Marine Advisory: 14/2023 - Guidance on interim compliance with MARPOL Annex VI EEXI Requirements

02 June 2023

Marine Advisory: 14/2023

SUBJECT: Guidance on interim compliance with MARPOL Annex VI EEXI Requirements

Dear Shipowner/Operator/Master/Recognized Organizations:

The purpose of this Advisory is to provide guidance on the interim compliance with MARPOL Annex VI

EEXI requirements. Verification that a vessel’s attained EEXI is in accordance with Chapter 4 (Energy Efficiency) of the 2021 Revised MARPOL Annex VI shall take place at the first annual, intermediate or renewal survey related to the IAPP certificate, whichever is the first, on or after 1 January 2023.

This verification includes confirming that the approved EEXI Technical File is on board the vessel and if any Shaft/Engine Power Limitation system is required to be installed, confirming that:

1. the system is appropriately installed and sealed in accordance with the 2021 Guidelines on the Shaft/Engine Power Limitation system to comply with the EEXI requirements and use of a power reserve (resolution MEPC.335(76)), and,
2. that a verified Onboard Management Manual (OMM) for overridable Shaft/Engine Power Limitation is on board the ship.

The Administration has received numerous requests for extension of the compliance with these requirements due to delays in procuring and installing required Shaft/Engine Power Limitation systems.

In such a case, it is required that an Interim OMM be provided to the vessel’s class society for their verification (if the class society is unable to verify it due to time restraints, then it may be submitted to the Administration for review and verification at planapproval@liscr.com). Upon receipt of the verified Interim OMM, the Administration will issue a letter authorizing the use of the Interim OMM for the time necessary and authorize the issuance of a short term IEEC for the same period along with the reissuance of the record of construction related to the IEEC duly completed in the revised format prescribed in Appendix VIII of the 2021 Revised MARPOL Annex VI. It should be noted that the IAPP survey should be completed and the IAPP certificate endorsed or renewed after completion of the survey.

The Interim OMM is to describe how the energy efficiency requirements will be handled by manual control until the Shaft/Engine Power Limitation system is installed by providing technical and operational conditions so that (a) the power limitation method and (b) any use of the power reserve satisfies the compliance with the EEXI requirements.

Please contact the Regulations & Standards Department at regsandstandards@liscr.com or telephone +1 703 790 3434 for more information.

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