Questions & Answers
Q1: Is the verification of the attained EEXI to be carried out by the ships' RO or may this be done by another RO?
A1: Verification of the attained EEXI includes verification of the EEXI technical file, and possibly verification of the Onboard Management Manual (OMM) and the shaft/engine power limitation. Therefore this can only be carried out by the RO that Classes the ship for Hull and Machinery. See for more information Resolution MEPC.351(78).
Q2: Is the verification of the CII to be carried out by the ships' RO or may this be done by another RO?
A2: Verification of the CII may be carried out by another RO than the one that Classes the ship, since this is a verification that can be carried out remotely. It should however be the same verifier as for IMO DCS since the CII is to be calculated based on the collected and reported ship fuel oil consumption data which has been submitted to the IMO DCS.
Q3: Is an additional authorization for the ROs necessary for attained EEXI / CII verification?
A3: Since the ROs are already authorized to conduct the surveys and to issue the certificates as regulated in MARPOL Annex VI, and the new requirements regarding EEXI and CII are amendments to MARPOL Annex VI, no separate authorization is required. The Appendix to Annex 1 to the Agreement between the NL and RO dated 03 April 2014 already provides for this.
Q4: Can other parties than the ROs perform verifications for EEXI and CII?
A4: For the reasons explained in Q1 and Q2, the NSI will not authorize other parties than the ships' ROs.
Q5: When shall the verification of the attained EEXI be carried out?
A5: During the first IAPP survey after 1-1-2023, as per MARPOL Annex VI, regulation 5.4.7. De-harmonization of the IAPP is not encouraged.
Q6: When is a draught increase considered a major conversion in relation to attained EEDI / EEXI?
A6: For a draught increase without altering the hull, the unified interpretation (as per MEPC.1/Circ.795, as revised) to MARPOL Annex VI, regulation 2.2.17(.1) is to be used and is thus not considered a major conversion. In general increasing the draught has a positive impact on the attained EEDI / EEXI. With reference to the aforementioned circular, the NSI considers a (permanent) decrease of the ship's draft as a major conversion.
Q7: Is there a margin for the application of an Overridable SHaPoLi?
A7: A SHaPoLi of less than 1% of the MCR does not need to be applied since this falls within the measurement uncertainty of common equipment.
Q8: Does the EEXI requirement apply to cement carriers?
A8: Yes, a cement carrier is a bulk carrier and cement carriers were also included in the calculation of EEDI reference lines, according to Resolution MEPC.231(65). See also Q&A 13.
Q9: What is a heavy load carrier in relation to EEXI?
A9: For the definition of a heavy load carrier the NSI follows the IACS recommendation 170.
An ungeared heavy load carrier is specially designed to carry outsized individual cargoes. The holds and hatches are designed for high deck loads and compared to the size of the ship, it has a low dead weight. The holds are not suitable for transporting bulk cargoes.
According to this IACS recommendation, endorsement for specific ship types mentioned shall be sought with the NSI.
Q10: Are open-top ships exempted from the EEXI requirements?
A10: Only the 'open-top notation' is not enough to be exempted from the EEXI requirements. This is still depending on the ships type and when this is an 'open-top general cargo ship' it should fulfil the EEXI requirements. When the owner wants to exempt the 'open-top general cargo ship', it has to be proven that there is a reduction in carrying capacity and / or an increased propulsion power for the ship type because of its specialized nature.
Q11: Is calculation of the attained EEXI required for ships that do not have an EEXI reduction factor applied to them?
A11: For this group of ships (i.e. the ships NOT mentioned in table 3 of regulation 25 of MARPOL Annex VI) it is not required to calculate the attained EEXI; for other type of ships, such us offshore working vessels (OSV, pipe laying vessels, diving vessels etc.), the attained- ánd required EEXI calculation is not applicable.
Q12: Is EEXI applicable to fishing vessels >400 GT making international voyages?
A12: No, fishing vessels are an exempted ship type.
Q13: Which ships fall into the scope for the EEXI?
A13: The ship categories for which reference lines were calculated and which are in the scope of EEXI, based on MARPOL Annex VI, regulation 23.1, are mentioned in Table 1 of Appendix 1 of Res.MEPC.231(65).
Q14: Which attained EEXI is to be used for a ship which falls into more than one ship category?
A14: For ships which are falling into more than one categories of ships, as per MARPOL Annex VI, regulation 23(.1), the most stringent attained EEXI, as calculated for the categories the ship falls into, shall be used.
Q15: Which CII is to be used for a ship which may fall into more than one ship category?
A15: For ships which are falling into more than one categories of ships, as per MARPOL Annex VI, regulation 28(.1), the most stringent attained annual operational CII, as calculated for the categories the ship may fall into, shall be used.
Q16: Can, for an ice-classed ship, the time in port be included in the voyage period for when applying voyage adjustments?
A16: When an ice-classed ship sails in ice conditions to and from a port within the same sea area within the same ice edge:
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the period of time the ship is in that port (port period) may be included in either the voyage period to that port or the voyage period from that port; and
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all fuel consumption for that port period may be included in the voyage adjustment to the calculation of the attained annual operational CII.
For further clarification and instructions see Resolution MEPC.355(78).
