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Rules and methods for monitoring and reporting greenhouse gas emissions and other relevant information for shipping

Climate action

This Delegated Regulation establishes the rules and methods for monitoring and reporting greenhouse gas emissions and other relevant information pursuant to the revised Regulation (EU) 2015/757 on the monitoring, reporting and verification of greenhouse gas emissions.

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Public consultation

ID: 13865

Lobbying Activity

13 responses

T&E warns of shipping 'dieselgate' over methane emission rules

Transport and Environment (European Federation for Transport and Environment), 28 Aug 2023

T&E demands the Commission re-calculate default values to better reflect methane slip. They also urge reporting of all fugitive emissions and the use of 20-year global warming potentials.
Stricter reporting would help the organization highlight the true climate impact of fossil shipping fuels.
Engine manufacturers would lose the advantage of using testing methods that underestimate methane leakage.

Eurogas urges aligned emission factors for maritime reporting

EUROGAS, 30 Aug 2023

Eurogas requests alignment with the Renewable Energy Directive to ensure consistency across maritime policies. They propose using specific Global Warming Potential factors to avoid incoherent dual reporting.
This would simplify administrative processes by ensuring multiple climate policies are updated simultaneously.
Scientific accuracy may suffer if reporting standards rely on older scientific assessments instead of newer data.

CMA CGM urges zero-emission status for renewable shipping fuels

CMA CGM, 30 Aug 2023

CMA CGM requests that greenhouse gas emission factors for biofuels and e-fuels be set to zero. They also propose lowering the default methane slip value for certain LNG engines.
Zero-rating these fuels would reduce their future carbon costs under EU regulations.
Climate interests are harmed if lower default values hide the real impact of methane.

NABU urges stricter methane reporting for EU shipping

Naturschutzbund Deutschland e.V., 30 Aug 2023

NABU demands revised default values for methane emissions and stricter conditions for companies wishing to deviate from these standards. Reporting must include all fugitive emissions from pipes and tanks. Calculations should use a 20-year global warming potential.
Stricter reporting would prevent shipping companies from underreporting their actual environmental impact.
Shipping companies would face higher reported emissions and more burdensome monitoring requirements.

Snam Urges Consistent Emission Factors and Engine-Specific Methane Reporting

Snam S.p.A., 30 Aug 2023

The organization recommends aligning global warming potential factors with the Renewable Energy Directive for consistency. They suggest reassessing methane slippage default values based on specific engine types. For high-pressure engines, they propose removing methane slip from certain calculation formulas.
This alignment would reduce reporting complexity and better reflect their engine technology's performance.

Cruise lines urge clarity on maritime emission monitoring rules

Cruise Lines International Association, 30 Aug 2023

The association requests clearer guidance on fuel documentation and outermost region exemptions. They also advocate for carbon capture recognition and zero-rating all biofuel emissions.
Flexible accounting and carbon capture recognition would reduce the industry's overall compliance costs.

Costa Cruises Urges Carbon Capture Inclusion in EU Shipping Rules

Costa Cruises, 30 Aug 2023

Costa Cruises calls for carbon capture technology integration to support future decarbonization efforts. They also request that all greenhouse gases from sustainable biomass receive a zero emission rating.
These changes would decrease the high operational costs associated with using renewable fuels.

Green Transition Denmark Urges Stricter Shipping Emission Rules

Rådet for Grøn Omstilling, 30 Aug 2023

The organization demands updated default values to reflect real-world methane leakage. They want all gas leaks reported and global warming potential measured over twenty years.
Tighter rules would validate their advocacy by forcing industry transparency on climate impact.
Shipping companies and engine manufacturers lose the ability to hide significant methane leaks.

Tree Energy Solutions calls for life-cycle shipping emission monitoring

Tree Energy Solutions BV, 30 Aug 2023

The organization recommends replacing the tank-to-wake approach with a life-cycle analysis to acknowledge the sustainability of renewable fuels. They request that renewable fuels of non-biogenic origin be fully recognized under the European Emission Trading System.
This would make the company's renewable gas products more commercially attractive and competitive against fossil fuels.
Traditional fossil fuel suppliers lose competitive advantage as their higher upstream emissions are revealed.

Greek Shipowners urge direct emission measurements for fossil fuels

Union of Greek Shipowners - ΕΝΩΣΙΣ ΕΛΛΗΝΩΝ ΕΦΟΠΛΙΣΤΩΝ, 24 Aug 2023

The UGS recommends allowing direct emissions measurements for fossil fuels to account for methane slippage. They argue current rules disincentivise investments in technologies like post-combustion treatment.
Members could lower reported emissions and justify investments in advanced green technologies.
Environmental progress is hindered because current rules discourage the use of cleaner tech.

Consultation response

Verband Deutscher Reeder, 7 Aug 2023

Feedback relates to ANNEX I Methods for monitoring greenhouse gas emissions, Chapter A. CALCULATION OF GREENHOUSE GAS EMISSIONS (ARTICLE 9), Number 2. Default Emission Factor, Column 6 in context of LNG and gas engines. The slip resulting from the use of LNG in a gas engine ("tank-to-propeller")…

Consultation response

Methanol Institute, 30 Aug 2023

The Methanol Institute expresses its sincere support for the European Commission's efforts in monitoring GHG emissions in maritime transport. However, we have identified a significant risk to alternative fuel integration, found in the DA's provisions on attributing the least favorable default value…

EUROMOT supports flexible emission factors for marine engines

European Association of Internal Combustion Engine and Alternative Powertrain Manufacturers, 30 Aug 2023

EUROMOT supports allowing companies to diverge from default values for emission factors. Using actual measurement factors helps incentivize reducing methane and nitrous oxide emissions. They advocate for using established international maritime codes for technical engine certification.
Manufacturers can prove their engines are cleaner than standard industry default values.