MRV FAQ´s

MRV is a legislation created by the European Council that has the goal of implementing retractions to Green House Gases (GHG) emissions to maritime transportations. Initially the focus was CO2 – the most hazardous gas among them, although since January 2024, also emissions from Methane (CH4) and nitrous oxide(N2O) will be considered. The target of MRV is to obligate the shipowners to monitor, report and verify emissions made of these GHG, among other KPI´s from vessel´s activity (fuel consumption, hours at sea, distance carried, transport work, energy efficiency parameters).

Since the very beginning, the focus of monitoring was CO2, although from Jan 1^st 2024, there is an obligation on Monitoring, Reporting and Verifying emissions of methane (CH4) and Nitrous Oxide (N2O).

Maritime transportation has a considerable environmental impact. That is reflected in GHG emissions (carbon dioxide (CO₂), nitrogen oxides (NO_x), sulfur oxides (SO_x), methane (CH₄)) as well as safety and health impact (particulate matter (PM) and black carbon (BC)). Between 1990 and 2007 the resulting CO₂ emissions from maritime transportation increased by 48%.

Monitoring Maritime activities allows the compliance with the Paris Agreement and the reinforcement of the UN climate goals.

Due to this fact, it was urgent to take measures and, therefore, the best possible option was to set up a system for monitoring, reporting and verification (MRV system) of GEE emissions based on the fuel consumption of the vessels or direct measurements of the exhaust gases, as a first step of a staged approach. By establishing these measurements, it will also allow to extend CELE activities to the maritime transportation and initiate a cap-and-trade market for GHG emissions allowances.

There are strict penalties in case of non-compliance. Those penalties should be effective, proportionate and dissuasive.

The penalties are defined by each Member State. It is appropriate to provide the possibility of expulsion for ships that failed to comply for two or more consecutive reporting periods with monitoring and reporting requirements.

MRV regulation is Applicable to ships with a gross tonnage equal to or greater than 5000 GT regarding greenhouse gas emissions generated during voyages undertaken for the purpose of transporting goods or passengers and for commercial purposes. As of January 1st, 2025, it will also be applicable to general cargo ships with a gross tonnage of less than 5000 tons but not less than 400 tons regarding greenhouse gas emissions generated during voyages.

Nevertheless, there are ships exempted from MRV:

• Warships;
• Naval auxiliaries;
• Fish-catching or fish-processing ships;
• Wooden ships of a primitive build;
• Ships not propelled by mechanical means;
• Government ships used for a non-commercial purpose;
• Dredging;
• Ice-breaking;
• Pipe laying;
• Offshore installation activities.

The MRV Regulation sets monitoring and reporting obligations for EEA- related voyages carried out after 1^st January 2018. Among the activities it covers:

• Activities starting or ending in a port of call serving the purpose of transporting passengers and cargo for commercial purposes (voyages);
• Ballast voyages (where ships load or discharge cargo and/or passengers for commercial purposes between ports of call).

Any other ship activities that do not serve the purpose of transporting cargo or passengers for commercial purposes are not subject to the monitoring, reporting and verification requirements (ex: ice-breaking, prospection, and extraction of material, support to offshore installations).

A Port of call is a start or an endpoint of a voyage, where ships stop to load or unload cargo, embark or disembark passengers. Doesn’t count as a port of call, a stop for the purpose of refueling, gathering supplies, relieving crew members, going into dry-dock or provide reparations to the ship and its equipment. It isn’t considered a port of call when for a reason of assistance, distress or by the effect of adverse climacteric conditions a ship need take shelter.

In MRV context a voyage is considered a journey between two consecutive ports of call and an “EU MRV voyage” is considered when at least one of the ports of call is in the EU. The kind of voyages involved are:

• Voyages from ships that come from the last port of call outside of the EU to the first EU port of call;
• Voyages within EU ports of call;
• Voyages from EU ports of call to the first port of call outside the EU.

Besides the mentions voyages, it should also be considered the laden voyages. See the following example:

Yes, they are. During voyage variations of cargo should be considered and a weighted average of cargo should be determined and applied to the voyage.

