E

MARINE ENVIRONMENT PROTECTION MEPC 80/6/13

COMMITTEE 12 May 2023
80th session Original: ENGLISH
Agenda item 6 Pre-session public release: ☒

ENERGY EFFICIENCY OF SHIPS

Comments on the report of ISWG-GHG 14 to the Committee on the matter of

appropriate metrics to quantify cargo carried by containerships

Submitted by World Shipping Council

SUMMARY

Executive summary: This document comments on proposals to amend the IMO Data
Collection System (DCS) and provides further information to support
the use of TEU-miles as the sole metric to quantify cargo carried by
containerships.

Strategic direction, if 3
applicable:

Output: 3.2

Action to be taken: Paragraph 16

Related documents: Circular MEPC.1/Circ.684; ISWG-GHG 13/7; ISWG-GHG 14/4,

ISWG-GHG 14/4/1, ISWG-GHG 14/4/2 and MEPC 80/WP.6

Introduction

1 This document is submitted in accordance with the provisions of paragraph 6.12.5 of

the Organization and method of work of the Maritime Safety Committee and the Marine
Environment Protection Committee and their subsidiary bodies (MSC-MEPC.1/Circ.5/Rev.4)
and provides comments on document MEPC 80/WP.6.

2 Following consideration of proposals to amend the IMO Data Collection System

(DCS) submitted by Austria et al. in document ISWG-GHG 13/7 (Austria et al.), further
documents on the matter were submitted to ISWG-GHG 14. The relevant documents are
ISWG-GHG 14/4 (Austria et al.), ISWG-GHG 14/4/1 (India) and ISWG-GHG 14/4/2 (WSC).

3 Document ISWG-GHG 14/4/2 supported reporting data for cargo carried to the DCS,
along with improving data granularity and transparency. WSC advocated using TEU-miles as
the sole metric to quantify cargo carried by containerships. Document ISWG-GHG 14/4 called
for containerships to report both weight of containers plus cargo and TEUs. Member State
support was divided between the two proposals.

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4 To facilitate further discussion, the Working Group invited the Committee to refer the
matter to the working group on air pollution which is expected to be established at MEPC 80
(MEPC 80/WP.6, paragraph 129). This document comments on paragraphs 112 to 114 of the
report of the Working Group and provides further information to the Committee on why
TEU-miles should be the sole metric for cargo carried by containerships.

Discussion

5 WSC reaffirms support to report data on cargo carried to the DCS, to improve
granularity of data and improve transparency of the DCS in accordance with proposals
submitted in document ISWG-GHG 14/4/2. Adding further granularity will promote a better
understanding of the relative contributions of time under way and at rest, and cargo
conditioning loads on transport work values. Improving transparency will enhance confidence
in the database, as a matter of principle transparency and openness are to be welcomed.

6 Document ISWG-GHG 14/4/2 proposed TEU-miles as the sole metric for cargo
carried by containerships, transport work would be calculated for each port pair and not using
aggregated total TEU at the end of the reporting period. A simplified worked example was
provided to illustrate the importance of using port pairs instead of aggregated TEUs.
No delegations disagreed that transport work should be calculated for port pairs at the session;
however, discussions with a range of stakeholders (including Member States) has highlighted
a need for this to be made explicit in any amended DCS reporting requirements as already
provided in paragraph 3.6 of the Guidelines for voluntary use of the ship energy efficiency
operational indicator (EEOI) (EEOI Guidelines), issued as circular MEPC.1/Circ.684.
The arguments considered by the Working Group are provided in document MEPC 80/WP.6,
paragraphs 112 to 114. The following paragraphs provide information to assist the Committee
in giving the matter further consideration.

7 TEU-miles calculated through port-pairs as detailed in document ISWG-GHG 14/4/2

is an extremely accurate and simple calculation. It is equally important to understand that
simply using total TEU is not accurate because many containers are carried across multiple
port pairs that would grossly overestimate TEU if one uses total TEU counts. For this reason,
TEU-miles is the accurate figure to be used in calculating TEU carried.

