering authority is responsible for
your company
Step 3: Open an account in the Union Registry
When should shipping companies open an account in the Union
Registry?
Shipping companies can already open trading accounts to start buying
allowances.
Provided the Registry Regulation is revised in this manner, shipping
companies will need to open a Maritime Operator Holding Account in
the EU Member State corresponding to their administering authority.
Step 4: Update the ship’s monitoring plan and submit it to the
verifier and the administering authority
By when will companies need to submit their monitoring plan for
approval by the administering authority?
Companies will need to submit a monitoring plan for each of their
ships falling within the scope of the MRV Maritime Regulation to
their administering authority by 1 April 2024. By that date, the
monitoring plan must have already been assessed as being in
conformity with the MRV Maritime Regulation by an independent
accredited verifier.
Why do companies need to revise their ships’ monitoring plans?
The monitoring plan should follow updated templates that will be
adopted by the Commission by the end of 2023. These updated
templates will reflect the revisions brought to the MRV Maritime
Regulation, in particular the inclusion of CH4 and N2O emissions
within the scope of that Regulation.
How can I know if the verifier is accredited to perform ETS-related
verification activities?
Accredited verifiers should be able to perform all verification
activities falling under the scope of the MRV Maritime Regulation
(i.e. including the verification of emissions reports, aggregated
emissions data at company level and assessment of monitoring plans).
The accreditation should be granted by national accreditation
bodies.
Step 5: Monitor your greenhouse gas emissions
As of 1 January 2024, shipping companies should monitor their
emissions in accordance with the revised monitoring plan that should
be assessed by verifiers and approved by the administering
authority.
Step 6: Prepare your emissions reports and the report at company
level and get them verified
Once per year, companies must submit an emissions report for each of
the ships under their responsibility, as well an emissions report at
company level (aggregating the data to be reported for ETS
purposes). For this purpose, companies must follow the templates
(updated templates to be available in late 2023). All ship-level and
company-level emissions reports must be verified by an accredited
verifier by 31 March of the following year (or by 28 February if so
requested by the administering authority responsible).
Step 7: Surrender EU allowances
Once aggregated emissions data at company level have been verified
and submitted to the administering authority, companies must
surrender the equivalent number of allowances in the Union Registry
by 30 September of that year.