The countries that are included in the regulation are part of the EU State Members, Iceland, Norway, and the EEA Outermost Region:

The most relevant information to be monitored and reported are:

• GHG emissions (based on emissions factors for each type of fuel);
• Fuel consumption at sea and at berth for each emission source;
• Voyage data (time at sea, distance traveled, cargo carried, transport work);
• Energy efficiency parameters (total fuel consumption per distance, total fuel consumption per transport work, total GHG emissions per distance, and total GHG emissions per transport work);
• Emissions sources (main engines, auxiliary engines, boilers, gas turbines, inert gas generators).

Type of Ships	Cargo	Units of Cargo
Passenger Ship	Ship that carries more than twelve passengers but not cargo.	Passengers
Container Ship	Ship designed exclusively for the carriage of containers in holds and on deck.	Tonnes
Oil tanker	Ship constructed or adapted primarily to carry oil in bulk in its cargo spaces.	Tonnes
Chemical tanker	Ship constructed or adapted for the carriage in bulk of any liquid product listed in the International Bulk Chemical Code (a chemical tanker) or a ship constructed or adapted to carry a cargo of noxious liquid substances in bulk.	Tonnes
LNG carrier	Tanker for the bulk carriage of liquefied natural gas (LNG) (primary methane) in independently insulated tanks. Liquefaction is achieved at temperatures down to -163°C).	Cubic meters
Gas carrier	Tanker for the bulk carriage of liquefied gases other than LNG.	Tonnes
Bulk carrier	Ship which is intended primarily to carry dry cargo in bulk, including such types as other carriers.	Tonnes
Combination carrier	Ship designed to load 100% dead weight with both liquid and dry cargo in bulk.	Tonnes
General cargo	Ship with multi-deck or single-deck hull designed primarily for the carriage of general cargo.	Tonnes, Tones of dead-weight carried (ton)
Refrigerated cargo	Ship designed exclusively for the carriage of refrigerated cargoes in holds.	Tonnes
Vehicle carrier	Ship designed for the carriage of empty cars and trucks.	Tonnes, Tones of dead-weight carried (ton)
Ro-ro Ship	Ship designed for the carriage of roll-on roll-off cargo transportation units or with roll-on roll-off cargo spaces.	Tonnes
Ro-pax ship	Passenger ship with roll-on roll-off cargo space.	Tonnes, Tones of dead-weight carried (ton)
Container/Ro-ro cargo ship	Hybrid of a container ship and a ro-ro cargo ship in independent sections.	Cubic meters
Other ship types	Ships not covered by any of the above definitions which fall under the scope of the regulation.	Tonnes, Tones of dead-weight carried (ton)

Shipowners are responsible for complying with GHG emissions of their Company and each vessel within the scope of the MRV regulations.   Legislation allows the shipowner to delegate in a company or specific entity/person under the issuing of a declaration.

Companies have to validate until 31^st December of each civil year if they have the Monitoring Plan of each vessels of the fleet updated or need to establish any modifications.  The Monitoring Plans are created by the companies, for each vessel, sent and validated by an accredited verifier.

In case the company does not have any Monitoring Plan, it is mandatory for the vessel´s activity to have one validated by an independent verifier and to be allowed to enter EU Ports of Call.

If the vessel already has a Monitoring Plan, it can be changed and sent for revalidation of a verifier, explaining the changes intended. Although it has to be in line either with changes allowed by EU Regulation 2023/957 article 7º. Nº2 or change in methodology due to the new regulation that entered in force.

For ships which call into EEA ports for the first time after the deadline for submitting monitoring plans, companies should submit a monitoring plan to an accredited verifier without delay, and no later than two months after the ship’s first call at an EEA port.

A ship which has not carried out voyages during a whole reporting period of a calendar year X will not be required by the authorities to have a Document of Compliance on board showing compliance for that specific reporting period, when calling at EEA ports between 30^th June of next year and 29^th June of the subsequent one.

No need to. The companies can avoid redundant submission of information, identifying data which applies in an identical way to their fleet and that reflects their technical characteristics and procedures.

