The Norwegian Environment Agency (Miljødirektoratet) is the administering authority for the MRV Regulation and the EU ETS in Norway.

Content

  1. 1 The scope of the EU ETS and the MRV Regulation Ships, activities and emissions covered by the EU ETS and the MRV Regulation.
  2. 2 Determination of the shipping company Who is responsible for complying with the MRV and EU ETS obligations?
  3. 3 Monitoring plan Shipping companies must submit a monitoring plan for each ship under their responsibility.
  4. 4 Emissions reports Shipping companies must submit emissions reports.
  5. 5 EU-ETS: Surrendering of allowances Shipping companies covered by the EU ETS must surrender EU allowances for their emissions.
  6. 6 List of useful websites, regulations and links

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Terms we use in this guide:

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Ships and activities covered by the EU ETS and the MRV Regulation

The legal acts cover greenhouse gas emissions from ships of 5,000 gross tonnage and above when they transport cargo or passengers for commercial purposes. This includes emissions released

  • during voyages from the last port of call to a port under the jurisdiction of a Member State
  • during voyages from a port under the jurisdiction of a Member State to the next port of call
  • within ports under the jurisdiction of a Member State

This is according to Article 2(1) of the MRV Regulation. 

In addition, as of 1 January 2025, the MRV Regulation will also apply to offshore ships of and above 5 000 GT, as well as offshore ships and general cargo ships below 5 000 GT but not below 400 GT.

Ships are subject to the MRV Regulation and EU ETS obligations regardless of their flag and country of registration. 

A limited number of categories of ships are excluded, notably:

  • warships
  • naval auxiliaries
  • fish-catching or fish-processing ships
  • ships not propelled by mechanical means
  • government ships used for non-commercial purposes.
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Voyages and port of call

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

‘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.

  • stops for the sole purposes of refueling; obtaining supplies (including fodder for vessels transporting animals as cargo); relieving the crew of a ship other than an offshore ship; going into dry-dock or making repairs to the ship and/or its equipment
  • 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 transshipment port identified in Implementing Regulation (EU) 2023/2297.
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Greenhouse gas emissions covered

The EU MRV Maritime Regulation covers:

  • Carbon dioxide (CO2)
  • Methane (CH4) 
  • Nitrous oxide (N2O) 

The EU ETS covers:

  • Carbon dioxide (CO2)
  • Methane (CH4) as of 2026
  • Nitrous oxide (N20) as of 2026

The system is flag-neutral and voyage-based, and covers emissions from maritime transport as follows:

  • 100% of emissions from ships performing voyages departing from a port under the jurisdiction of an EEA country and arriving at a port under the jurisdiction of an EEA country (e.g. Hamburg to Marseille and Marseille to Hamburg)
  • 100% of emissions from ships within a port under the jurisdiction of EEA country (e.g. in the port of Antwerp), i.e. emissions released at berth and during movements within such a port.
  • 50% of emissions from ships performing voyages departing from a port under the jurisdiction of an EEA country and arriving at a port outside its jurisdiction (e.g. Rotterdam to Shanghai).
  • 50% of the emissions from ships performing voyages departing from a port outside the jurisdiction of an EEA country and arriving at a port under the jurisdiction of an EEA country (e.g. Shanghai to Rotterdam).
  • Some derogations apply, for instance for certain voyages to outermost regions or some small islands, or to the benefit of ships using renewable fuels. 
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Planned extensions

This is a timeline for the extension of the MRV Regulation and the EU ETS to maritime transport, focusing on various ship sizes and types, greenhouse gases, and the phase-in percentages for emissions to be surrendered. 

In addition to cargo and passengers ship of or above 5 000 GT, offshore and general cargo ships of tonnage of or above 400 GT will be included under MRV scope starting 2025. Large offshore ships of tonnage of or above 5 000 GT will be included within ETS scope starting in 2027, meaning that allowances will have to be surrendered in 2028. The inclusion of offshore and general cargo ships between 400 and 5 000 GT in the EU ETS is to be considered as part of the ETS review in 2026. 

