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European Community Shipowners' Associations

ECSA

ECSA represents the national shipowner associations of the European Union and Norway.

Lobbying Activity

Meeting with César Luena (Member of the European Parliament)

15 Jan 2026 · ETS

Meeting with Bruno Tobback (Member of the European Parliament)

9 Dec 2025 · ECSA 60 Years Anniversary Reception

European Shipowners demand removal of cargo restrictions from EU Taxonomy

5 Dec 2025
Topic — This initiative updates technical screening criteria for the EU environmental taxonomy regulation.
Message — ECSA recommends removing cargo-based restrictions and aligning environmental thresholds with current maritime regulations. They also request aligning financial reporting definitions with international standards to reduce complexity.12
Why — This would reduce disproportionate compliance costs and help maintain Europe's attractiveness as a shipping hub.3
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Meeting with Flavio Laina (Head of Unit Competition)

1 Dec 2025 · Competitiveness of EU Shipping sector

Meeting with Tiemo Wölken (Member of the European Parliament)

1 Dec 2025 · Maritime Emissions in the EU and internationally

Meeting with Peter Liese (Member of the European Parliament) and Stellantis

26 Nov 2025 · Austausch

Meeting with Yannis Maniatis (Member of the European Parliament)

26 Nov 2025 · STIP

Meeting with Jens Gieseke (Member of the European Parliament) and Association des Constructeurs Européens d'Automobiles

26 Nov 2025 · Austausch zu EU-Verkehrspolitik

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

26 Nov 2025 · STIP

Response to Ship recycling – format of the certificate on the inventory of hazardous materials

7 Nov 2025

European Shipowners | ECSA welcomes and supports this initiative, which contributes to enhancing legal certainty, ensuring coherence with the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC), and reducing administrative burdens for both industry and competent authorities.
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Response to Ship recycling – format of the ready for recycling certificate

7 Nov 2025

European Shipowners | ECSA welcomes and supports this initiative, which contributes to enhancing legal certainty, ensuring coherence with the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC), and reducing administrative burdens for both industry and competent authorities.
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Meeting with Kurt Vandenberghe (Director-General Climate Action)

22 Oct 2025 · discuss about the recent developments and the alignment of the EU legislation with the international measures

European Shipowners Call for Enhanced Cooperation Against Drug Trafficking

26 Sept 2025
Topic — New EU strategy and action plan to combat drug trafficking and security threats.
Message — The association requests enhanced cooperation across the supply chain and with third countries to detect trafficking. They emphasize that national authorities should lead efforts, as private companies lack enforcement tools. They also call for fair treatment of seafarers during criminal proceedings when drugs are found onboard.123
Why — This would shift enforcement responsibility to authorities and protect their seafarers from unfair prosecution.45
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Shipowners oppose extending carbon border mechanism to shipping

26 Aug 2025
Topic — The EU is consulting on expanding the Carbon Border Adjustment Mechanism to include downstream products.
Message — Shipowners question the added value of extending CBAM to shipping because it covers the same scope as the EU ETS. They argue this would create unnecessary administrative complexity and demand full harmonization with international frameworks.12
Why — This would prevent a disproportionate administrative burden and double payments for the same greenhouse gas emissions.34
Impact — European consumers would face higher transport costs while industry loses global competitive advantage.56
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European shipowners urge EU to create single CO2 transport market

19 Aug 2025
Topic — Legislative initiative to develop competitive markets and transportation infrastructure for carbon dioxide.
Message — Shipowners want a single European market for CO2 transport to replace bilateral deals. They request that onboard carbon capture be integrated into EU strategies and funding.12
Why — This would open new revenue streams and lower costs for older vessels.3
Impact — National authorities lose the ability to manage CO2 transport through specific bilateral deals.4
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European shipowners urge EU to fund green fuel transition

11 Aug 2025
Topic — The consultation develops a strategic framework for investing in sustainable transport fuels.
Message — The group wants EU ETS revenues to fund the gap for green fuels. They propose a 40% domestic production mandate for fuel suppliers. Finally, shipping should be prioritized over road transport for fuel supplies.123
Why — Reinvesting revenues would lower high costs for shipowners adopting clean fuels.4
Impact — The road transport sector loses access to limited advanced biofuels and e-fuels.5
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European shipowners urge port investment in clean fuel infrastructure

25 Jul 2025
Topic — The EU Ports Strategy frames challenges regarding security, competitiveness, energy transition, and infrastructure.
Message — ECSA recommends boosting port infrastructure investment to turn ports into energy hubs. They call for revising AFIR to include e-fuel storage and maintaining anti-drug trafficking efforts.123
Why — Shipowners would benefit from guaranteed access to clean fuels and necessary onshore power.4
Impact — National budgets and port operators face higher costs for mandatory, specialized e-fuel storage facilities.5
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Response to EU industrial maritime strategy

25 Jul 2025

Please find attached the feedback by European Shipowners | ECSA to the call for evidence on the EU Maritime Industrial Strategy.
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European Shipowners urge grid upgrades for clean maritime fuels

22 Jul 2025
Topic — EU initiative to modernize energy infrastructure and expand electricity and hydrogen grids.
Message — ECSA calls for grid upgrades including hydrogen and CO2 infrastructure to support ship decarbonization. They recommend revising fuel regulations to mandate storage and refuelling capacity at ports.123
Why — This ensures ports have the necessary power and fuel to meet strict emission rules.45
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Meeting with Annika Kroon (Head of Unit Mobility and Transport)

18 Jul 2025 · Meeting with ECSA representatives on reporting obligations

Meeting with Apostolos Tzitzikostas (Commissioner) and

17 Jul 2025 · Implementation Dialogue on ramping up renewable and low-carbon maritime and aviation fuels production in the EU

Meeting with Jan-Christoph Oetjen (Member of the European Parliament)

14 Jul 2025 · General exchange on the European Maritime Industrial Strategy

European Shipowners Urge Full Harmonisation of EU ETS with IMO Climate Agreement

8 Jul 2025
Topic — Review of EU Emissions Trading System for shipping sector decarbonisation.
Message — The organization requests full harmonisation of EU ETS and FuelEU Maritime with the new IMO net-zero framework. They want simultaneous review of both regulations to avoid double regulation and double payment for emissions. They argue shipping needs one global regulatory framework.123
Why — This would eliminate duplicate compliance costs and administrative burdens from overlapping regulations.45
Impact — EU climate ambition could be weakened if harmonisation dilutes stronger European standards.
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European Shipowners demand dedicated maritime funding and simplified rules

8 Jul 2025
Topic — This consultation evaluates the operations and performance of the EU Innovation Fund.
Message — ECSA calls for dedicated maritime funding and earmarking carbon revenues for shipping. They suggest flexible eligibility based on vessel management rather than port calls. They propose a grace period for missing documents to help smaller companies.123
Why — This would provide financial support to bridge the price gap for clean fuels.4
Impact — European equipment manufacturers lose if funding supports technology produced outside the region.5
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Meeting with François Kalfon (Member of the European Parliament)

2 Jul 2025 · Décarbonation des transports

Meeting with Ilia Lazarov (Member of the European Parliament)

