Cruise Lines International Association

CLIA Europe

Cruise Lines International Association represents leading cruise companies operating in Europe and their interests in regulatory and policy matters.

Lobbying Activity

Meeting with Apostolos Tzitzikostas (Commissioner)

28 Jan 2026 · Exchange of views

Meeting with Jens Gieseke (Member of the European Parliament)

17 Dec 2025 · Austausch zu EU-Verkehrspolitik

Meeting with Elissavet Vozemberg-Vrionidi (Member of the European Parliament, Committee chair)

17 Dec 2025 · Exchange on Maritime Policy and Upcoming Strategies

Cruise industry urges EU to relax green investment rules

5 Dec 2025
Message — The organization recommends abandoning the 'best in class' approach because it limits financing for transitional investments. They want requirements to focus on ship design at construction rather than how vessels are operated later. They also propose replacing zero-emission standards with lifecycle fuel accounting.123
Why — Easier access to capital for building new ships and lower regulatory hurdles.45

Meeting with Elena Kountoura (Member of the European Parliament, Shadow rapporteur)

3 Dec 2025 · Meeting with CLIA representative

Meeting with Fotini Ioannidou (Director Mobility and Transport) and

24 Oct 2025 · Exchange of views on the current issue of interest

Meeting with Daniel Attard (Member of the European Parliament, Rapporteur)

9 Oct 2025 · Sustainable Tourism Report, smart destination policy

Meeting with Niels Flemming Hansen (Member of the European Parliament)

23 Sept 2025 · Policy Breackfast

Cruise industry urges EU to fund sustainable maritime tourism

12 Sept 2025
Message — CLIA requests earmarked tourism funding from existing European financial instruments. They want prioritized investment in onshore power infrastructure at major ports. The group urges simpler regulations to keep Europe an accessible destination.123
Why — This would lower decarbonization costs and prevent new administrative burdens.45
Impact — Consumer groups may lose protections if passenger rights regulations are simplified.6

Response to Sustainable transport investment plan

4 Sept 2025

SUMMARY Achieving net zero cruising by 2050 will require estimated investment costs in the range of 29bn to 38bn over the next 25 years, encompassing fuel production, distribution, port infrastructure, and onboard ship technology costs, this represents an approximate 80% increase over business-as-usual investments. To support the energy transition efforts of the cruise sector, low and net-zero carbon fuels such as LNG (in its bio or synthetic form), and green forms of hydrogen and methanol must be available at scale and where they are needed, facilitated by supportive measures and funding from Governments. Several scenarios are possible for the cruise sector to achieve the FuelEU Maritime decarbonisation targets, but all require significant but broadly similar investment: The estimated investment cost of the more capital-intensive and complex methane-dominated pathway in terms of fuel production is at least 12.8 billion by 2050. For fuel distribution, the majority of the investments required are estimated to be for bunker vessels for the distribution of methanol and an increased volume of LNG, bio- and e-methane. The establishment of Onshore Power Supply (OPS) dominates the investment requirements from 2026 to 2030. By 2028, more than 70% of the ocean-going cruise fleet will be equipped with OPS connection. Three of the top ten busiest cruise ports in the world are located in Europe and of these European ports, only one has OPS active. To meet AFIR requirements for TEN-T ports, installation and provision of OPS at European cruise ports should be given priority. Investment in net-zero technologies remains key to the sector. The cruise industry continues to trial and invest in new technologies, like fuel cells and batteries, and to explore carbon capture and storage capability, however the majority of the investment is needed further down the fuel supply chain. The Sustainable Transport Investment Plan should be a robust framework of action to support the decarbonisation process of the cruise shipping sector and to that effect it should: 1. Ensure full harmonization between EU legislation and the IMO emissions framework. Full harmonization with IMO regulation must include the full retrieval of EU regulation, therefore no additional ETS fees shall apply to shipping. 2. Direct all national ETS revenues from shipping to be reinvested in the maritime sector. 3. Prioritise OPS infrastructure in European cruise ports and ensure transparency in OPS pricing. 4. Accelerate the production of low- and zero-carbon fuels, coupled with investments in bunkering facilities in European ports and a mechanism to bridge the price gap with traditional fuels using the EU ETS revenues, and public and private funding. Specifically Contracts for Difference are needed to derisk the commitment of off takers and ensure that new fuel suppliers can reach Financial Investment Decisions and establish the production of sustainable. fuels. Please see attached the full CLIA response to the Call for Evidence regarding the Sustainable Transport Investment Plan.
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Cruise lines urge prioritized funding for port power infrastructure

