Key stakeholders and administering authority 

Q1: Who is responsible for MRV and EU ETS obligations?

Q2: If the shipowner decides not to delegate the EU ETS obligations, hereunder surrendering allowances, can an ISM-responsible company continue to be responsible for MRV obligations, hence all the activities related to monitoring and reporting?

Q3: Which administering authority responsible shall shipping companies report to?

Q4: Which authority will be the administering authority for MRV and EU ETS in Norway?

Q5 Who can carry out verification activities of monitoring plans and emissions reports?

1. Who is responsible for MRV and EU ETS obligations?  

The shipping company is the responsible entity for compliance with the obligations under MRV and the EU ETS. 

In practical terms, it means the registered shipowner is considered to be the default shipping company, and therefore responsible for compliance with MRV and EU ETS obligations. 

However, the registered shipowner can mandate another entity, the ISM- responsible company (DOC holder), to comply with those obligations. A documentation that clearly and explicitly stating the delegation must be submitted to the administering authority responsible, in accordance with the rules set out in EU 2023/2599. 

If such document is not submitted to the administering authority responsible, the registered shipowner is considered as the responsible entity.  

2. If the shipowner decides not to delegate the EU ETS obligations, hereunder surrendering allowances, can an ISM-responsible company continue to be responsible for MRV obligations, hence all the activities related to monitoring and reporting?

The same entity shall be responsible for both MRV and EU ETS obligations. Therefore, if the shipowner decides not to delegate the EU ETS obligations, it is also responsible for MRV obligations.

3. Which administering authority responsible shall shipping companies report to?

The Commission published on 31 January 2024 a list specifying the administering authority responsible in respect of shipping companies that were already in the THETIS-MRV system in November 2023. The list is therefore based on best available information at that time, and it will not give an exhaustive overview of shipping companies that will be subject to the EU ETS.

The list is available here:

We emphasise that the list is not binding in regard to which shipping company is responsible for EU ETS obligations. The list is only relevant for identifying the Member State that will be the administering authority responsible for the entities on the list, and only for entities that are still considered as the shipping company under the EU ETS – either because they are the registered owner, or because they are an IMS company and have agreed to assume responsibility for MRV and ETS obligations and have received a mandate in accordance with Commission Implementing Regulation (EU) 2023/2599.

Shipping companies that are not on this list will be allocated to an administering authority responsible in accordance with the rules for administering authority in respect of a shipping company. Please see our below scenarios for further clarification.

4. Which authority will be the administering authority for MRV and EU ETS in Norway?

The Norwegian Environment Agency (Miljødirektoratet) will be the administering authority for both the MRV and EU ETS in Norway.

5. Who can carry out verification activities of monitoring plans and emissions reports?

A verifier must be accredited for the relevant verification activity by a National Accreditation Body in an EEA member state.

Shipping companies have the flexibility to choose any accredited verifier that comply with the obligations set forth for the verifiers in both MRV and the EU ETS.

Ships and obligations

Q6a: Which ships are covered by the MRV Regulation from 1st January 2025?

Q6b: For which ship types do MRV and EU ETS apply?

Q7: Shall ships with ice class capacity surrender the same number of allowances as their verified emissions?

Q8: What is the definition of offshore ship?

Q9: What GHG emissions are covered by MRV and EU ETS?

Q10: Shall methane slip be included in monitoring plan and emissions report?

Q11: Do shipping companies that are registered in EEA, but have none of its ships with port of calls in the EEA, have to comply with MRV and EU ETS obligations?

Q12: Important dates for complying with MRV and EU ETS obligations

Q13: Which IT system to use for submitting monitoring plan and emissions report?

Q14: Which type of ships are affected by the implementing act about neighbouring container transhipment ports?

Q15: How to monitor and report emissions?

Q16: Can shipping companies use the current template of monitoring plan after 1. January 2024?

6a. Which ships are covered by the MRV Regulation from 1st January 2025? 

General cargo ships between 400 – 4999 GT and offshore ships above 400 GT will be covered by MRV from 1st January 2025. Definition of ship types can be found in Implementing Regulation (EU) 2016/1928 article 2.  This is in addition to ship that are already covered by the Regulation.