Each company must assure an English translation of the assessed monitoring plan.
The monitoring plan must follow a template as indicated in Regulation EU 2023/2449 Annex I.
In terms of the content necessary, it must include:

• Vessel, Shipowner and Company data;
• Description of the Emission Sources on board (eg main engines, auxiliaries, gas turbines, boilers, inert gas generators and types of fuel used);
• Description of procedures, systems, and responsibilities;
• Emission factors;
• Methodologies for sampling;
• Methods of analysis and description of the laboratories used;
• Procedures to monitor the voyages and its activity (departure and arrival points, date and time using Greenwich Mean Time,  distance recorded, transport activity, cargo transported, data sources for determination and recording of time spent at sea between ports);
• Procedures for monitoring fuel consumption on the ship (method chosen for calculation, description of measuring equipment, procedure for measuring fuel and fuel supplies in tanks, method for determining density, procedure to ensure the total uncertainty inherent in measurements);
• Calculation of Energy Efficiency Average by one of the possible 4 methods: fuel consumption by distance, fuel consumption by activity, GHG emissions by distance or GHG emissions by activity;
• Additionally, a number of voluntary fields that might be relevant for limited number of ship categories. These voluntary fields concern, for example, Ice class Ship, time and distance spent at sea when navigating on the ice, data sources and formulas to determine records (if applicable).

Shipowners can use any of the following methodologies:

• Bunker Fuel Delivery Note (BDN) and periodic stocktakes of fuel tanks;
• Bunker fuel tank monitoring on board;
• Flow meters for applicable combustion processes.

The verification activities must take into consideration that the verifier avoids any conflict of interest with the company, and should be completely impartial to it.

A ship can be exempt from the obligation to monitor a per-voyage basis, if:

• All of the ship’s voyages during the reporting period are EEA-related voyages;
• The ship performs more than 300 voyages during the reporting period;
• Both conditions need to be fulfilled at the beginning of the reporting period.

• Develop a monitoring plan for each vessel within the scope of MRV regulation and submit to an independent accredited verifier;
• For each report period present to the verifier as Emissions Report for each vessel and an Aggregated Emissions Report of the Company, that must by verified satisfactory. Until 2024 the Companies must submit to the verifier the Emissions Report no longer than 30^th March, and should present to the Authorities a Verification Report and a Document of Compliance until 30^Th April. From 2025 onwards, the deadlines will change, therefore the Emissions Report will have to be sent to the verifier no later than the end of February. After this, the satisfactory verification approval needs to be submitted until the end of March;
• Provide all necessary information and grant access to its instalations for the verifier can establish a complete and correct activity.

In order to fulfil MRV’s obligations and avoid penalties shipowners should require the assistance of an independent accredited entity – the verifier, which has the following responsibilities:

• The verifier must be impartial, independent, capable and accredited;
• Identify and evaluate the risks related to the monitoring activity (inherent, calculations, control and detections);
• Conduct validation and verification activities;
• Issue a validation report for the monitoring plan and verification report and document of compliance when verifying the clients´Emissions Report.

According to the Regulation 765/2008, the Commission stipulated that each Member State in the EEA will define National Accreditation Bodies that can grant accreditation to legal entities performing verification activities pursuant to MRV.

Yes. Under exceptional circumstances, an entity can request accreditation from another National Accreditation Body of the Member State.

A conformity assessment body may request accreditation by a National Accreditation Body in any one of the following situations:

• When the Member State in which it is established has decided not to establish a National Accreditation Body and has not had recourse to the National Accreditation Body of another Member State;
• When the National Accreditation Bodies do not perform accreditation in respect of the conformity assessment activities for which accreditation is sought;
• When the National Accreditation Bodies have not successfully undergone peer evaluation in respect of the conformity assessment activities for which accreditation is sought.

At TecnoVeritas, our primary objective is to provide products and services of the highest quality, ensuring the satisfaction of our customers. However, we recognize that on some occasions, expectations may not be met, and legitimate concerns may arise. We want to assure you that we are committed to addressing each complaint in a fair, transparent, and effective manner.

We value your feedback and are always ready to listen to your concerns. Through clear and accessible communication channels, we aim to fully understand the details of your complaint. To do so, you can send us an email at quality@tecnoveritas.net or contact us by phone at 261 819 819.

As soon as your complaint is received, our team initiates a complete analysis. Our goal is to provide an initial response within a specified timeframe, informing you about the investigation and resolution process. Each complaint is treated with the utmost seriousness. Our specialized team reviews the provided information, checks relevant records, and identifies areas where we may have made mistakes. This helps us prevent future recurrences. After the investigation, we share the findings with the customer and the corrective measures taken or proposed.

We view each complaint as an opportunity to learn and continuously improve to serve you better.