Hi!
Assume a tanker vessel loading in an offshore field in Angola and discharging full cargo in Rotterdam. Is this voyage subject to 50% CO2 allowances or subject to 100% CO2 allowances?
Hello @Surcouf_Renard !
The fact that you mention an offshore field complicates the question.
If vessel would load berthed at an Angolan port, then the voyage to Rotterdam would be subject to 50% allowances.
If cargo operation is carried out at an offshore terminal then it may not count as a port of call, and the evaluation should be made basis previous port of call for cargo ops (even if it was a discharge operation, MRV does not take such trivial matters into account 
)
Quite relevant to this, there has been a clarification recently on “port of call” definition, introducing the idea that if an offshore terminal has a UN/LOCODE or a permanent connection to a sea port then it should be counted as a port of call.
20240703_Presentation on offshore.pdf (621.2 KB)
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Hello @NikosPiperis. Thank you for the useful info and presentation. My question was not clearly described. However, you have managed to provide a clear response.
I wanted to point out the case: Rotterdam - Offshore Angolan terminal - Rotterdam.
According to the existing regulatory framework the voyage is subject to 100% CO2 allowances. However, taking into account the latest updates then this voyage is subject to 50% CO2 allowances. Is my understanding correct?
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Yes @Surcouf_Renard, I believe this is correct.
The offshore Angolan terminal would not count as a port of call, so the leg would be Rotterdam to Rotterdam (EU port to EU port) and 100% factor would apply.
As per latest updates, if the offshore terminal does have a UN/LOCODE then it counts as a port of call and thus we are dealing with two legs: EU port to non-EU port and non-EU port to EU port, so 50% factor should apply for each of these two legs.
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