Starting 2024, the MRV scope will be extended to include CH4 and N2O, in addition to CO2. Only CO2 emissions will be accounted for under ETS scope in the first two years (2024 and 2025), as CH4 and N2O will fall under scope starting 2026. 

A phased approach for surrendering obligations determination is foreseen, starting at 40% in 2024, 70% in 2025 and reaching 100% by 2026 for the ship types under scope.

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Shipping company

The shipping company is the entity responsible for compliance with the obligations under the MRV Regulation and the EU ETS. The registered owner is considered as the shipping company, by default, and thus the entity responsible for compliance with the MRV and EU ETS obligations. 

However, the registered shipowner may mandate another entity, the ISM responsible company (DOC holder), to comply with the MRV and EU ETS obligations. A document that demonstrates the existence of an agreement according to which the ISM Company is mandated by the registered owner to comply with these obligations in respect of one or several ships must be submitted to the administering authority responsible, in accordance with the rules set out in Regulation (EU) 2023/2599. In the absence of such a document, the registered shipowner is considered as the shipping company (the responsible entity).

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

The term ‘registered owner’ refers to the owner specified on a ship’s certificate of registry. The registered owner is determined on the basis of its IMO Unique Company and Registered Owner Identification Number.

Please note that, in respect of a given ship, a bareboat charterer cannot be considered as the shipowner within the meaning of the ETS Directive. This consideration also applies in the case where the ship is subject to a ‘parallel registration’ in the registry of two administrations.

The term ‘ISM Company’ refers to the organisation or person, such as the manager or the bareboat charterer, that has assumed the responsibility for the operation of the ship from the shipowner.

Upon assuming such responsibility, this entity has agreed to take over all the duties and responsibilities imposed by the International Management Code for the Safe Operation of Ships and for Pollution Prevention, set out in Annex I to Regulation (EC) No 336/2006 of the European Parliament and of the Council.

Regulation

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Responsibilities in case of change in shipping company

A change of shipping company occurs anytime a change of the company assuming responsibility for MRV and EU ETS obligations in respect of a given ship takes place.

Such a change may be due to a change of ownership (i.e. sale and purchase of a ship) or to a change in the ISM Company being mandated to assume responsibility in accordance with Implementing Regulation (EU) 2023/2599. 

Where there is a change of shipping company, both the previous and the new company are assigned responsibilities. This includes submitting emissions reports and modifying the monitoring plan. More information is available in the chapters dedicated to emissions reports and monitoring plans.

After a ship changes shipping company, the previous shipping company shall submit a verified partial emissions report to the administering authority within three months after the change, as specified in the MRV Regulation, Article 11 (2). 

A ship can only be assigned to one company at a time in THETIS-MRV. To avoid complicating the completion of the aforementioned responsibilities, it is recommended that the verified partial emissions report is submitted before the ship is transferred to the new company. 

For ships covered by the EU ETS

The previous company is also responsible for including the emissions from the ship during the time it was part of their fleet in the aggregated emissions report at company level (CER), that shall be submitted 31 March the following year. Finally, the previous shipping company shall surrender allowances corresponding to the emissions from the transferred ship for the duration it was in their fleet the previous reporting period. For more information on content and deadlines, please see the respective steps in this guide.

 

The new shipping company must inform the administering authority without delay when there is a change of shipping company assuming the EU ETS responsibility for one or multiple ships.

The new shipping company shall also update the monitoring plan for the ship(s), notify an accredited verifier and finally submit it to the administering authority responsible without due delay. More information on monitoring plan modification is provided in the next step.

If the shipping company is an ISM Company a document that clearly states the existence of an agreement according to which the ISM Company is mandated by the registered owner to comply with the EU ETS and MRV obligations, shall be submitted alongside the monitoring plan in THETIS-MRV. 

If the new shipping company is responsible for the ship(s) at the end of a reporting period, it shall report the emissions from the new ship(s) for the entire reporting period.

Note that this does not mean that the new company is obliged to surrender allowances for emissions for the period the ship(s) were not under its responsibility.

When submitting the aggregated emissions report at company level for the previous reporting period, the emissions from the new ship(s) after transferring to the new shipping company must be included. Finally, the new shipping company shall surrender allowances corresponding to the emissions from the transferred ship(s) for the period it was in their fleet during the previous reporting period.

