Clarification on Reporting Amendments for the IMO Ship Fuel Oil Consumption Database

Decarbonization
,
1

Hello Queseanians,

In March 2024, Resolution MEPC.385(81) was adopted, introducing amendments regarding the information to be submitted to the IMO Ship Fuel Oil Consumption Database (MARPOL Annex VI Regulation 27).

These amendments are set to enter into force on August 1, 2025, with parties encouraged to consider early application starting from January 1, 2025. The amendments mandate the reporting of the following:

  • Fuel oil consumption per consumer type, including:
    • Main engine(s)
    • Auxiliary engine(s)
    • Boilers
    • Others
  • Fuel oil consumption per consumer type when the ship is not underway
  • Total amount of onshore power supplied, expressed in kWh
  • As applicable:
    • Transport work using tonne-mile.
    • TEU-mile and/or passenger-mile data.
    • Notably, containerships are required to report both tonne-mile and TEU-mile data.

It is important to note that the amendments will come into effect halfway through the calendar year, which could lead to two distinct levels of data granularity for that year, potentially causing confusion regarding the requirements for revising the Ship Energy Efficiency Management Plan (SEEMP II).

To address this issue, MEPC 82, which concluded just last week, approved MEPC.1/Circ.913, providing guidance on the application of the amendments to Appendix IX of MARPOL Annex VI (Resolution MEPC.385(81)). This circular aims to clarify any confusion surrounding the amendments.

I believe the clarification provided will be particularly useful for planning revisions to the SEEMP and the Data Collection System.

image

References:
MEPC.385(81).pdf (159.8 KB)
MEPC.1/Circ.913

2 Likes
2

Dear Stela,

Good day.

  1. As per Res. MEPC.388(81), for the collection of fuel consumption per consumer type, we have 2 methods: a) flow-meters and b) daily tank sounding.
  2. If we take a typical Chinese-built, 15-year old Bulk Carrier or Tanker, then we usually have 3 types of consumers, namely M/E, A/Es and A/B. Let’s assume we have volumetric flow-meters for M/E and A/Es, but no flow-meter on the A/B. Based on this, for the A/B none of the 2 methods above can be used (since the A/B doesn’t have a dedicated tank).
  3. Section 7.4 of Res. MEPC.388(81) states that “if there is a consumer type whose fuel consumption cannot be determined directly according to one of the methods indicated” above (such as the A/B in this case), then we can either use a) method using subtraction or b) method using estimated fuel consumption, “to the satisfaction of the Administration or RO”.
  4. Using subtraction we understand that one may keep the same methodology to gather total annual fuel consumption (BDN and tank sounding), and then use flow-meters to gather fuel consumption per consumer type for M/E and A/Es and subtract from the total to obtain the A/B consumption.

There are 2 issues I would seek advice for:
a) what happens if we have an old, volumetric flow-meter that cannot be calibrated – would Class ask for calibration records to complete annual verification? In that case we understand that the only alternative would be to install mass flow-meters, correct?
b) what about if we add to the equation an IGG? Would Section 7.4.1 of Res. MEPC.388(81) still apply (it says “if the fuel consumption for only one of the consumer types is not available”)? If not, what’s the alternative here (assuming no flow-meter on the IGG and no dedicated tank)?

Thanks in advance,

3

Hello @PTsichlis,

Effective from August 2025, the revised Appendix IX to the MARPOL Convention requires that fuel consumption be tracked for each type of consumer (MEPC.388(81)). To ensure accurate measurement of fuel oil consumption by consumer type, the methodologies primarily depend on the:

  1. use of flow meters or
  2. monitoring fuel oil tanks on board, with separate tanks designated for each consumer.

Since having separate fuel tanks for each consumer is uncommon, flow meters are generally the preferred option. They can enhance the ship’s equipment and provide more precise measurements. However, challenges may arise if a fuel flow meter is not installed for a specific consumer type. In such cases, MEPC 81 allows for alternative methods, such as subtraction or estimation.

The subtraction method can be applied when the fuel consumption data for one consumer type is unavailable. In this scenario, the consumption for that type can be calculated by subtracting the fuel consumption of the other types from the total annual fuel oil consumption.

If none of the aforementioned methods—flow meters, tank monitoring, or subtraction—are applicable, an estimation method may be used. This alternative must be approved by the Administration or an organization recognized by it. Estimations can be based on manufacturer data or historical fuel consumption over a specified period.

For example, to estimate the fuel consumption of the main engine, one could use data from the M/E shop tests, sea trials, and information from the trim and stability booklet. This would allow for daily adjustments based on weather and operational conditions, ultimately leading to an annual fuel consumption estimate. A similar approach can be applied to auxiliary engines. It is essential that this estimation method is well-documented, implemented correctly, validated, and accepted by the Administration or Recognized Organization (RO). It is advisable for a dedicated, qualified individual or a performance department to be responsible for establishing the estimation methodology.

Regarding the case (a) you mentioned, I agree with your understanding, when calibration records are insufficient, the verifier may need to conduct a more detailed investigation and request additional documentation to confirm proper implementation of the requirement. Therefore, I believe installing mass flow meters would be a more “straightforward” approach to ensure compliance with these requirements. It is important to note that these flow meters must be properly calibrated and maintained.

For the case (b) and the IGG, I understand that paragraph 7.4.1 of MEPC.388(81) still applies. Actually, only one of the following could use the subtraction method, the rest need to either have a flowmeter or monitoring fuel oil tanks on board.

image
image358Ă—261 12.1 KB

If there is no flow meter on the Inert Gas Generator (IGG) and no dedicated tank available, and the subtraction method cannot be utilized, I would recommend contacting the IGG manufacturer to obtain additional data that could assist in the estimation method. Alternatively, I would arrange for the installation of an additional flow meter on board as a quick solution. While this option comes with extra costs, I believe it is a worthwhile investment.

Lastly, it’s always a good idea to seek advice from the ship’s verifier.

4

Dear Stela,

Thank you for your response. Do you know if IACS intends to publish any Unified Interpretation on this, especially on subtraction / estimation methods?

Thanks in advance,

5

Hello @PTsichlis,

While I currently lack that specific information, I believe it would be beneficial for IACS to offer additional guidance, potentially through a revision of Recommendation 35 regarding the “SEEMP/CII Implementation Guidelines.'”