2 Jul 2025 · Clean fuels in maritime transport

Meeting with Apostolos Tzitzikostas (Commissioner) and

1 Jul 2025 · Strategic Dialogue on the EU Industrial Maritime Strategy

Meeting with Apostolos Tzitzikostas (Commissioner) and

1 Jul 2025 · Strategic Dialogue on the EU Port Strategy

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

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

Meeting with Stéphane Séjourné (Executive Vice-President) and

1 Jul 2025 · EU Strategic Dialogue on the EU Industrial Maritime Strategy.

Meeting with Ruth Reichstein (Cabinet of President Ursula von der Leyen)

26 May 2025 · Shipping industry

Meeting with Ruth Reichstein (Cabinet of President Ursula von der Leyen)

26 May 2025 · TO FOLLOW

Meeting with Daniel Attard (Member of the European Parliament)

20 May 2025 · Maritime Port Strategy

Meeting with Annika Kroon (Head of Unit Mobility and Transport)

20 May 2025 · IMO Net zero framework and FuelEU review process

Meeting with Bruno Tobback (Member of the European Parliament)

13 May 2025 · STIP and the European Maritime Industrial Strategy

Meeting with Jens Gieseke (Member of the European Parliament) and Bundesverband Güterkraftverkehr Logistik und Entsorgung (BGL) e.V. and

13 May 2025 · Austausch zu EU Politik

Meeting with Polona Gregorin (Head of Unit Climate Action)

28 Apr 2025 · General discussion on the upcoming ETS review – Maritime

European shipowners demand removal of cargo-related taxonomy restrictions

26 Mar 2025
Topic — This consultation seeks to simplify EU sustainability reporting and reduce administrative costs.
Message — ECSA demands the removal of cargo restrictions from technical screening criteria. They call for consistent reporting rules to avoid administrative complexity and overlaps.12
Why — Removing cargo restrictions ensures shipowners maintain access to finance for green transitions.3
Impact — Environmental initiatives lose if the taxonomy ignores the impact of fossil fuel shipments.4
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Meeting with César Luena (Member of the European Parliament, Rapporteur) and World Shipping Council

25 Mar 2025 · Pellets Regulation

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

20 Mar 2025 · Animal welfare during transport

Meeting with Mohammed Chahim (Member of the European Parliament)

20 Mar 2025 · European Shipping Summit 2025 (event, speaker)

Meeting with Maroš Šefčovič (Commissioner) and

20 Mar 2025 · Ship Industry

Meeting with Apostolos Tzitzikostas (Commissioner) and

19 Mar 2025 · Exchange of views on maritime policy

Meeting with Gerben-Jan Gerbrandy (Member of the European Parliament)

6 Mar 2025 · Meeting KVNR

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

6 Mar 2025 · Exchange of views on initiatives regarding the shipping sector

Meeting with Sérgio Gonçalves (Member of the European Parliament)

4 Mar 2025 · Priorities for this mandate

European shipowners urge Oceans Pact to boost maritime competitiveness

17 Feb 2025
Topic — The European Oceans Pact aims to harmonize EU policies for a healthy, resilient blue economy.
Message — The organization requests the Pact protect industry competitiveness and ensure a level playing field. They call for a mandate requiring fuel suppliers to produce 40% of clean fuels within Europe. They also want carbon market revenues used to subsidize the high costs of green ships.123
Why — Accessing carbon market revenues would lower the industry's costs for transitioning to green fuels.4
Impact — Global fuel producers lose business as shipping fuel production is mandated for European suppliers.5
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Meeting with Polona Gregorin (Head of Unit Climate Action) and Orange and Armateurs de France

12 Feb 2025 · Discussion on the EU Emissions Trading System (ETS) extension to maritime and the situation of cable-layers vessels

Meeting with Anna Panagopoulou (Cabinet of Commissioner Apostolos Tzitzikostas), Anne Bergenfelt (Cabinet of Commissioner Apostolos Tzitzikostas)

14 Jan 2025 · Introductory meeting

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

14 Jan 2025 · SEARICA

Meeting with Sofia Asteriadi (Cabinet of Commissioner Maroš Šefčovič)

13 Jan 2025 · Courtesy Visit

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

4 Dec 2024 · EU Shipping Industry priorities for the Clean Industry Deal and Maritime Industrial Strategy

Meeting with Ana Vasconcelos (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

2 Dec 2024 · Accounting of greenhouse gas emissions of transport services 2023/0266(COD)

Response to Ship recycling – European list of ship recycling facilities (14th edition)

28 Nov 2024

Please find enclosed the feedback of ECSA to the consultation.
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Meeting with Elena Kountoura (Member of the European Parliament)

17 Oct 2024 · Meeting with ECSA representatives

Meeting with Jens Gieseke (Member of the European Parliament)

16 Oct 2024 · Austausch zu maritimer Politik

Meeting with Peter Liese (Member of the European Parliament)

10 Oct 2024 · Klimapolitik

Meeting with Sakis Arnaoutoglou (Member of the European Parliament)

1 Oct 2024 · Major challenges faced by the shipping industry and maritime transport

Meeting with Michalis Hadjipantela (Member of the European Parliament)

5 Sept 2024 · Introductory Meeting with ECSA

Response to Monitoring and reporting of greenhouse gas emissions from offshore ships and zero-rating of sustainable fuels

3 Sept 2024

ECSA welcomes the draft delegated act on the inclusion of offshore vessels in the EU MRV, as it is of utmost importance for the decarbonisation and environmental sustainability of the maritime industry. While we support the inclusion of offshore vessels under the EU ETS, the current MRV framework is not fit for purpose in addressing the unique operational characteristics of this segment of the industry. We therefore would like to outline below the main issues we have identified and propose solutions to address them (see enclosed document).
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Meeting with Elissavet Vozemberg-Vrionidi (Member of the European Parliament, Committee chair) and Union of Greek Shipowners - ΕΝΩΣΙΣ ΕΛΛΗΝΩΝ ΕΦΟΠΛΙΣΤΩΝ

3 Sept 2024 · Maritime Affairs

Meeting with Yannis Maniatis (Member of the European Parliament) and FuelsEurope

16 Jul 2024 · Introductory Meeting

European shipowners seek clarifications on FuelEU Maritime monitoring plans

23 Apr 2024
Topic — Template for monitoring renewable and low-carbon fuel use in maritime transport.
Message — The association requests clarification on mandatory reporting requirements for different ship types and alignment of terminology across documents. They highlight inconsistencies in abbreviations and definitions that need correction.123
Why — This would provide clearer compliance requirements and reduce confusion in reporting obligations.4
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European shipowners seek clarity on FuelEU Maritime verification rules

23 Apr 2024
Topic — New EU regulation on verification of renewable and low-carbon fuel use in maritime transport.
Message — The association requests clarifications on site visit requirements, data verification boundaries, and pooling procedures. They want verifiers to upload reports directly and seek guidance on record requirements for compliance pooling.123
Why — This would reduce duplicate site visits and clarify verification scope, lowering compliance costs.45
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Meeting with Ditte Juul-Joergensen (Director-General Energy) and Transport and Environment (European Federation for Transport and Environment) and

8 Apr 2024 · Energy market

Meeting with Kurt Vandenberghe (Director-General Climate Action)

12 Mar 2024 · the EU climate targets

Meeting with Marco Zanni (Member of the European Parliament, Shadow rapporteur)

21 Feb 2024 · Basel III Finalisation - Taxonomy

Meeting with Roxana Lesovici (Cabinet of Commissioner Adina Vălean)