In terms of maritime operator holding account obligations, the national administrator must be informed of any update in the ship(s) the company assumes EU ETS responsibility for, by the following deadlines: 

  • For ISM companies, the national administrator must be informed within 10 working days of the change. 
  • For registered owners (ship owners), the national administrator must be informed within 20 working days of the change. 

This follows from Regulation (EU) 2019/1122.

 

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The monitoring plan for each ship must be verified by an accredited verifier before it is submitted to the administering authority in THETIS-MRV.

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Deadlines

The shipping company shall submit a positively assessed monitoring plan to the administering authority no later than three months after the ship’s first call in an EEA port.

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Preparations

Whilst working on a monitoring plan, the shipping company should do the following:

Shipping companies shall submit monitoring through THETIS-MRV. 

Monitoring plans and emission reports shall be verified by a verifier accredited by a National Accreditation Body in the EEA. 

Shipping companies may select any duly accredited verifier for each of their ships, irrespective of the ship's flag or the country where the company is based and where the accredited verifier is based.

A MOHA is necessary for the reporting of greenhouse gas emissions and the surrendering of EU ETS allowances. The account may also be used to transfer/receive allowances to/from other accounts in the registry.

Shipping companies must open a MOHA in the country of their administrating authority. On January 31, 2024, the European Commission published a list of administrating authorities and shipping companies. 

You can find the list here. 

Shipping companies not included in the list who are performing voyages covered by the EU ETS Directive must identify their administrating authority through THETIS-MRV. The THETIS-MRV helpdesk will help the companies assign their responsible administering authority in the system.

The helpdesk may be contacted by email:

How to apply

The Norwegian Environment Agency is the national administrator of the Union Registry in Norway. A guide on how to apply for a MOHA is available here: 

According to the Registry Regulation, a shipping company shall submit to the relevant national administrator a complete application for a maritime operator holding account (MOHA):

  • within 40 working days of the publication of the attribution list (published on 31 January 2024);
  • for shipping companies not included in that list, within 65 working days of the first port of call falling within the scope of the ETS Directive.

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Content

Shipping companies shall use the monitoring plan template in Annex I Template  for monitoring plans, in Implementing Regulation (EU) 2023/2449.

  • All mandatory fields shall be duly filled in. 
  • All fuel tanks which are part of a measuring method, all emission sources and all measuring equipment must be included and listed separately. The identification and technical description shall be sufficient.
  • The measuring equipment must be sufficiently described, identifiable and related to an emission source/fuel tank. The technical description shall provide required information such as specification, year of installation, maintenance intervals and calibration method and intervals. If calibration is not applicable to the respective measuring equipment, this should be clarified and an alternative method for quality assurance should be provided.
  • Ships using LNG as fuel shall include methane slippage in the monitoring plan. Where default slippage coefficients are not listed for a specific emission source class, companies should apply a slippage coefficient of zero.
  • Only fuels that the ship actually consumes shall be listed.
  • Cargo tank(s) have to be listed in the fuel tank table when cargo is used as fuel.
  • Information in the fuel tank table, emission source table and measuring equipment table needs to be consistent. For example all measuring equipment listed in the fuel tank table or in the emission source table has to be listed in the measuring equipment table.
  • The MP Assessment Report shall be attached.
  • If the shipping company is an ISM company, we ask you to attach the mandate when submitting the monitoring plan.

Please note that this is not a complete list of monitoring plan requirements. For detailed requirements regarding the content of each part of the monitoring plan, see Annex I to Regulation (EU) 2023/2449 (the Templates Regulation), cf. the Greenhouse Gas Emissions Trading Regulation (klimakvoteforskriften) § 2-1a second paragraph. See in particular the footnotes as well as the header rows of the tables. 

Methods for handling missing data must be sufficiently clear, comprehensive and unambiguous for the administering authority to understand what sources of data will be used as a backup for all relevant scenarios of missing, or incorrect data. Below, we list particularly the important aspects that must be accounted for. See also the European Commission's guidance document, chapter 7.4.4.