28 Jul 2025
Message — CLIA requests prioritized investment in onshore power supply, particularly in Mediterranean ports. They advocate for mandatory price transparency for electricity and more flexible green technology regulations.12
Why — Predictable electricity pricing would allow cruise operators to secure cheaper industrial energy rates.3
Impact — European shipyards and technology innovators lose out due to restrictive zero-emission equipment definitions.4

Response to EU industrial maritime strategy

28 Jul 2025

The Cruise Lines International Association (CLIA) welcomes the Commissions initiative to develop a robust EU Industrial Maritime Strategy. Our sector is a cornerstone of Europes maritime industrial base, sustaining high-value manufacturing, innovation, and employment across shipbuilding, fuel production, port services and maritime equipment. With 97% of cruise ships built in Europe, cruise shipbuilding accounts for 80% of the value of commercial ship orders in the EU. However, this strategic advantage is not guaranteed and must be reinforced through dedicated EU policy and investment. We urge the Commission to build on the cruise sector's contribution and ensure European maritime industries remain globally competitive and lead maritime decarbonisation: 1. Maintain the industrial excellence and competitiveness of European shipyards with the cruise sector recognized as fundamental to their long-term success - The cruise industry directly supports tens of thousands of skilled jobs in shipbuilding and retrofitting, particularly in Europes industrial regions. To retain this high-value industrial leadership, the EU should: Establish a Clean Cruise Tech facility to fund innovation in green ship technologies. Introduce an EU Matching Facility to co-fund projects eligible under the IMO Net Zero Fund when they involve EU yards, ports, or manufacturers. Ensure EU funding and taxonomy mechanisms apply Life Cycle Analysis criteria to avoid disadvantaging maritime projects. 2. Secure access to sustainable maritime fuels and technologies - The availability of affordable, sustainable fuels is the most critical enabler of maritime decarbonisation and is essential to the competitiveness of ship owners and operators. However, biogas/biofuels and RFNBOs face constrained supply and steep costs. CLIA calls for: i. Adoption of a fuel supplier mandate for all Sustainable Maritime Fuels (SMF) in Member States. ii. Equal priority for maritime and aviation in access to sustainable fuels. iii. Inclusion of SMFs in national funding mechanisms (e.g. Contracts for Difference). iv. Recognition of mass balance and Book & Claim systems to facilitate fuel uptake. v. Establishment of a maritime SAF mechanism under the EU ETS to bridge the price gap. 3. Remove regulatory bottlenecks and strengthen fuel infrastructure - Cruise ships are being designed to be fuel-flexible, but infrastructure and supply networks for fuels such as biomethane, green methanol, and e-methane remain limited. Distribution hubs must be a priority. CLIA recommends dedicated support for dual-fuel engines, bunkering facilities, shore power, and net-zero technologies like CCS and fuel cells. 4. Foster innovation and global regulatory alignment - The EU must support maritime decarbonisation through innovation and regulatory coherence: FuelEU Maritimes definition of zero-emission technologies should be revised to reflect life-cycle emissions. EU policy must align with IMO lifecycle-based GHG measures, including onboard methane slip measurement and verification systems. 5. Align EU legislation with the IMO Net Zero Framework - CLIA urges the Commission to review and align the EU ETS and FuelEU Maritime with the IMO framework, to avoid duplication and regulatory fragmentation. A global approach ensures fairness, investment certainty and cost efficiency for decarbonisation efforts. CLIA calls for full reinvestment of maritime EU ETS revenues into the sector, with annual transparency on spending by Member States. Maritime fuels and infrastructure should be explicitly eligible under national and EU funding schemes, and cruise treated equally within the transport and maritime frameworks. With supportive policies and investment, the cruise industry can continue to drive green innovation, industrial excellence and high-skilled employment in Europe. CLIA looks forward to working with the Commission on the EU IMS. For more information, please see attached submission document.
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Meeting with Polyvios Eliofotou (Cabinet of Commissioner Costas Kadis) and Shipyards' and Maritime Equipment Association of Europe and

16 Jul 2025 · Review of the European Oceans Pact and future situation of the Blue Economy

Meeting with Henrik Nielsen (Director Migration and Home Affairs) and

1 Jul 2025 · Entry/Exit System state of play and next steps

Meeting with Apostolos Tzitzikostas (Commissioner) and

13 Mar 2025 · High level dialogue on cruise industries and on European shipyards.

Meeting with Anne Bergenfelt (Cabinet of Commissioner Apostolos Tzitzikostas)

10 Feb 2025 · CLIA Cruise Week 2025 and introductory meeting

Meeting with Cynthia Ní Mhurchú (Member of the European Parliament, Shadow rapporteur) and International Road Transport Union Permanent Delegation to the EU and

30 Jan 2025 · Package Travel Directive

Meeting with Christophe Clergeau (Member of the European Parliament) and WindEurope and

14 Jan 2025 · SEARICA

Meeting with Pasquale Tridico (Member of the European Parliament)

21 Nov 2024 · Meeting with Francesco Galietti - Cruise Lines International Association (CLIA)

Meeting with Susanna Ceccardi (Member of the European Parliament)

13 Nov 2024 · Priorities in the field of Transport and Tourism

Meeting with Jens Gieseke (Member of the European Parliament)

13 Nov 2024 · Austausch zu maritimer Politik

Meeting with Rosa Serrano Sierra (Member of the European Parliament)

13 Nov 2024 · Priorities for European Commission 2024-2029

Meeting with Borja Giménez Larraz (Member of the European Parliament)

13 Nov 2024 · Priorities for the new mandate: cruise lines sector

Meeting with Grégory Allione (Member of the European Parliament)

13 Nov 2024 · Réunion Cruise Lines International Association

Meeting with Kurt Vandenberghe (Director-General Climate Action)

13 Nov 2024 · EU Maritime industrial strategy

Meeting with Magda Kopczynska (Director-General Mobility and Transport)

13 Nov 2024 · • Current state of the EU maritime and shipbuilding industries

Meeting with Jan-Christoph Oetjen (Member of the European Parliament) and Royal Caribbean Group

12 Nov 2024 · General exchange on current tourism topics

Meeting with Kris Van Dijck (Member of the European Parliament)

12 Nov 2024 · Decarbonisation in the EU cruise sector

Cruise industry demands maritime sector provisions in emissions reporting rules

28 Jul 2024
Message — The organization requests adequate provisions for the maritime sector and alignment with FUEL EU certification. They argue the regulation's focus on other sectors creates gaps for shipping and seek equal treatment with aviation in ETS implementing acts.12
Why — This would reduce regulatory uncertainty and avoid conflicting requirements across multiple EU legislations.3

Cruise industry seeks flexibility in FuelEU Maritime verification rules

24 Apr 2024
Message — The cruise industry requests that site visit decisions be left to verifier professional judgement, with waivers when EU ETS visits occurred recently. They seek clarity on compliance balance calculations, pooling mechanisms, and renewable fuel accounting. The industry wants timeline flexibility for verification processes and alignment with EU ETS requirements.1234
Why — This would reduce significant expenses from duplicative site visits and ship inspections.5

Cruise industry seeks clarity on FuelEU Maritime implementation details

24 Apr 2024
Message — The organization requests clarification on administering state definitions, alignment with EU ETS regulations, and publication timelines for outermost region exemptions. They also seek corrections to monitoring plan terminology and ship classifications.123
Why — This would reduce administrative burden and avoid duplication between overlapping EU regulations.45

Meeting with Roxana Lesovici (Cabinet of Commissioner Adina Vălean)

18 Apr 2024 · Decarbonization, Competitiveness, Seafarers/ Skills – Human dimension, Tourism

Meeting with Jens Gieseke (Member of the European Parliament) and Royal Caribbean Group

13 Mar 2024 · Umwelt- und Verkehrspolitik

Meeting with Gerassimos Thomas (Director-General Taxation and Customs Union)

5 Dec 2023 · Physical meeting - EU implementation of the OECD Pillar 2 model tax rules

Meeting with Roxana Lesovici (Cabinet of Commissioner Adina Vălean)

19 Oct 2023 · Maritime package and FuelEU Maritime.

Cruise Industry Urges Less Complex Maritime Emissions Monitoring Rules

31 Aug 2023
Message — The group wants company-level verification restricted to summarizing reports to avoid double-checking data. They also suggest limiting site visits to onshore locations only.12
Why — This would lower compliance costs and minimize time spent on administrative procedures.34
Impact — Public authorities would have less time and restricted access to verify reported emissions.56

Cruise lines urge clarity on maritime emission monitoring rules

30 Aug 2023
Message — 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.12
Why — Flexible accounting and carbon capture recognition would reduce the industry's overall compliance costs.3