Q17: Do the Netherlands' have interpretations on the requirements for the arrangement ShaPoLi
A17: The system should comply with both Res.MEPC.335(76) and IACS Rec. No. 172 - EEXI Implementation Guidelines and it must be approved by the ships' RO.
In Section 2.1.1.3 of Res.MEPC.335(76) the general system requirements for the ShaPoLi among others include 'a control unit for calculation and limitation of the power transmitted by the shaft to the propeller(s).'
Section 6.6 of the IACS Rec. No. 172 guideline states that 'this control unit can be independent from the engine automation' and furthermore states that 'Override of limitation should be indicated by giving an alarm'.
Since Res.MEPC.335(76) does not require the ShaPoLi to operate automatically, there is no objection if a ShaPoLi is installed that does not automatically reduce engine power. This means that the power limit function specified by Res.MEPC.335(76) can be arranged as described in section 6.6 of IACS Rec. No. 172. The navigator's acknowledgement of the alarm, followed by manual reduction of speed command is considered as equivalent to automatic power limitation through the ShaPoLi system.
Q18: How should Cf factors be assigned to biofuels for CII and DCS purposes?
A18:
MEPC.1/Circ.905 provides guidance on the assignment of Cf factors for biofuels. In addition, the following applies:
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The guidance entered into effect on October 1, 2023. For DCS reporting and CII calculation for the year 2023 this guidance may be applied for the entire reporting year.
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Apart from the certification schedules mentioned in the Circular, fuels certified in accordance with ISCC EU under the sustainability criteria of the RED II are also accepted. Other certification schedules not mentioned are not accepted, but may be considered at a later stage.
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In the Circular the PoS or similar document is mentioned as a document to be provided to facilitate the verification process. In the Netherlands, where the PoS is required to be handed over by the fuel suppliers in order to comply with the RED requirements this is not possible. In these cases a copy of the PoS is considered sufficient evidence. For other certification schemes this shall be considered on a case-by-case basis.
Q19: How is the use of shore power calculated in the CII regulations?
A19: In the current regulations the use of shore power is not taken into account. Thus, ships can improve their CII by making use of shore power where available.
Q20: LNG carriers are exempted from the EEXI requirements, while Gas Carriers are not. What is the EEXI ship type designation for LNG carriers with an extended cargo list?
A20: Since the boil-off gas needs to be consumed by the main engine power reduction is not possible. Therefore LNG carriers with an extended cargo list are also exempted from the EEXI requirements.
Q21: How should DP voyages for general cargo ship be accounted for?
A21: The voyages where DP is predominantly used may be excluded from the CII reporting, since this would result in unfair category attribution.
Q22: Can regular engine performance testing be considered as engine maintenance for the purpose of use of a power reserve? Does 'engine maintenance' in section 3.1 of Res.MEPC.335(76) include regular scheduled (e.g. weekly/monthly) use of power reserve for maintenance purposes (preventing carbon buildup, etc.)?
A22: Yes, but only where specifically prescribed by the equipment manufacturers of engine and boiler for example. (Medium speed engines for example can be operated continuously down to 50% without any fouling or adjustment)
Q23: For compliance with paragraph 3.4 of Res.MEPC.335(76), as amended, is the operator of the ship to report to the NSI and/or RO?
A23: Reporting should be done to the ships' RO, and this should be mentioned in the OMM. To get an indication of the number of notifications the ships' RO is invited to forward all reports until June 30, 2024
Q24: For compliance with paragraph 3.4 of Res.MEPC.335(76), as amended, as the operator is reporting the required information to the RO, how and when does the NSI want the RO to report the findings to the NSI?
A24: The ships' RO should report to the NSI two weeks before the IMO reporting deadline using the format of the Appendix of Res.MEPC.375(80).
Q25: For compliance with paragraph 3.5 of Res.MEPC.335 (76), is the operator of the ship to report to the NSI and/or RO?
A25: Reporting should be done to ships' RO.
Q26: As the answer to Question 25 is the ship's RO, is this the RO responsible for issuing the relevant certificate?
A26: Yes
Q27: For compliance with paragraph 3.5 of Res.MEPC.335(76), what does the NSI require the operator to submit as supporting evidence? And when should the submission occur?
A27: OMM record log, or log of the ShaPoLi to be retained, in accordance with the OMM. Submission should be to ships' RO together with the report mentioned in paragraph 3.4 of the resolution. Since it is expected that the override will be activated for a limited duration (less than 8 hours) only, the reports under paragraph 3.4 and 3.5 of the Resolution may be combined. For longer periods separate reporting is required. In any case, the format of the Appendix of Res.MECP.375(80) should be used. Ships' RO shall verify the consistency with the OMM, in case of discrepancies the NSI shall be informed.
Q28: For compliance with paragraph 3.5 of Res.MEPC.335(76), does the NSI require the ships' RO to undertake a survey to confirm reactivation or replacement of the SHaPoLi / EPL system? If so, when should the survey take place, and can this survey be done by remote means.
A28: Yes, a survey is needed. Remote survey in accordance with ItoRO no. 32 – Remote Survey is allowed upon reactivation of the system, however physical verification to be carried out during the first IAPP survey following reactivation.