6b. For which ship types do MRV and EU ETS apply?

MRV apply to offshore ships of or above 5000 GT from 2025, and EU ETS apply to offshore ships of or above 5000 GT from 2027. The definition of offshore ships is not defined yet in the regulations or guidance.

MRV and EU ETS do not apply to warships, naval auxiliaries, fish-catching or fish-processing ships, wooden ships of a primitive build, ships not propelled by mechanical means, or government ships used for non-commercial purposes.

7. Shall ships with ice class capacity surrender the same number of allowances as their verified emissions?

No, shipping companies may surrender 5 % fewer allowances than their verified emissions released until 31 December 2030, provided that such ships have the ice class IA or IA Super or an equivalent ice class, established based on the Baltic Marine Environment Protection Commission (HELCOM) Recommendation 25/7.

The ships do not need to sail in ice conditions in order to benefit from the derogation.

8. What is the definition of offshore ship?

Offshore ships have not yet been defined in the regulations or in guidance.

We will update the website once we have more information about this.

9 What GHG emissions are covered by MRV and EU ETS?

10. Shall methane slip be included in monitoring plan and emissions report? 

Yes, methane slip shall be included in the monitoring plan and emissions report. The shipping companies shall surrender allowances corresponding to verified CO2-equivalent of methane slip.

More information is available in the revised MRV annexes (adopted by the Commission): Shipping emissions - rules on monitoring & reporting (europa.eu)

11. Do shipping companies that are registered in EEA, but have none of its ships with port of calls in the EEA, have to comply with MRV and EU ETS obligations?

No, MRV and EU ETS obligations are subject to shipping companies with ships that have port of calls in EEA.

12. Important dates for complying with MRV and EU ETS obligations

13. Which IT system to use for submitting monitoring plan and emissions report?

All monitoring plans and emissions reports shall be submitted through THETIS-MRV (europa.eu)

14. Which type of ships are affected by the implementing act about neighbouring container transhipment ports?

Currently, the Commission has published a list of two ports, which are Tanger Med in Morocco and East Port Said in Egypt, as neighbouring container transhipment ports. The list has been adopted by the Commission. The list will be revised every two years.

Stops of containerships in abovementioned ports should not be considered as port of calls for the purposes of MRV and EU ETS.

15. How to monitor and report emissions?

Shipping companies can use one or more of the undermentioned methods to determine greenhouse gas emissions and fuel consumption of each emission source:

• Method A: BDN and periodic stocktakes of fuel tanks
• Method B: Bunker fuel tank monitoring on-board
• Method C: Flow meters for applicable combustion processes
• Method D: Direct greenhouse gas emissions measurement

16. Can shipping companies use the current template of monitoring plan after 1. January 2024?

No, shipping companies shall use the new template for monitoring plan from 1. January 2024. The monitoring plan shall be verified by an accredited verifier. Shipping companies shall also use new templates for emissions report and emissions report at company level.

Voyages and port of call

Q17: What is a voyage?

Q18: What is considered as a port of call?

Q19: Do emissions from listed scenarios fall within the scope of MRV and EU ETS?

Q20: Do ballast voyages fall within MRV and EU ETS scope?

17. What is a voyage?

Voyage means any movement of a ship that originates from or terminates in a port of call.

18. What is considered as a port of call?

For the purpose of EU ETS, a port of call means:

• the port where a ship stops to load or unload cargo
• or to embark or disembark passengers
• or the port where an offshore ship stops to relieve the crew

Following activities are not a port of call:

• stops for the sole purposes of refuelling, obtaining supplies, relieving the crew of a ship other than an offshore ship
• going into dry-dock or making repairs to the ship, its equipment, or both, stops in port because the ship is in need of assistance or in distress
• ship-to-ship transfers carried out outside ports
• stops for the sole purpose of taking shelter from adverse weather or rendered necessary by search and rescue activities
• stops of containerships in a neighbouring container transhipment port listed in the implementing act adopted pursuant to Article 3ga(2)

19. Do emissions from listed scenarios fall within the scope of MRV and EU ETS?

20. Do ballast voyages fall within MRV and EU ETS scope?

More information

For further information visit the FAQs published by the European Commission: