The Critical Need for a CII Review is Approved at MEPC 80

The shipping industry is in critical need of a functioning Carbon Intensity Indicators (CII) framework.

A review plan was approved and initiated at the IMO’s Marine Environment Protection Committee 80^th session (MEPC 80) this past July 2023. This review assessed the need for corrective actions and data collection system enhancements. MARPOL Annex VI Regulation 28.11 states that a review of the CII regulations and guidelines must be completed by January 1, 2026.

The review is focused on short-term measures, including the CII, Energy Efficiency Existing Ship Index (EEXI), and Ship Energy Efficiency Management Plan (SEEMP). It will consider enforcement experiences by Flag States and Port State Control, as well as the effectiveness of CII metrics, correction factors, and voyage adjustments. The review is to be conducted in three phases, with data gathering as the initial phase until MEPC 82 in Autumn 2024. Data analysis is set to begin at MEPC 82 and continue with a correspondence group until MEPC 83 in Spring 2025. A working group meets in late 2024 or early 2025 to review the regulations in MARPOL Annex VI and associated guidelines.

IMO ship fuel oil consumption database (SFOCD)

To facilitate the review, changes to data points submitted annually to the IMO Ship Fuel Oil Consumption Database were approved at MEPC 80 meeting. These changes are expected to be adopted at MEPC 81 in April next year. However, they may not come into force before Autumn 2025, with application starting from the calendar year 2026. Therefore, new data points won’t be available for consideration in the second half of 2027. To ensure timely input, Flag States and other stakeholders are invited to collect and submit data to IMO no later than MEPC 82 in Autumn 2024. This group will work together to support the review process and develop a metric that promotes commercial practices reducing CO₂ emissions in the shipping sector.

Unfavorable CII metric challenges ships

In its current form, the CII metric penalizes efficiently operated cargo-carrying ships and favors empty ships trading in ballast condition. Additional challenges to a functioning CII framework include the inclusion of fuel consumption when the ship is not underway. Periods of reduced demand and oversupply can result in ships waiting at anchorage, negatively impacting their attained CII rating. Ports with congestion issues disproportionately affect certain trades, leading to inferior trade conditions.

In conclusion, the shipping industry must prioritize the development of a robust and fair CII strategy. This review process will address existing challenges and seek to create a metric that accurately reflects operational efficiency and supports efforts to reduce CO₂ emissions.