30 Jan 2024 · Maritime transport policies

Response to Evaluation of the implementation of the EU Drugs Strategy and of the EU Drugs Action Plan 2021-2025

16 Jan 2024

ECSA represents 21 national shipowners associations based in the EU and Norway. European shipowners control 39.5% of the global commercial fleet, contribute 149 billion euros per year to the EU GDP and provide 2 million Europeans with careers both on board and ashore. ECSA strives for a regulatory environment that fosters the international competitiveness of European shipping, to the benefit of the EU. ECSA strongly support the EUs efforts in addressing the challenges created by drugs trafficking. However, due to the complex issue these challenges represent, it is important to coordinate across the EUs various initiatives. The EU Drugs Strategy 2021-2025 should complement, and not duplicate, initiatives such as the EU Roadmap to fight Drug Trafficking and Organised Crime. From a shipping perspective, the following two strategic priorities from the strategy are especially important: 2.1. Counter the smuggling of drugs and drug precursors in and out of the EU by using established legitimate trade channels. 2.2. Increase monitoring of border crossings that are not part of established trade channels to more effectively prevent illicit or undeclared crossings of the EU external borders. It is a joint responsibility for all actors in the supply chain to work together in addressing and combatting drug smuggling and organised crime. However, national authorities should have a leading role, as they have some tools at their disposal that private companies do not: intelligence sharing and cross border cooperation between the Member States and internationally ; collaboration between EU agencies regarding customs and border control, police, and anti-corruption measures. ECSA and its members welcome the chance to support this effort, as the increasing illegal drugs trafficking constitutes an ever-present risk, not least to the employees both abord the ship and on land.
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Response to Business in Europe: Framework for Income Taxation (BEFIT)

16 Jan 2024

The European Community Shipowners Associations (ECSA) represents 21 national shipowners associations based in the EU and Norway. European shipowners control 39.5% of the global commercial fleet, contribute annually 149 billion euros to the EU GDP and provide 2 million people with careers both on board and ashore. ECSA strives for a regulatory environment that fosters the international competitiveness of European shipping, to the benefit of the EU. Shipping is a cornerstone of Europe's security - from energy to food and supply chain security. The European shipping fleet is one of the largest in the world, representing 39.5% of the world fleet enabling the EU to play a leading role in the global supply chains. Shipping delivers the goods we need, supports EU exports and connects European citizens within Europe and with the rest of the world. In the past years, the COVID pandemic, the war in Ukraine and the energy crisis have brought to the forefront the strategic role of shipping and seafarers to Europes security and prosperity. Shipping also plays a strategic role in achieving its climate objectives towards the Fit-for-55 target by 2030 and the net-zero target by 2050. European shipping competes on the global stage. Global challenges can only be addressed through coherent regulation ensuring a level playing field at international level. A fit-for-purpose regulatory and taxation framework is crucial to ensure that EU shipping companies remain globally competitive. ECSA welcomes that the European Commission it its recent proposal for a directive for Business in Europe: Framework for Income Taxation (BEFIT), recognises the specificities of the European shipping sector. ECSA strongly supports recitals (11), (13) and Article 15, which define the exclusion from the scope of this proposal certain shipping activities. ECSA is ready to use its expertise and the expertise of its members to be a reliable and collaborative partner to the Commission in providing further technical details if needed.
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Meeting with Magda Kopczynska (Director-General Mobility and Transport)

19 Dec 2023 · - Maritime Security - Climate and environment: CO2 reductions, alternative fuels, ship recycling - Social aspects and skills

Meeting with Roxana Lesovici (Cabinet of Commissioner Adina Vălean)

27 Nov 2023 · General review of maritime files

Meeting with Dino Toljan (Cabinet of Vice-President Maroš Šefčovič), Juraj Nociar (Cabinet of Vice-President Maroš Šefčovič)

9 Nov 2023 · Shipping industry and FF55

Response to Revision of the Union Customs Code

7 Nov 2023

The European Community Shipowners Associations (ECSA) represents 20 national shipowners associations based in the EU and Norway. European shipowners control 39.5% of the global commercial fleet, contribute annually 149 billion euros to the EU GDP and provide 2 million people with careers both on board and ashore. ECSA strives for a regulatory environment that fosters the international competitiveness of European shipping, to the benefit of the EU. ECSA welcomes the European Commissions proposal for a Regulation on the revision on the Union Customs Code and the European Union Customs Authority. We agree that the EUs customs framework should take into account the transformations of the market, the evolution of new digital data submission solutions and the growth of e-commerce. Therefore, ECSA welcomes the European Commissions efforts to strive towards standardisation of technology and processes. ECSA also welcomes the objective of aligning this regulation with other legislative initiatives such as the VIDA proposal, which would be a step towards providing regulatory consistency. We also recognise the merits of an EU customs agency would bring by contributing to bring more consistency in practices across the EU. Finally, ECSA also strongly supports the aim to reform the Authorised Economic Operator (AEO) scheme and the introduction of trust and check processes which need to bring simplifications and facilitations for the legitimate trade. The proposed reform is important for strengthening the single market, for the protection of EU trade and citizens and to bring the legal framework in line with the digital challenge of the 21st century. This exercise will also have to take into account the need to have a more efficient system facilitating trade and smarter border requirements. Considering the importance of shipping in international trade, ECSA supports the reform which is ambitious and is going in the right direction. ECSA shall use its expertise and the expertise of its members to be available, collaborate with the commission and be a force de proposition through this long journey.
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European shipowners seek clarification on EU emissions trading compliance

28 Sept 2023
Topic — EU rules for administering shipping companies under the Emissions Trading System.
Message — The association requests clear wording on legal consequences when shipping companies fail obligations, specific provisions for non-EU ship management companies established in Member States, and a process for advance declaration of responsible entities. They propose amendments allowing determination of registration based on establishment address and a December 2023 deadline for voluntary declarations.1234
Why — This would provide legal certainty and avoid practical complications in ETS implementation.56
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European Shipowners demand dedicated EU funding for maritime decarbonisation

7 Aug 2023
Topic — The EU is revising rules for the Innovation Fund's competitive bidding process.
Message — ECSA calls for shipping-specific calls to be launched early using earmarked allowances. The group wants the fund to finance low-carbon fuels to bridge price gaps. They request project rankings account for the high cost of reducing shipping emissions.123
Why — Dedicated funding ensures shipping projects win grants despite having high abatement costs.4
Impact — Non-maritime sectors lose access to the allowances reserved for exclusive shipping calls.5
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Meeting with Roxana Lesovici (Cabinet of Commissioner Adina Vălean)

20 Apr 2023 · Meeting on maritime energy transition

Meeting with Pierre Karleskind (Member of the European Parliament) and Repsol, S.A.