Cruise industry urges tailored maritime Innovation Fund criteria

7 Aug 2023
Message — The association requests dedicated maritime funding calls that reflect each shipping segment's unique needs. They want technology-neutral selection criteria that account for differences between vessels carrying passengers versus cargo. They also ask to reduce emphasis on technology maturity as an award criterion.123
Why — This would increase their access to EU funding for advanced cruise ship technologies like fuel cells and hydrogen.4

Meeting with István Ujhelyi (Member of the European Parliament)

28 Jun 2023 · Transportation

Cruise industry urges lower efficiency targets for sustainable shipping

3 May 2023
Message — CLIA recommends reducing energy efficiency targets from twenty percent to ten percent for passenger vessels. They urge the Commission to align fuel definitions with maritime laws to ensure legal certainty. Finally, they advocate for a broader definition of retrofitting that includes minor technical upgrades.12
Why — Easier criteria would allow more cruise companies to qualify for green investment funds.3
Impact — Environmental goals are harmed if fossil-based fuels are permitted to meet sustainability criteria.4

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Meeting with Elsi Katainen (Member of the European Parliament, Shadow rapporteur) and Costa Cruises and

6 Jul 2022 · FuelEU Maritime

Meeting with Jens Gieseke (Member of the European Parliament)

5 Jul 2022 · Austausch zur Verkehrspolitik

Meeting with Jörgen Warborn (Member of the European Parliament, Rapporteur) and World Shipping Council

5 Jul 2022 · Sjöfartsfrågor

Meeting with Alfred Sant (Member of the European Parliament)

5 Jul 2022 · Fit for 55 package

Response to Evaluation of the Visa Code

23 May 2022

On the question regarding whether the visa code has 'contributed to a more harmonised, flexible and secure EU Visa Policy, in line with the ongoing digital transition', the timing of the Visa Code applying coincided with the start of the pandemic, and for many months, the focus was on assisting seafarers to return home, not applying for new visas under the new Visa Code rules. When visa applications did start up again, the process was so back-logged, that it is nearly impossible to determine whether a more harmonised procedure is actually in place. Notably, the 'cascade' approach to MEVs introduced under article 24 which could have a big impact on seafarer visas and simplify procedures for seafarers and cruise companies alike has not been seen at all. We hope that it will be applied as more and more visas are issued. For the moment, crew members still tend to receive short validity single-entry visas with short duration periods. Another area of importance for seafarers and cruise companies has to do with the rules on MEVs being adapted to specific situations in local Schengen cooperation. These discussions have not been possible for the same reasons. A positive aspect which CLIA members have been able to note is that we have examples of Member States allowing seafarers to apply 9-months ahead of their intended date of travel which has been very helpful (in line with article 9). Finally, we very much welcome the recent Commission proposal as regards the Digitalisation of the Visa Procedure. However as it will take years before it is operational, Member States should be encouraged to make use of the digital options they have under the current Visa Code which would greatly facilitate and harmonise procedures, and help avoid the extreme delays the industry experienced during the pandemic.
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

2 Mar 2022 · Clean cruise shipping and sustainable tourism

Meeting with Jutta Paulus (Member of the European Parliament, Shadow rapporteur)

2 Mar 2022 · Fuel EU maritime

Meeting with Ondřej Kovařík (Member of the European Parliament, Shadow rapporteur)

12 Jan 2022 · Energy Taxation Directive

Response to Count your transport emissions: CountEmissions EU

16 Dec 2021

European Commission’s Call for evidence on the new ‘CountEmissions EU’ initiative CLIA Europe welcomes the possibility to comment on the call for evidence on the new ‘CountEmissions EU’ initiative and in principle could support the idea to have a consistent framework. However, CLIA Europe notes that there are already various standards in use and being developed that purportedly claim to measure and normalise GHG emissions. In practice, many only provide an additional method leading to considerable additional administrative burden. CLIA Europe would first like to highlight that shipping, including cruise passenger shipping, is already required to monitor, report and verify its carbon dioxide emissions of vessels under the EU MRV system. The EU MRV sets up four monitoring methods to determine emissions, as well as a database. EU MRV also includes a number of different metrics for calculating the operational efficiency of ships. The Commission makes publicly available all the information about emissions and operational efficiency per ship name and publishes an annual report. Any new regional GHG emission accounting applicable to the maritime sector should be fully aligned and consistent with the existing MRV system already in place. Moreover, it should be(come) fully in line with relevant, regionally and globally applicable metrics in order to avoid any duplication of systems, standards and reporting obligations. The Fitfor55 package including Fuel EU Maritime, RED and the LCA approach should also be very relevant. Second, the proposal is aiming at providing comparison tools between different modes of transport, in line with Action 33, Action 28, Action 34 under the Sustainable and Smart Mobility Strategy COM(2020) 789. CLIA would like to stress that this approach will not be suitable for the cruise passenger sector, since cruise ship operations incorporate many other services, beyond transport. Third, the EC’s call for evidence states: “the main problem that the initiative aims to address is the information failure that prevents companies, customers and passengers from monitoring and comparing easily and accurately various transport service options with respect to their GHG emissions.” It should then be confirmed that these transport services compared provide realistic alternative “transport service options”. Any methodology should be based on existing processes and should not lead to unfair and arbitrary comparison among different transport modes. Any initiative comparing transport modes should therefore consider the full diversity of the shipping sector and the services those transport modes provide. CLIA Europe therefore highlights that more information should be provided and a proper consultation with the stakeholders should be carried out before any policy options are put forward.
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Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