The method for handling missing data;  

  • must be described in such a way that they cover all parts of the data flow thoroughly. For example, they must cover any dysfunctional measuring equipment, loss of AIS signals, missing BDN, missing registrations of measurements, loss of registered measurements, use of incorrect calculation basis, etc. 
  • should be a different method than the method(s) otherwise mentioned in the monitoring plan. If a method for handling missing data is similar to a monitoring method during normal operation, it is important that it is clearly described how the method can be considered an alternative used in the event of lost or incorrect data. 
  • should be conservative. For example, it is not sufficient to calculate emissions using historical data, unless specific conditions (such as wind and sea conditions) are also taken into account. Furthermore, Article 3(l) of the same regulation defines "conservative" as the use of assumptions that ensure no underestimation of annual emissions and no overestimation of distances or amounts of cargo carried.

Procedures should be sufficiently described, including reference to existing procedure, name of person/position responsible, location of records etc. 

References to existing procedures should be provided as a general rule. If this is missing, we consider that as a strong indication that no external procedures exist, and that the description given in the "Description of procedures" field constitutes a complete procedure. This means that the content of the description of the procedure should provide clear, complete and unambiguous instructions to the shipping company's employees and the ship's crew on how the tasks are to be performed. If, on the other hand, reference is given to external procedures, the description of the procedures may be briefer and more general, but it should still provide sufficiently detailed information to allow the verifier and the administering authority to make an informed decision on whether or not the procedures enables the company to comply with the relevant requirements. 

To assess the descriptions, we generally need information on

  • the responsibilities and roles of the personnel on the ship offshore and onshore,
  • the frequency of tasks,
  • and a brief description of how all relevant tasks are performed, including methodology and criteria, where relevant. 

For more information on what is expected in each individual procedure, please also see the European Commission's guidance document The EU ETS and MRV Maritime General guidance for shipping companies, in particular Chapter 6.

Please note that this is not a complete list of monitoring plan requirements. It is the shipping company’s responsibility to ensure that the content of the monitoring plan is accurate, complete and updated.

More detailed information on the content of the monitoring plan is available in the European Commission's Guidance Document No. 1.  

Template

All mandatory fields must be filled in.

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Submit the monitoring plan

The monitoring plans shall be submitted through THETIS-MRV. 

Please contact the THETIS-helpdesk if you have any questions or problems related to this step.  

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Assessment and approval of monitoring plans

Shipping companies shall submit monitoring plans of ships under their responsibility and falling within the EU ETS scope to their responsible administering authority for approval. 

Monitoring plans that meet the regulatory requirements and were submitted within a reasonable timeframe will be approved by the 6th of June 2025, in accordance with Article 6(8) of the MRV Regulation, cf. Section 2-1a of the Greenhouse Gas Emissions Trading Regulation.

The Norwegian Environment Agency will approve monitoring plans through administrative decisions. It is important that shipping companies read these carefully, as they may contain crucial information. Additionally, the monitoring plans will be marked as ‘approved’ in THETIS-MRV.

Shipping companies registered in Norway will receive administrative decisions in Altinn. Shipping companies registered elsewhere may choose to receive administrative decisions either by email or letter.  

Note that monitoring plans for ships only falling within the scope of the MRV Regulation can be controlled by the administering authority but shall not be approved. 

Fee

Shipping companies will have to pay a fee for the approval of monitoring plans. The fee is based on processing time. The invoice will be issued once the monitoring plan has been approved. 

See Section 9-3 of the Greenhouse Gas Emissions Trading Regulation.

Regulations (in norwegian)

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Modifications of the monitoring plan

Shipping companies must regularly, and at least once a year, check if the ship’s monitoring plan fits the ship’s operations and if the monitoring methods can be improved.

Shipping companies must change the monitoring plans in the following situations:

  1. When the shipping company changes.
  2. When new greenhouse gas emissions occur due to new emission sources or the use of new fuels not included in the monitoring plan.
  3. When the availability of data changes due to new types of measuring equipment, new sampling methods, or analysis methods, or for other reasons that may affect the accuracy of greenhouse gas emissions calculations.
  4. When data from the applied monitoring method is found to be incorrect.
  5. When any part of the monitoring plan does not meet the requirements of the MRV Regulation and the company must revise it according to Article 13(1) of the regulation.