1 Dec 2022 · Décarbonation du transport maritime

Meeting with Clara De-La-Torre (Acting Director-General Climate Action)

28 Nov 2022 · ETS maritime

Meeting with Anne Funch Jensen (Cabinet of Executive Vice-President Margrethe Vestager), Stina Soewarta (Cabinet of Executive Vice-President Margrethe Vestager)

19 Oct 2022 · OECD and State aid

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

14 Oct 2022 · ETS

Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

12 Sept 2022 · State of play of the FuelEU Maritime initiative and discussion on how to foster the uptake of cleaner fuels in shipping

Meeting with Roxana Lesovici (Cabinet of Commissioner Adina Vălean)

30 Jun 2022 · Ongoing maritime files in the Fitfor55 package

Response to Evaluation of the Ship Recycling Regulation

29 Jun 2022

ECSA and ICS welcome the efforts of the Commission and Member States to ensure safe and environmentally sound ship recycling practices and standards, and to facilitate the early entry into force of the Hong Kong Convention. The shipping industry is committed to improving the conditions of recycling operation in order to ensure that ships are recycled in a responsible manner without risk to life, health or the environment. ECSA and ICS welcome the possibility to contribute to this call for evidence for an evaluation / fitness check of the ship recycling regulation. The call for evidence includes questions, which will be covered by the evaluation that the Commission has to prepare by 31 December 2023. ECSA and ICS would like to answer to some of the questions raised by this call for evidence (see enclosed document).
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Meeting with Roxana Lesovici (Cabinet of Commissioner Adina Vălean)

8 Jun 2022 · ongoing maritime files, taxonomy, impact of the Russian war in Ukraine

Response to Improving environmental protection through criminal law

21 Apr 2022

ECSA, ICS and the IG P&I Clubs welcome the efforts of the European Commission to reinforce environmental protection in particular by setting as a high priority the preservation of the oceans and the seas. However, in the context of shipping, the new proposal on the protection of the environment through criminal law (ECD) which aims to replace Directive 2008/99/EC, leads to discrepancies in the interpretation of existing EU and international instruments. Rather than creating the expected harmonisation and enhancing the protection of the environment, it creates legal uncertainty. Clarity and certainty are essential where criminal liability and an individual’s personal freedom is at stake: for a crime to have been committed, the offender should have known that their actions are unlawful. It is the severity of the actions of the offender that should be the focus and most relevant factor when seeking to impose penalties and criminal sanctions and not the severity of the consequences arising from those actions. Executive Summary: • An extension of the ECD to other areas of maritime legislation is unnecessary and may contradict the Member State’s obligations under international maritime treaties and would provide no additional dissuasive measures that would meet the Commission’s stated objectives; • The international treaties MARPOL and UNCLOS already restrict when and what type of criminal penalties may be applied to foreign seafarers and foreign flagged ships visiting EU ports; • The concept of “serious negligence” contained in the ECD (Article 3 (2) of the new proposal) is not in line with these international treaties. EU Member States have existing treaty obligations vis-à-vis other State Parties that they are legally bound to uphold and must interpret “serious negligence” in line with the definition of conduct to be regarded as criminal under MARPOL. • EU regulators should be cautious when aiming to harmonise different legislations through a “one size fits all” framework. Changing the substance of several pieces of legislation could have unintended consequences, especially where they will already have been interpreted by the courts of EU Member States; • Administrative sanctions have proven effective for the shipping industry and should be maintained over criminal sanctions; • Sanctions must be effective, dissuasive and proportionate. Their imposition must not have consequences which are manifestly incompatible with the purpose pursued; • Criminal prosecution of individuals for accidental pollution reduces the attractiveness of the seafaring career and its expansion will contribute to the existing severe difficulties in recruiting seafarers. Please see attached ECSA, ICS and IG P&I Clubs position paper on the new proposal on the Protection of the Environment through Criminal Law.
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Response to Minimum level of taxation for large multinational groups

6 Apr 2022

The European Community Shipowners’ Associations (ECSA) welcomes the opportunity to give feedback on the Commission's Proposal for a directive to implement the OECD Pillar Two rules. ECSA would like to draw the attention of the Regulators that the EC Proposal in its current form may lead to competitive disadvantages and distortions. ECSA calls upon the Regulators to ensure consistency between the EU’s proposed Directive implementing the OECD Pillar II minimum global tax regime and the OECD Framework, (and its implementation within other jurisdictions) while safeguarding the competitiveness of the European shipping industry and to avoid the distortion of competition. In this regard we call for the following changes: - in line with the OECD GloBE rules and with Article 8 MTC and its commentary, slot chartering activities should be considered as international shipping income: the definition of qualified ancillary shipping income should be aligned with the definition included in the OECD Pillar II text; - in line with the Commission's approach expressed in their introductory remarks (paragraph 15), the definition of shipping income to be excluded should be fully in line with the definitions of those shipping tax regimes which in some crucial points differ from the article 8 OECD MTC-definition. A too narrow definition of shipping income could cause qualifying shipping income under EU tonnage tax systems to be taxed under the top-up taxation of the GloBE-rules and the proposed Directive, which may lead to a severe distortion of the present level playing field within EU and outside EU shipping tax regimes. This distortion might cause EU ship owners to leave the EU due to the fact that the proposed Directive, for valid EU-law reasons, applies the top-up taxation also on (large-scale) domestic groups whereas the GloBE-rules are only applicable on MNE’s; - simultanious implementation accross jurisdictions should be ensured. ECSA, hence, shares its suggestions how to amend the Proposal to avoid competitive disadvantages and distrortions. Further details and explanation can be found in the attached file.
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Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

16 Mar 2022 · Decarbonisation of the maritime sector in the context of Fit-for-55

Response to Update of the European List of ship recycling facilities - 9th version

9 Mar 2022

Please find enclosed the feedback of the European Community Shipowner's Associations (ECSA).
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

23 Feb 2022 · Taxonomy criteria

Response to Better protection for passengers and their rights

14 Jan 2022

The European Community Shipowners' Associations (ECSA) believes that the current Regulation (EU) No 1177/2010 concerning the rights of passengers when travelling by sea is fit for purpose and sees no compelling need for any new initiative. In fact, ferry and cruise sectors are known for their high standards of customer service. This conclusion was also drawn by the recent evaluation itself (Commission Staff Working Document) where it is stated that the National Enforcement Bodies received a very low number of complaints from passengers, although the number of passengers is increasing exponentially. The evaluation seems to suggest that the current legislation is fit for purpose and a new revision will not bring an actual added value compared to the current legal framework. This conclusion seems to be in line with the objectives of the better regulation agenda, its policy and principles in particular with regard to strengthening subsidiarity (Commission should aim to only act where it is necessary) and proportionality (ensure that regulatory actions do not exceed what is necessary to achieve the legislative and policy objectives). Finally, it should be noted that ECSA supports initiatives that help improve the implementation of existing sectoral regulations and the provision of more information on available services, through guidance and information that is consistent with national law and practices. ECSA believes that the current Regulation address these challenges in an adequate and reasonable way. The contractual, legal, insurance, practical, operational and economic implications of a new legislative framework for different transporters will far outweigh the possible gains for the passenger and cannot be justified.
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Response to Evaluation of the Environmental Liability Directive and of its implementation