3 May 2021 · The cruise ship industry’s role in supporting a sustainable recovery and the decarbonisation of the economy

Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

Dear, CLIA Europe represents the cruise lines operating in Europe and is the European section of Cruise Lines International Association (CLIA). CLIA members represent 95% of the cruise industry. Our industry fully supports the long-term commitments of continuously reducing the carbon intensity and making progress toward a climate neutral cruise sector in line with the commitments at the IMO. These already agreed commitments and timelines are ambitious and challenging for our sector. The most important development for the shipping industry including the cruise sector to become fully sustainable, is the development and market readiness of zero emission fuels. As of today, these fuels are not available in sufficient quantities or quality. A massive investment is required for research, technology, and infrastructure, with the European shipyards, their suppliers, and ports, supported by national governments and the EU. Please find attached the amendments proposed CLIA Europe to the Draft Delegated Regulation including its Annexes. Best regards,
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Cruise industry demands global shipping standards and R&D support

25 Nov 2020
Message — The industry wants a phase-in period where only partial emissions are covered to avoid distorting competition. They argue that any system must be technology neutral and aligned with global International Maritime Organization standards.123
Why — The industry would secure financial support for new fuel technologies and minimize administrative costs.45
Impact — Non-European ports and shipping companies might face trade disputes due to the regional scope.6

Response to Environmental claims based on environmental footprint methods

30 Aug 2020

Dear, An EU initiative on “Environmental performance of products & businesses – substantiating claims” could have far reaching unintended consequences for a worldwide operating sector which is highly regulated and already knows various environmental indicators, many of whom determined by the market. When applied to shipping and cruise ships, such initiative would therefore require a very thorough Impact Assessment, taking due account of sector specific characteristics and should learn from similar, previous EC initiatives and studies. Any EU driven initiative would not diminish the need for and existence of market driven systems which already answer specific interests and would therefore lead to considerable additional administrative burden to the cruise ship operator. Most importantly, in case this initiative would be made mandatory and be applicable to “services”, the same principles and requirements should apply to any other party making claims about that service. It would be very undesirable situation where one party (e.g. a business owner) would need to comply with specific requirements when presenting their product whereas another party could state whatever it thinks is appropriate about that same product. Therefore, especially at first instance, the scope would need to be limited, should exclude services and focus should be on lower hanging fruit first. The cruise sector provides services worldwide, well beyond Europe and complies with worldwide, regional as well as local regulatory requirements and endeavors going beyond the needs and wishing of its guests and partners. It is common to use regulatory instruments as (a basis for) indicators of environmental performance, whereas it should be noted that the current 2013 Recommendation referenced in the inception impact assessment explicitly excludes regulatory instruments. Due to the lack of clarity on scope and impact on specific sectors, it is unclear from the “Inception Impact Assessment” what problem(s) the initiative would solve in practice and how unintended consequences would be avoided. We would therefore urge the EC to limit the scope of the initiative and define priorities and we are looking forward to receive more information during the impact assessment and the consultation process, especially regarding the options identified under the “Objectives and policy options”. ============ You may also want to note that, though the feedback period to the Roadmap/Impact Assessment hasn’t changed, the consultation period for the Public Consultation has (now planned for 3rd quarter 2020). Thank you for your consideration and feedback to the above proposal. Kind regards, Paul Altena Manager European Government Affairs Cruise Lines International Association (CLIA) Europe Troonstraat 60 | 1050 Brussels paltena@cruising.org | T +32 (0)2 709 01 38 | M +32 (0)472 13 24 20 www.cliaeurope.eu | Facebook | Twitter | LinkedIn
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Response to Sustainable and Smart Mobility Strategy