In case of modifications of the monitoring plans, shipping companies shall notify the verifiers without undue delay.

In circumstances provided by points 2, 3 and 4 above, modifications of the monitoring plan shall be subject to assessment by the verifier. Following the assessment, the verifier shall notify the shipping company whether those modifications are in conformity with the requirements of the MRV Regulation.

Once a shipping company has received a notification of conformity, and for ships falling within the scope of the EU ETS Directive, it shall submit its modified monitoring plan to the responsible administering authority for approval. Shipping companies shall also submit modifications provided under points 1 of the above to the responsible administering authority without undue delay once it has notified the verifier. 

Regulation

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Guidance - Key deadlines and monitoring plan approval process

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Shipping companies shall submit emissions reports for each ship under their responsibility. Shipping companies with ships subject to EU ETS shall also submit an emissions report at company level (CER).

The emissions reports shall be verified by an accredited verifier before it is submitted to the administering authority in THETIS-MRV.

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Deadlines

Emissions reports shall be submitted to the administering authority by 31 March the year after the emissions took place. Other deadlines apply for partial emissions reports.

Different types of emissions reports

Shipping companies falling within the scope of the EU ETS must in addition report verified emissions from the previous year in the European emissions trading registry by 31 March. 

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Content

Shipping companies shall use the emissions report template in Annex II and IV in Implementing Regulation (EU) 2023/2449. 

  • data identifying the ship and the company, including:
    name of the ship,
    • IMO identification number,
    • port of registry or home port,
    • ice class of the ship, if included in the monitoring plan,
    • technical efficiency of the ship (the Energy Efficiency Design Index (EEDI) or the
    • Estimated Index Value (EIV) in accordance with IMO Resolution MEPC.215 (63), where applicable),
    • name of the shipowner,
    • address of the shipowner and its principal place of business,
    • name of the company (if not the shipowner),
    • address of the company (if not the shipowner) and its principal place of business,
    • address, telephone and e-mail details of a contact person;
  • the identity of the verifier that assessed the emissions report;
  • information on the monitoring method used and the related level of uncertainty;
  • the results from annual monitoring of the parameters in accordance with Article 10 in the MRV Regulation.  .

Regulation

Templates

All mandatory fields must be filled in.

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Submit emissions reports

All emissions reports shall be submitted through THETIS-MRV.   

Please contact the THETIS-MRV helpdesk if you have any questions or problems related to this step.  

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After submitting the emissions report 

The administering authority shall not approve the emissions report but can control it.

Shipping companies will have to pay a fee for the control and case processing of emissions reports, see Section 9-2 of the Greenhouse Gas Emissions Trading Regulation. The fee is based on processing time. The invoice will be issued once the emissions reports have been controlled. 

Shipping companies are required to surrender EU allowances for their verified emissions from ships falling within the scope of the EU ETS.

More information is provided in the next step.

Regulation (in norwegian)

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Surrender allowances

By 30 September, the shipping company must acquire and surrender the number of allowances corresponding to their verified annual emissions determined in accordance with Part C of Annex II in the MRV Maritime Regulation, to the Union Registry. When surrendering allowances, the shipping company must ensure that they have a sufficient number of allowances on their account. 

For the reporting year 2024, the number of allowances surrendered should correspond to 40% of the verified emissions reported. From the reporting year 2025, this percentage increases to 70% of the verified emissions reported. Finally, the allowances shall correspond to 100% of the verified reported emissions for the reporting year 2026.

Regulation

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How to surrender allowances

See our guide on how to report emissions and surrender allowances: 

 

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Deadline for surrender of allowances

Shipping companies must surrender allowances no later than 30 September the following year.

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Penalties if allowances are not surrendered

Failure to surrender allowances by 30 September will result in a penalty fee. This follows from the Greenhouse Gas Emission Trading Act Section 19.

Regulation (in norwegian)

 

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Administrating Authorities

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