21 Dec 2021

The European Community Shipowners Associations (ECSA), the International Chamber of Shipping (ICS), the International Group of P&I Clubs (IG P&I) and BIMCO, would like to reply jointly to this Call for Evidence for an Evaluation of the Environmental Liability Directive. Please note their main comments and concerns below: • We support the International regime for liability and compensation for environmental damage from a shipping incident and strongly urges the continued retention of exceptions so as to maintain the application of the international regime without conflict with the ELD; • In fact, environmental damage from shipping incidents should continue to be covered under the International Conventions, rather than under the ELD, as stated in Article 4.2 of ELD; • The 2016 Commission Staff Working Document on the Evaluation of the Environmental Liability Directive Accompanying the document Report from the Commission to the European Parliament and to the Council pursuant to Article 18(2) of Directive 2004/35 on environmental liability with regard to the prevention and remedying of environmental damage concluded that “the exemptions to the ELD in favour of some international conventions in the field of maritime transport should be maintained for the time being because IMO Conventions have, despite lower environmental remediation standards than the ELD a range of other advantages (no significance threshold, mandatory financial security, right of direct recourse against the insurer, three tier financial security for oil pollution damage, world-wide scope)”; • ELD should therefore only be of relevance for the few ship-source pollution damage liabilities where the conventions are not in force in an EU Member State; • It is important to recall also that the IMO Conventions provide that “no claim for compensation for pollution damage may be made against the shipowner otherwise than in accordance with the Convention(s)”. If the ELD applied to claims for environmental damage from shipping incidents, EU Member States would have to denounce the IMO Conventions in order to avoid breaching their international treaty law obligations. That would result in less protection for environmental damage from shipping incidents, including within the EU and severely undermine the international system; • Therefore, in the interest of legal principles of certainty and uniformity of law, any legislation with regard to environmental liability shall always include an exception for any damage from shipping incidents governed by international conventions. This legal reasoning should be disseminate to all governments and public bodies in order to avoid any possible conflict between EU law and international conventions; • Since the shipowner will be held strictly liable and knows that all claims will be channelled to him, he also has to carry sufficient insurance to pay the claims. The IMO Conventions ensure that compensation will be available and not defeated by for example, insufficient assets by the shipowner to pay the liability, by requiring the ship to carry a State issued certificate verifying that financial security/insurance is in place; • These measures have proven to work well over the past decades, providing effective compensation and reparation to claimants where needed in States worldwide, including EU Member States, without the need to await the outcome of potentially lengthy legal proceedings; • Finally, it should be highlighted that since the last Evaluation in 2016, five States have ratified the HNS Convention. Several other states including France, Belgium, Netherlands and Germany are currently taking active steps towards ratification. The shipping industry is glad to see the active work and commitment from EU states towards the ratification of the Convention and the industry continues to be fully supportive of its entry into force. Please see document attached for the full ECSA, ICS, IG P&I and BIMCO joint submission.
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Response to Count your transport emissions: CountEmissions EU

16 Dec 2021

ECSA welcomes the possibility to comment on the call for evidence on the new ‘CountEmissions EU’ initiative. ECSA would like to highlight that shipping is already required to monitor, report and verify the carbon dioxide emissions of vessels under the EU MRV system (Regulation (EU) 2015/757). The EU MRV already sets up four monitoring methods to calculate the emissions, as well as a database where they have to be reported to. EU MRV includes a number of different metrics for calculating the operational efficiency of ships as well. The Commission makes publicly available all the information about emissions and operational efficiency per ship name and publishes an annual report. All stakeholders have access to this information. In the framework of the development of the ‘CountEmissions EU’ initiative, the existence of the EU MRV scheme needs to be taken into account, in order to avoid any duplication of the schemes, the standards, as well as of the reporting obligations. The administrative burden on shipping companies should also be limited. The diversity of the shipping sector is also an essential element that should be taken into consideration. In addition, any methodology should remain voluntary and should not lead to unfair and arbitrary comparison among different transport modes. ECSA 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. ECSA looks forward to participating to the next steps of the consultation process.
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Response to Criteria for determining that a ship produces reduced quantities of waste

9 Nov 2021

ECSA supports the objectives of the Port Reception Facilities directive and welcomes the possibility to comment on the implementing regulation on sustainable management of on-board ship waste. ECSA believes that the implementing regulation should be clarified to explain that the “Means of verification” listed in section 1 and 2 of the annex are not cumulative, are given as an indicative list and that additional schemes could be used by ships to demonstrate that they comply with the criteria. For example, the following means of verification should be added for both mandatory criteria listed in Section 1: - Vessel Specific Garbage Management Plan, approved from vessel’s classification society and - ISO 14001 Environmental Management System. For the optional criteria listed in Section 2, the following means of verification should be added: - Ship Energy Efficiency Management Plan (SEEMP), for the first criterion related to the use of alternative fuels and other energy sources. - ISO 14001 Environmental Management System, for the last criterion related to the on-board re-use and recycling.
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European Shipowners urge shift in FuelEU Maritime responsibilities

8 Nov 2021
Topic — EU regulation requiring cleaner fuels in maritime transport by 2050.
Message — ECSA requests that EU fuel suppliers, not ships, be made responsible for meeting fuel standards. They argue enforcement loopholes exist when non-EU suppliers provide documentation and that this approach would align with other transport sectors.123
Why — This would reduce their compliance burden and legal liability for verifying fuel quality.45
Impact — Non-EU fuel suppliers lose competitive advantage from less stringent enforcement outside EU jurisdiction.6
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European Shipowners Demand Binding Cost Pass-Through in EU ETS

8 Nov 2021
Topic — Proposal to include maritime transport in the EU Emissions Trading System.
Message — European shipowners request legally binding requirement for shipping companies to pass EU ETS costs to commercial operators. They also demand dedicated maritime climate fund using ETS revenues to support R&D and bridge price gap between clean and conventional fuels.123
Why — This would ensure shipping companies avoid bearing compliance costs and litigation risks while gaining price certainty and innovation funding.45
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Meeting with Cyrus Engerer (Member of the European Parliament)

15 Oct 2021 · Emissions Trading System

Response to Animal welfare labelling for food

24 Aug 2021

The European Community Shipowners’ Associations (ECSA), which represents the interests of the EU’s shipping industry, welcomes the publication of the Inception Impact Assessment (IIA) on the revision of the EU legislation on animal welfare. ECSA's comments on the Inception Impact Assessment can be found attached.
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Response to Ship recycling – updated list of approved breaking yards (8th edition)

8 Jun 2021

Please find attached the response of ECSA to the consultation on the updated list of approved breaking yards (8th edition) - draft implementing decision amending Implementing Decision (EU) 2016/2323.
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Meeting with Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

4 Jun 2021 · Presentation and discussion of ECSA’s position in relation to the FuelEU Maritime initiative.

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

Brief summary of ECSA’s response ECSA welcomes the opportunity to comment on the draft delegated regulation related to the reporting requirements under Article 8 of the Taxonomy regulation and would like to draw the attention to the main questions and concerns that shipping companies have in this context. ECSA believes that disclosure and reporting can contribute to its goal of transitioning the European shipping industry towards a sustainable future only if it is usable in business practice. This requires flexibility in adapting to the complexity of the Taxonomy and the review of the relevance, methodology and reporting templates related to the KPIs. ECSA calls upon the Commission to ensure that the corporate reporting requirements are proportionate and fit for purpose. ECSA calls on regulators to consider the consequences of the lack of time available for adapting to the new rules. ECSA warns that the disclosure of business sensitive information on sustainability may lead to a competitive disadvantage of European companies in international markets. Further details can be found in the attached ECSA Response ***
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Meeting with Helena Hinto (Cabinet of Commissioner Kadri Simson), Laure Chapuis (Cabinet of Commissioner Kadri Simson)