28 Jul 2020

Dear, Please find attached CLIA Europe's feedback to the Sustainable and Smart Mobility Strategy. CLIA Europe welcomes the intention of the “Sustainable and Smart Mobility Strategy” initiative to support building a fairer, greener and more digital future. The cruise and tourism sectors are committed long term to further improve its operations, contributing to sustainable growth in close cooperation with other stakeholders, also within the more remotely located regions in Europe. For the cruise sector, the development of alternative technologies and fuels is a necessary enabler towards further greening of the shipping sector. Therefore, implementation of this initiative should be closely aligned with the other relevant processes of the EU Green Deal, especially FuelEU Maritime’ and the Alternative Fuels Infrastructure Directive. CLIA members represent 95% of the cruise industry which fully supports the long-term commitments of continuously reducing the carbon intensity and making progress toward a climate neutral cruise sector in line with the commitments at the IMO. These already agreed commitments and timelines are ambitious and challenging for our sector. Kind regards, Paul Altena
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Response to Modernising the EU’s batteries legislation

7 Jul 2020

CLIA Europe would welcome a proposal by the European Commission to modernize the EU’s batteries legislation. Whereas the inception impact assessment understandably references road transport and vehicles, we would like to emphasize that the application of batteries is also an important element of the strategies further reducing emissions in the cruise sector. Although the required size of power installations on oceangoing cruise ships presents some significant obstacles with regard to large scale uptake, CLIA members are already using significant battery installations for emergency power uses and are anticipating deploying them more broadly for limited propulsion augmentation purposes as this technology becomes more viable. Indeed lifecycle sustainability aspects of batteries should be carefully considered. Our members are already looking into these aspects and would be interested to further engage with the EC on this important issue. Though the overwhelming majority of cruise ships is being built at European yards and with European suppliers, we consider international coordination regarding on-board equipment to be of the utmost importance and the IMO would provide a good framework for such discussions. As our members look into increased optimisation of power delivery, we see batteries being one possible important element of the overall strategy which could also include Fuel Cells, LNG, EGCS and other (to be developed) (bio-)fuels and technologies, though at very different stages of maturity and viability. CLIA Europe would be interested in further liaising with the EC on this topic and to share its knowledge and experience.
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Cruise industry urges technology neutral rules and fuel funding

23 Apr 2020
Message — The cruise industry requests rules that do not favor specific technologies. They prioritize fuels that work in existing ship engines. They also advocate for tax exemptions to reduce costs.123
Why — This would protect long-term vessel investments and reduce the financial burden of decarbonization.45

Response to 2030 Climate Target Plan

14 Apr 2020

Dear, Please find attached the feedback from CLIA Europe. Kind regards, Paul Altena
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Meeting with Thierry Breton (Commissioner) and

2 Apr 2020 · COVID 19 economic impact on European tourism industry

Response to Climate Law

5 Feb 2020

Dear, Please find attached the response from CLIA Europe to the European climate law – achieving climate neutrality by 2050. Kind regards, Paul Altena
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Response to Evaluation of the Alternative Fuels Infrastructure Directive

20 Mar 2019

Clear priorities for the public consultation should be to include support for decarbonisation of the shipping sector, should take into account the considerable investments done by the cruise industry already, costs associated with supplying alternative fuels and should support the overall reduction of air emissions and the relevant EU Directives and Regulations for the shipping sector. For instance, and in addition to investments in other alternative fuels, the cruise industry has invested more than 8 billion Euros in building new LNG-fuelled cruise ships. The first cruise ship powered by LNG has launched in 2019 while more than thirteen additional LNG ships are on order and 25 could be in operation by 2025. This represents a percentage of new builds unmatched in the shipping sector. Whenever possible, CLIA Cruise Lines use electric shore power in port, further reducing emissions. Almost 60 percent of new builds have committed to shore power capability, despite the fact that adequate shore power facilities are available in just 13 ports served by cruise ships worldwide and only 1 in Europe (Kristiansand). The availability of Shore Side Electricity should therefore be a clear priority as well. The public consultation should therefore also facilitate the inclusion of priorities not necessarily related to transport (for instance the reference to the TEN-T networks), but also include the need to support first movers in the wider shipping sector including the cruise industry which would also benefitting the EU overall. CLIA Europe is looking forward to contribute and supply additional information to the public consultation.
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Meeting with Alisa Tiganj (Cabinet of Commissioner Violeta Bulc), Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

