MARPOL Course

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IMO Regulation 2023

A E EEXI and CII

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International Maritime Organisation (IMO) has set a target of reducing annual

greenhouse gas emissions in shipping by at least 40% by 2030 and pursuing a
70% reduction by 2050.

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As a key means of achieving this, the IMO, through the Marine Environment
Protection Committee (MEPC) has adopted amendments to the International

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Convention for the Prevention of Pollution from Ships (MARPOL) Annex VI.

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These changes will implement major new technical rules called the Energy

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Efficiency Existing Ship Index (EEXI) and the Carbon Intensity Indicator (CII).
The regulations are due to come into force on 1 January 2023, just 6 months
from now.

Put simply, EEXI is a framework for determining the efficiency of

the design of in-service vessels over 400 GT falling under MARPOL Annex
VI. The CII is an operational measure of how efficiently a ship transports
goods or passengers measured, in essence, in grams of CO2 emitted by
cargo-carrying capacity and nautical mile.

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Three key points can be made now:

For EEXI, owners are primarily responsible for ensuring a vessel’s compliance with
MARPOL (assuming its flag state is a MARPOL contracting nation). The terms of

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most charterparties will say, or at least imply, that technical modifications required

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to comply with industry regulations lie with owners as part and parcel of their
seaworthiness obligations.

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For CII, owners of time-chartered vessels must comply with charterers’ lawful

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employment orders. However, these orders could affect the vessel’s CII rating,
which owners must still comply with. Also, decisions by owners to slow steam,
reduce cargo-carrying capacity or deviate to maintain their CII rating could put
them in breach of charter, and potentially liable in damages.

Disputes under spot fixtures could arise if owners take operational measures to
maintain a CII rating which result in, for example, delays to the voyage. Again, this
could put them at risk of breaching their obligations to proceed with due or utmost
dispatch.
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 MARPOL Course

Carbon intensity indicator (CII)

For improvement of CII, MAN ES can provide a series of fuel saving solutions:

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MAN B&W two-stroke engines:

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 Dual-fuel conversion

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 Engine power limitation
 Turbocharger cut-out

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 PMI ACCo

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 PMI AutoTuning
 MAN EcoTorque
 MAN EcoNozzle
 MAN EcoCam
 PMI VIT
 Customised retrofit solution
o De-rating
o Part load optimisation
o Propeller upgrade and installation of possible efficiency improving devices
o Exhaust gas bypass

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