13 Apr 2021 · European shipowners' position on FuelEU Maritime and RED.

Meeting with Adina-Ioana Vălean (Commissioner) and

10 Mar 2021 · Meeting with ECSA board to discuss the latest maritime developments.

Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

9 Mar 2021 · Taxonomy draft delegated act

Meeting with Rachel Smit (Cabinet of Commissioner Adina Vălean)

5 Mar 2021 · Meeting to prepare the future meeting between our Commissioner and ECSA Board.

Response to Improving environmental protection through criminal law

18 Dec 2020

Please find enclosed the reply of the European Community Shipowners’ Associations to the Inception Impact Assessment.
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Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

ECSA response to the EC Feedback consultation on Sustainable Finance – EU Classification System for Green Investments – Draft Delegated Regulation The following points are raised in four attached files: 1. ECSA EU Maritime Taxonomy - Input to the consultation 2. ECSA EU Maritime Taxonomy - Annex 1Guiding Principles 3. ECSA EU Maritime Taxonomy - Annex 2 Definitions of maritime economic activities 4. ECSA EU Maritime Taxonomy - Annex 3 Proposed amendments Amongst others, ECSA welcomes the possibility to comment on the draft Taxonomy Delegated Act. ECSA welcomes the inclusion of the maritime economic activities in the Taxonomy exercise. ECSA calls upon the European regulators to recognise that the taxonomy in its current format is not yet fit for purposes other than those defined by the Taxonomy Regulation. ECSA finds it essential that the diversity of the shipping industry is taken into account by the taxonomy. In order to encourage the entire European shipping industry towards the green future, the taxonomy has to provide incentives whilst at the same time remaining realistic. In this light, ECSA would like to propose changes to the technical screening criteria and to the do no significant harm (DNSH) criteria. ECSA believes that a technology- and future fuel neutral taxonomy is essential to reach the green goals. ECSA is of the strong view that cargo-carried should not be in the scope of EU shipping economic activity when defining the EU maritime taxonomy.
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European shipowners warn EU ETS threatens global shipping trade

26 Nov 2020
Topic — The European Commission is reviewing emissions trading rules to include the maritime sector.
Message — The organization advocates for a global regulatory framework via the International Maritime Organization instead of a regional EU system. They request a pragmatic approach that accounts for the diversity of shipping segments and avoids administrative burdens.123
Why — Maintaining an international framework would protect their competitive position and avoid regional administrative costs.45
Impact — The climate and road infrastructure suffer if high sea-transport costs drive cargo to trucks.6
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Response to Port State control - Further improving safety, security and sustainability of maritime transport

20 Nov 2020

Please find attached the response of ECSA to the consultation on the Inception Impact Assessment on Port State Control.
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Response to Compliance with Flag State requirements (shipping)

19 Nov 2020

ECSA welcomes the launch of the Inception Impact Assessment (IIA) on the Directive 2009/21/EC on Flag State Control (FSC). The IIA follows up on an ex-post evaluation of Directive 2009/21/EC in 2018 as a part of the Maritime Fitness Check of the Commission. The outcome of the evaluation confirmed that the FSC Directive is relevant, effective and efficient and brings added value at EU level, playing a key role in enforcing International Maritime Organisation (IMO) and EU standards, thereby contributing to a high level of safety, security and sustainability of maritime transport as well as ensuring a level-playing field between Member States. In the attached document ECSA would like to mention some general remarks on the indicative roadmap before giving some more detailed comments on specific points raised by the European COmmission.
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Response to Maritime Accident Investigation

19 Nov 2020

Please find ECSA’s answer to the inception impact assessment on maritime accident investigation in annex.
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Meeting with Roxana Lesovici (Cabinet of Commissioner Adina Vălean)

19 Nov 2020 · Upcoming revision of the EU ETS and the possible inclusion of the shipping sector in it

Response to Updating the European List of ship recycling facilities - 7th version

31 Aug 2020

Please find enclosed ECSA’s contribution to the consultation on the draft implementing decision amending Implementing Decision (EU) 2016/2323.
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Response to Offshore renewable energy strategy

30 Jul 2020

Please find enclosed feedback to this roadmap on behalf of the European Community Shipowners' Associations (ECSA)
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Response to Sustainable and Smart Mobility Strategy

28 Jul 2020

Please find enclosed feedback to this roadmap on behalf of the European Community Shipowners' Associations (ECSA)
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Response to A EU hydrogen strategy

5 Jun 2020

Please find enclosed feedback to this roadmap on behalf of the European Community Shipowners' Associations' (ECSA).
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European shipowners urge tax exemptions for green maritime fuels

23 Apr 2020
Topic — This EU initiative aims to increase sustainable fuel use in maritime transport.
Message — ECSA supports the initiative but insists on a goal-based approach to foster innovation. They advocate for tax exemptions on all energy carriers to bridge the cost gap. Additionally, they call for minimal administrative burdens to protect smaller shipping companies.123
Why — Tax exemptions and R&D support would lower operational costs and help maintain global competitiveness.4
Impact — Consumers and shippers could face higher costs if green investments lead to increased freight rates.5
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Response to Climate change mitigation and adaptation taxonomy

20 Apr 2020

ECSA welcomes the opportunity to submit comments on the European Commission’s and its Technical Experts Group’s (TEG) work on sustainable finance taxonomy. ECSA is of the view that any taxonomy that facilitates the transition to a greener and more sustainable economy should be implementable on a daily basis and based on knowledge, experience and expertise of the sector. ECSA believes that the taxonomy for sustainable finance in the maritime sector should take into account the continuous efforts to reduce emissions, as per the Strategy agreed at the United Nations International Maritime Organisation (IMO). The European shipping industry stands behind the European Commission's Green Deal ambitions. Being a capital intensive industry, to reach these ambitions it is also necessary to ensure that companies can fully recover after the current COVID-19 crisis.
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Response to Revision of the Energy Tax Directive

1 Apr 2020

Introductory Remarks ECSA together with CLIA, Interferry and EuDA (the industry) wish to submit this joint paper reiterating the shipping industry’s position with regards to the directive. We believe that the Energy Taxation Directive (ETD) can be instrumental to support the industry's use of new low- or zero carbon fuels, thereby supporting the decarbonisation of shipping. We appreciate the commitment of the EU to lead the way in the fight against global warming. Shipping is committed to becoming climate neutral as soon as possible in this century. At the same time, the industry believes that lifting the tax exemption will not achieve the intended climate objectives being claimed, as it will not stop most of the industry from receiving tax free bunker fuel outside EU waters. It will also negatively affect EU jobs and business – intra EU shipping, bunkering companies and EU ports. Shipping is a global industry in need of global regulation in order to ensure a global level playing field and avoidance of distortion of competition. The industry believes net zero emissions is achievable, provided that active steps are taken by the legislators to provide an enabling framework to help facilitate the development of new propulsion technologies and fuels, including the required massive investment in bunkering infrastructure on a worldwide basis. In view of the above, the revision of the Energy Taxation Directive should be seen as a means of enabling this transition. Main conclusions The shipping industry considers that a revised Directive should take a technology neutral approach. Currently, it is not providing for the equal treatment of energy supplies to the shipping industry. In view of the global nature of the industry and the importance of the move to greener shipping, a revised Directive should provide for a taxation exemption for all energy carriers (i.e. fuels and electricity) in order to close the cost gap between traditional marine fuels and alternative fuels and electricity. The gap existing under the current Directive hampers investments in and the uptake of cleaner technologies and fuels, such as shore side electricity, fuel cells, ammonia, methanol, etc. Please refer to the attachment for the arguments in more detail why taxing bunker fuels in EU ports is not an effective way forward.
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Meeting with Adina-Ioana Vălean (Commissioner) and