22 May 2018 · Maritime issues

Response to Fitness Check of the Water Framework Directive and the Floods Directive

15 Nov 2017

Dear Madam, Sir, CLIA Europe welcomes the opportunity to share the views and concerns of the cruise industry in response to the publication of this “Roadmap”. CLIA Europe represents the cruise lines operating in Europe and is the European section of Cruise Lines International Association (CLIA), the world's largest cruise industry trade association with representation in North and South America, Europe, Asia and Australasia. CLIA Europe and its members stand for quality shipping, upholding high environmental and safety standards for the benefit of our passengers, coastal areas, the sea and society at large. Currently, some local and regional implementation of the Environmental Quality Standards Directive 2008/105/EC conflicts with internationally agreed legislation and guidelines. This has resulted in the very undesirable situation that the operation of onboard equipment actually allowed and supported by international laws and guidelines and approved and adopted by European Member States, is not allowed in some European waters of those same Member States. Early movers willing to invest and develop new technologies reducing the impact on the environment while outperforming regulatory standards should be supported by the regulatory framework and receive regulatory certainty. Therefore, the international legislative framework and guidelines should be included in the public consultation to be launched first semester 2018 especially: • IMO MARPOL Annex 6 • IMO 2015 Guidelines for Exhaust Gas Cleaning Systems (Resolution MEPC.259(68) Moreover, CLIA Europe is in the process of developing with other industry partners knowledge providing additional assurances on emissions from cruise ships to the water to authorities and other stakeholders. CLIA Europe is looking forward to further engage and provide its expertise during the public consultation to be launched first semester 2018. Kind regards, CLIA Europe
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Response to Reporting formalities for ships (European Maritime Single Window environment)

25 Aug 2017

Dear madam, sir, Please find attached the feedback from CLIA. Kind regards,
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Response to Evaluation of the Ozone Regulation

11 Aug 2017

Dear, The cruise industry operates worldwide and should therefore in principle be regulated by global regulation only. Any (proposal for) legislation or regulation going beyond international agreements should therefore be considered carefully. We note that the ODS Regulation goes beyond what is already agreed in the Montreal Protocol. Technical and operational consequences for the cruise industry should be considered appropriately when proposing amendments to the ODS Regulation. CLIA welcomes the pubic consultation, targeted consultation for key stakeholders and stakeholder workshop as envisioned in the roadmap. Kind regards,
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Response to Revision of the Shipping MRV Regulation

19 Jul 2017

Please find enclosed the CLIA Europe feedback to the Revision of the Shipping MRV Regulation. Kind regards,
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Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

6 Dec 2016 · Maritime

Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella)

30 Aug 2016 · Cruise tourism, Blue Growth

Response to Shipping Emissions Monitoring Methods

25 Aug 2016

Given the international nature of shipping, full alignment of the EU MRV regulation with the IMO’s approved data collection system is vital. It will not only reduce cost to the EU shipping industry and EU citizens, but also will be the most effective method of reducing shipping’s carbon emissions by creating a true level-playing field. The table on the emission factor per type of fuel should be aligned with Table B.4 of the template monitoring plans (ref. Ares(2016) 3985800). The distance travelled should be defined as distance travelled over the ground. The berth to berth concept should be clarified for situations in which a ship finalizes its voyage by remaining (dynamic) positioning (and therefore not being at berth or at anchor).
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Response to Shipping Emissions Templates