8 Where possible, IMO should align with existing global standards and norms.
WSC would highlight the following text from International standard ISO 14083:2023:

"For containerized shipping, the number of TEU slots available onboard is both the
primary limiting characteristic and the mechanism by which bookings are made.
As such, the TEU is the unit established within the industry for calculation and is
recommended as the unit to be combined with the transport activity distance when
calculating transport activity in this specific subsector.1"

9 WSC further highlights paragraph 3.5.2 of EEOI Guidelines, "for containerships

carrying solely containers, number of containers (TEU) or metric tons (t) of the total mass of
cargo and containers should be used". For a voluntary mechanism a choice of options is
acceptable, a mandatory system should identify a single cargo parameter for each ship type.
It should be further noted that international organizations which monitor international container
transportation, such as UNCTAD and OECD use TEU data.

1
ISO 14083:2023 Greenhouse gases – Quantification and reporting of greenhouse gas emissions arising
from transport chain operations, G.3.3.

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10 This emphasis on use of TEU by ISO and other bodies is entirely appropriate.
Ships are designed and optimized for either weight or volume, which is the basis of design and
should determine whether weight or volume should be used to calculate transport work.
The Fourth IMO GHG Study 2020 found that when cDIST was calculated using TEU, transport
work followed broadly similar trends as AER but the magnitude of performance change
differed. The study suggested that:

"Given all else is equal, this can be possibly explained by the alternative units in cDIST
used for indicating capacity, which can additionally capture the optimization in ship
design, such as more container or gas capacity per given dwt2"

11 Use of two metrics for containerships would result in having two transport work values
which may diverge. If the DCS is only intended as an information resource, Member States
might consider this to be acceptable, although it could introduce confusion and uncertainty as
to which value properly represented performance. However, if transport work values are to
underpin future regulatory measures, the Organization would have to make a choice on which
one to use as it would not be sensible to attempt to regulate the sector using two values.
The first value (TEU) is the clear and unambiguous unit that captures the transport work of the
container sector. The second value (gross mass) is a secondary measure that containerships
are not optimized for and, unlike TEU-miles, is a value which will be significantly wrong due to
the reasons outlined in document ISWG-GHG 14/4/2. Most importantly, tonne-miles do not
accurately or qualitatively measure the transport work performed by containerships.
Put another way, all of us see the transport work performed when we receive a package at our
door and it was delivered on time. We do not get more excited or feel a greater service has
been performed if the box weighs slightly more. It is no different in the container trades – it is
the delivery of the box that matters.

12 Document ISWG-GHG 14/4/2 highlighted the importance of accuracy. The number of

TEU carried can easily be verified with complete accuracy and minimal administrative burden
for both operators and Administrations. This is not the case for weight. Despite the container
verified gross mass (VGM) requirements of SOLAS, containers are still misdeclared, meaning
that a reliance on declared weight cannot be accepted as accurate.

13 Any attempt to agree an average assumed weight would be just that – an assumption,
and as such inherently inaccurate. Typical container weights vary greatly, and even when
averaged, vary between routes with some trades having a higher percentage of heavy or light
containers than others.

14 The number of TEU on board is a simple value, which is completely accurate and can
be verified with minimal burden.

Proposals

15 It is recommended to adopt TEU-miles as the sole metric for cargo carried by

containerships. It is also essential that any TEU figure must be calculated as TEU-miles as
noted in paragraph 7 of this document and detailed in document ISWG-GHG 14/4/2.

Action requested of the Committee

16 The Committee is invited to consider the information provided in this document and
the specific proposal made in paragraph 15 and take action, as appropriate.
___________

2
Fourth IMO GHG Study 2020 Full Report – 3.3.4 Comparison between potential carbon intensity metrics,
p.209

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