20 Feb 2020 · General discussion on maritime transport in margins of the European Shipping Week

Meeting with Diederik Samsom (Cabinet of Executive Vice-President Frans Timmermans)

20 Feb 2020 · Speech on the European Green deal at the European Shipping Week

Response to Climate Law

5 Feb 2020

The European Community Shipowners' Associations (ECSA) is pleased to give feedback on the European Climate Law. In the attachment ECSA is making some general remarks about the most effective and efficient way to phase out shipping emissions as quickly as possible in this centure. It also proposes concrete actions at EU level that support the shipping industry becoming climate neutral.
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Meeting with Roxana Lesovici (Cabinet of Commissioner Adina Vălean)

22 Jan 2020 · Maritime related issues

Meeting with Anthony Agotha (Cabinet of First Vice-President Frans Timmermans) and Danish Shipping

22 Nov 2019 · Sustainability, climate and maritime issues

Response to Evaluation of rights of passengers when travelling by sea and inland waterway

6 Sept 2019

The European Community Shipowners' Associations (ECSA) welcomes this evaluation which, as part of the better regulation agenda, is intent to ensure the regulation is fit for purpose and is being properly implemented. ECSA considers the Regulation fit for purpose. The ferry and cruise sectors are known for their high standards of customer service. ECSA and its members look forward to actively contributing to the exercise and wish to be closely involved in any discussions about any 'alternative proposals'.
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Response to Revision of the Shipping MRV Regulation

29 Mar 2019

The European Community Shipowners’ Associations (ECSA) and the International Chamber of Shipping (ICS) welcome the revision of Regulation (EU) 2015/757, thereafter the MRV Regulation, attempting to align the EU MRV with the global IMO Data Collection System (IMO DCS). ECSA nonetheless regrets that the European Commission did not opt for a full alignment with the IMO DCS. OUr full poistion can be foudn n the attached document.
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Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)

20 Mar 2019 · Clean Transport and Climate Policy

Response to More efficient law-making in social policy: identification of areas for an enhanced move to qualified majority voting

24 Jan 2019

ECSA, the recognized EU sectoral social partner, representing employers of the maritime transport sector strongly opposes the European Commission’s proposal to introduce more qualified majority voting in social policy. The areas under unanimity voting rules are core pillars of national socio-economic systems and are related to how Member States define the different rights and responsibilities of citizens in their respective countries. European social policy should maintain supportive and complementary role to national policies, respect diversity of national social systems and social partners’ role and not interfere of matters of national competence . The European Commission needs to take initiatives in a targeted and balanced way on topics where there is a clear role and added value for the EU to act, building on the existing process of the EU integration and focusing on delivering mutually beneficial outcomes for companies, workers and citizens. This is how Europe will move forward in unity. ECSA therefore endorses the position outlined by Business Europe that can be found attached.
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Meeting with Joost Korte (Director-General Employment, Social Affairs and Inclusion)

22 Oct 2018 · Introductory meeting with Secretary General Martin Dorsman to discuss Social Dialogue in the Maritime Transport sector, the state of play of transposition of Directives 2015/1794 and 2018/131, seafarers and Transparent and Predictable Working Conditions, the European Labour Authority, and 883

Response to Reporting formalities for ships (European Maritime Single Window environment)

31 Jul 2018

European shipowners see the benefits of the Commission’s proposal to change the current Directive on the Reporting Formalities Directive, on which the Maritime Single Windows are based into a Regulation. However, the proposal can be improved to avoid costs and further increase benefits in terms of reducing administrative burdens and improving the environmental performance of shipowners and other companies in the whole logistical chain. The current situation needs urgent improvement. ECSA proposes four suggestions to further improve the proposal: 1. Make sure the harmonised EU dataset works as intended as the single dataset for reporting. 2. Make sure the harmonised interface works optimally, giving access to all EU ports. 3. Make sure future improvements of the interface are technologically neutral and users are involved at the right moments. 4. Introduce EU developed and centrally operated shared trader interface that coexists alongside existing interfaces and enables reporting to all EU MS via the same channel. Member States could opt into this interface in a comparable way to the opt in possibility under the customs’ Import Control System ICS 2. Watering down the proposal is not acceptable.
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Meeting with Andras Inotai (Cabinet of Vice-President Karmenu Vella) and International Chamber of Shipping

27 Jun 2018 · Ocean Governance, UNCLOS BBNJ

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

26 Jun 2018 · International ocean governance/BBNJ

Response to Evaluation of the Directive on safety of offshore oil and gas operations

25 May 2018

ECSA welcomes the roadmap and looks forward to answering to the public consultation. Please find enclosed the joint contribution of ECSA, IADC and IMCA to the evaluation of the Offshore Safety Directive (OSD).
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Meeting with Violeta Bulc (Commissioner) and

7 Mar 2018 · Meeting with ECSA (maritime stakeholder)

Meeting with Henrik Hololei (Director-General Mobility and Transport)

14 Nov 2017 · Maritime transport challenges

Response to Reporting formalities for ships (European Maritime Single Window environment)

25 Aug 2017

ECSA welcomes the Inception Impact Assessment. It identifies and analyses correctly the problems shipping companies are facing with regard to reporting obligations within the EU. ECSA shares the analysis that the objectives of the Reporting Formalities Directive (RFD) of harmonisation, simplification and rationalisation were not reached. To the contrary, the administrative burden on the shipping sector increased due to the Directive. ECSA stresses the urgency to correct this through a thorough revision of the RFD.
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Response to Revision of the Shipping MRV Regulation

7 Jul 2017

Please find enclosed the ECSA response.
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Response to Electronic documents for freight transport

15 Jun 2017

The World Shipping Council (WSC) and the European Community Shipowners Associations (ECSA) welcome the opportunity to respond to this European Commission (EC) Inception Impact Assessment amplifying views expressed on this subject via their membership of the Digital Transport and Logistics Forum (DTLF). The current consultation comes at a time of extensive and very rapid technological change. From block chain to data pipelines and cloud solutions, innovation is being driven by private industry, aimed at harnessing the potential of digitalised transport data. WSC and ECSA welcome the EC’s interest in examining how European logistics can be made more efficient through the better and more effective use of electronic data. However, it is critical that the Commission acts judiciously and exclusively in areas where it can effect positive change. WSC and ECSA strongly urge the Commission to focus on improving the flow of statutorily required business to government data. This is where the EC is best placed to act effectively and where its involvement is most needed. By contrast it should avoid trespassing into the domain of business to business communications, above all through legislative actions. WSC and ECSA welcome efforts to examine how sharing of data across transport modes may improve the efficiency of logistics. However, only individual commercial entities will be able to define adequately what is required. The EC is strongly urged to recognise the complex operational and legal realities that distinguish each transport mode and to avoid pursuing ‘one size fits all’ multimodal solutions, which ignore those facts. Discussions within the DTLF have most urgently centred on regulatory deficiencies and the submission of business to government information. There is a great deal of necessary work to be done that can improve the competitiveness and efficiency of the European logistics industry. This is where the EC can most effectively direct its efforts. It should not expend efforts trying to duplicate activities that the market is already pursuing of its own volition. Commercial data and their digitalisation are matters for the private sector to address. In response to the consultation paper WSC and ECSA has provided a detailed paper forwarded to the Commission alongside these remarks.
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Meeting with Miguel Arias Cañete (Commissioner)