25 Aug 2016

Table B.4 of the template monitoring plans should be aligned with the table on the emission factor per type of fuel in Annex 1 of Regulation 2015/757 (ref. Ares(2016) 3985746). Also, when referring to an IMO Emission Factor, the reference year should be specified. IMO has changed the Emission Factors over the years and may change them again in the future. Table C.2.2 of the monitoring plan template requires recording of procedures for determining fuel bunkered and fuel in tanks. However, the EU MRV Regulation does not require monitoring of fuel remaining on board, but the amount of fuel consumed during the reporting period under the scope of the regulation. In addition, this section may be unnecessary for ships that use method 3 and 4 to monitor their fuel consumption. This section therefore goes beyond the requirements of the EU MRV Regulation and should be deleted accordingly. Moreover, it is noted that it is not specified what should be determined. Table C.2.6: Again, this table is too specific (see also comments to Table C.2.2). The company should specify the method to determine the density of the fuel used. A service tank may therefore be relevant, a fuel tank which is not, will not be relevant and the density of the fuel in that tank may chance over time. This table should therefore only have 2 columns: “Fuel type/tank used” and “Method to determine the density of the fuel used”. Table C.2.6: Footnote 2: it would be more clear if there would be an order in the options: Fuel supplier? If not: (on-board) measurement equipment? If not: laboratory test? This, because the fuel supplier would also apply measurement equipment or laboratory tests. Therefore, currently, more than one category may be correct. Table C.3: It should be made clear that only voyages covered by this Regulation should be included in this list. Table C.6: The definition of “at berth” should include situation where a ship is at anchor or even at drift, in or outside port limits. For instance, a cruise ship may use tenders to transport passengers to and from a berth. Table D.1: “Back up monitoring method”: only the options “(A/B/C/D)” are provided although the option “not applicable” is available in the footnote. The latter should also be included in the table itself. The cell should therefore read: “Back-up monitoring method (A/B/C/D/not applicable). Annex II, Part D: throughout this section, many definitions are applied including: tonnes CO2, tonne fuel, kilogram fuel per nautical mile, kilogram CO2 per nautical mile, grams fuel per tonne nautical mile and grams CO2 per tonne nautical. More alignment especially on gram vs kilogram is recommended in order to prevent any misunderstanding in the future by other parties. Also, there seems to be a doubling in section “Energy efficiency” par. 1.b.
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Response to Shipping Emissions Verification and Accreditation

25 Aug 2016

This regulation should clearly state that any aspect, already verified by Flag and/or Port State control via international treaties and conventions, such as Marpol, and Solas including aspects like the ISM, EEDI and EIV, should only be checked for the presence of a valid certificate, issued by or on behalf of the proper authority. The doubling of administrative burden and associated costs should at all times be prevented. It should be made clear that the ESSF group agreed throughout the Regulation, when referred to “copies”, hard-copies as well as digital copies would be allowed. This may for instance be included in Article 2 of this Regulation “Definitions”. Article 2 contains a definition on “non-conformity”. Point a) and point b) refer to ship responsibilities while point c) refers to the verifiers responsibility. This is very confusing and therefore should be amended. Article 2, point 10: the definition on “Material misstatement” is not in line with article 17. The section “or could affect the treatment of the emissions report” is too vague and should be deleted. The description used in Article 17 should be applied. Article 4, point 3: “its assessment of the plan” should be changed to “the verifier’s assessment of the plan”. Article 6 and Article 16: According to the Article 15.4 of the EU MRV regulation the verifier may conduct spot checks. However, Article 6 – ‘’Site visits’’ of the implementing acts, makes sites visits mandatory by stating that ‘’the verifier shall carry out site visits’’ and ‘’any waives of the site visit should be properly justified’’. According to our recollection, the majority of the EU MRV Sub-group had opted for remote verification and that site visits may be possible when based on the risk assessment by the verifier. Therefore, we believe that this paragraph needs to be revised to better reflect the agreement reach at the EU MRV Subgroup meetings and the EU MRV regulation, as site visits will increase considerably the cost and time duration of the verification. Article 8 requires that the verifier’s work regarding its assessment of the monitoring plan is reviewed by an independent reviewer. This double verification process is unnecessary, increases the cost of the verification and its benefits are not clear and therefore not justified. Moreover, the results of the “independent review” only need to be included and therefore do not serve a clear purpose. Also, the verifier is already accredited by an EU National Body. That accreditation should be sufficient to prove that the verifier’s work meets the requirements of the EU MRV regulation. We would therefore recommend to remove this requirement or include the use of an independent reviewer as an option for the verifier’s internal quality control process, linked to the accreditation process. Article 10: it should be clarified that it was agreed that “copies” include hard-copies as well as digital copies. Article 10, point 2: It is unclear to which logbooks the phrase “ship’s official logbook” refers to. Providing copies of logbooks will be a very burdensome and costly exercise. It should be stated in this article that only relevant to the scope of the MRV and appropriate logbooks should be made available to the verifier. For some logbooks copies (hard copies or digital copies) may be available. The ORB should be used only to verify if the entries of bunkering operation match the bunkering document. The verifier should ask only ( b) and (c) of paragraph 2 article 10. Paragraph 3 (d) should be clarified for the definition of “evidence” with regard to the fuel tank meter reading” and for which tanks, storage, service? Again, only fuel consumed is to be reported via this Regulation and it should be left to the company and the very different designs of the ships in coordination with the verifier to specify which manner is most appropriate. Article 13 requires verifiers to verify whether the monitoring and reporting systems exist in practice
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