As of 2024 ships transporting cargo or passengers will have to monitor and report their emissions on journeys to and from EU ports as part of the EU Emissions Trading System (EU ETS). In 2025 offshore ships from 400 GT and above will also fall under the EU Monitoring, Reporting and Verification (EU MRV) regulation and from 2027 onwards, offshore ships of 5,000 GT or above will need to surrender emission allowances under EU ETS.
Around onefifth of the ships in the EU member states’ fleet operating in offshore activities, are owned by Dutch shipowners. Therefore, it is highly relevant for the Dutch industry that the regulation is effective, workable and enforceable, keeping evasion and carbon leakage as low as possible and, the level playing field intact. The Dutch ministry of Infrastructure and Water Management identified several points in the amended EU MRV regulation and EU ETS directive that need to be addressed to overcome issues that arise when implementing the regulation. Therefore, the ministry of Infrastructure and Water Management requested CE Delft to describe the challenges and make suggestions how to improve the functioning of these instruments.
In the executed study two main concerns we address the lack of a clear definition which ships are classified as offshore ships in the regulation and the definition of a port call for offshore ships based on a crew change.
First, adding a definition for offshore can improve clarity for the sector, can maintain the level playing field, limit the risk of evasion and maximize the environmental impact. To that end we propose a definition in which offshore ships are all ‘non-transport ship types’ and ‘other ship types’ (i.e. not included by other ship definitions in the regulation).
Second, in most cases within the maritime non-transport segments a crew change doesn’t take place when the ship calls at a port. This raises the question whether a crew change port call is a suitable way to monitor and report emissions of offshore ships, or that offshore ships without crew changes are unintentionally excluded by the set definition. Therefore, we discuss two more appropriate options to define a port call of which the realisation of virtual ports at worksite is the most adequate to be able to define voyages that can be registered as part of the legistlastion with a limited risk of evasion, higher effectiveness of EU ETS and with maintaining a level playing field.