24 Feb 2017 · ETS Revision – maritime transport

Meeting with Gints Freimanis (Cabinet of Vice-President Valdis Dombrovskis), Jan Ceyssens (Cabinet of Vice-President Valdis Dombrovskis)

24 Jan 2017 · Discussion on new banking legislation in Basel group; main concern of ECSA is about the negative impact of proposals in Basel group that may affect shipping industry

Meeting with Joao Aguiar Machado (Director-General Maritime Affairs and Fisheries)

22 Nov 2016 · Reefer vessels / sharks

Meeting with Henrik Hololei (Director-General Mobility and Transport)

21 Oct 2016 · IMO

Meeting with Joao Aguiar Machado (Director-General Maritime Affairs and Fisheries) and WWF European Policy Programme and

18 Oct 2016 · Shipping of Shark Products

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc), Matej Zakonjsek (Cabinet of Commissioner Violeta Bulc)

5 Oct 2016 · Exchange of views with Niels Smedegaard, President and ECSA board members on state of play of EU maritime policy

Meeting with Daniel Calleja Crespo (Director-General Environment)

12 Sept 2016 · Ship recycling

Response to Shipping Emissions Verification and Accreditation

25 Aug 2016

Article 10 §2: It should be clarified that the company shall provide supporting documents only for the representative sample of voyages carried out by the ship in question as determined by the verifier. This is related to the data sampling plan as part of the verification plan under Article 12 (drafted and implemented by the verifier), setting out the scope and methods of data sampling relating to the data points (underlying the aggregated CO2 emissions) and other information in the emissions report of the ship in question. Moreover, proper guidance should be provided in the Regulation (delegated act) for ships that will have to monitor fuel consumption on an annual basis as the high number of voyages will make this task unnecessarily burdensome and a time-consuming exercise for both crews aboard ships and personnel ashore. Article 10 §3(d): Providing evidence of fuel tank meter readings, if asked by the verifier would be burdensome and onerous. It is questionable whether such a requirement is really necessary to be included in the draft legal act. Article 10 §4: This is ambiguous with regards to responsibility. The new owner should not be responsible for collecting data from the previous owner and then be responsible for the whole reporting period. The distinction of responsibility between successive owners (and by this possibly between different verifiers) should be more expressively indicated and activated on the day of change of ownership. In case of change of owner the new owners should report separately. Article 13 §1 and §2: The implementation of a company's internal procedures is subject to the Audit requirements according to IMO (ISM Code). Therefore, the introduction of this requirement will result in double auditing procedures at additional cost to the industry, a fact that contradicts with the principle of “avoidance of any unnecessary duplication of (verification) procedures’’ as stipulated in the Recital (4) of the draft delegated act. Article 14: Purchasing ship-tracking data from private companies is expensive and burdensome. Therefore, unless the external data sources are provided free of charge by the European Commission, it should not be included in the delegated act. Otherwise, shipping companies will be burdened with increased verification costs. Additional comments: Article 16: Article 16 should be considered in connection with (similar) requirements imposed to the verifier (under Article 6) when carrying out site visits. A site visit at the office (where the critical mass of data is kept) should be preferably carried out provided that the outcome of the risk assessment proves necessary in case the information that the verifier needs to perform cannot be remotely obtained and assessed with the required reasonable assurance as specified in the Delegated act (Reference: ESSF Shipping MRV A&V subgroup final report to ESSF Plenary on 28/6/2016, Annex 2, p.24). Articles 23 and 30 §6: Notwithstanding the comment made above on the independent verifier it would be relevant to mention opine that at least one person in the verifiers team must be employed by the verifier directly – given that it is the verifier that holds the accreditation. Article 30 §3(a): it is suggested that dialogue between company and verifier in the course of development of the plan renders the verifier no longer impartial. This does not tally normal commercial practice where feed-back from verifiers in the form of management memos with corrective action plans is standard practice. Reading this article, it remains unclear whereas the Classification Society of the ship can perform the verification, provided that it fulfil the requirements and gets the accreditation. Classification Society’s role is to give an external and independent point of view on technical, operational, and management subjects. To perform the verification would be logical.
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Response to Shipping Emissions Templates

25 Aug 2016

General concern: Whilst it is appreciated that the monitoring requirements under Regulation 2015/757 and accompanying legal acts will be facilitated by the establishment Thetis-MRV, the shipping industry still feels concerned that such a large documentation is required, it illustrates the complexity and administrative task MRV reporting will be for the industry. The amount of data/information requested in the Monitoring Plan creates administrative burden and unnecessary duplications of work, e.g.: (i) name and location of systems where data is stored (If at a later stage a company buy a new server or move the data to another server, then all monitoring plans needs to be updated to reflect this), (ii) ‘Version of existing procedure’ and ‘Reference to existing procedure’ are requested 20 times (This is an irrelevant piece of information, because it will of course always be reference to the latest version of a given procedure. If this remains in the template there will be 20 inherent compliance traps in each vessel plan as every vessel will need to update the plan every time a procedure is revised). A far more simple monitoring plan that does not need to be continuously amended could be achieved by including references to procedures in the Safety Management System (under ISM Code) would avoid re-approval of Monitoring Plans. General comment: it seems that the template for Monitoring Plans as set out in Annex I (of the draft implementing act) cannot fulfill its purpose as it constitutes an administrative burden and creates unnecessary duplication of work for a sizeable shipping company. Overall it does not present a workable solution for the shipping industry as regard the large amount of data to be repeatedly entered and, therefore, it needs to be brought in line with the examples of interactive templates elaborated and displayed by EMSA during the 4th meeting of the ESSF MRV Sub-group (11-12/4/2016) under the future Thetis-MRV. Article 2: There is a reference to a table B.6 which does not exist. In addition, it is unclear if the company-specific part may include any of the tables of the templates, provided that it makes sense, or just some of the tables suggested with this last paragraph. Furthermore, from 1. And 2. Under this article it appears illogical that a certain template must be applied and at the same time flexibility is supported. It is therefore suggested to replace ‘using the template’ by ‘covering all required items as laid out in the template’. Annex I, Part B, Table B.3: The request for Specific Fuel Oil Consumption (SFOC) should be deleted as SFOC is a factory setting based on burning diesel and the value is of no use without the corresponding power out, which is not asked for. Annex I, Table C.2.9, fifth line – ‘Split of fuel consumption into freight and passenger part (if area method is used only)’: clarification should be provided as whether a yes/no answer (yes - car decks areas between freight and passengers are split, no -they are 100% allocated to freight) or whether a percentage differentiation is required. In case of the latter, it is not possible to indicate a value in the monitoring plan since this value can vary one year from another depending on the operational values. Annex I, Part C, Table C.2.2: 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 C and D to monitor their fuel consumption. General remark: It is not clear whether the monitoring plan must be available in printed copy, or not. Requirements for hard copies is undesirable.
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Response to Shipping Emissions Monitoring Methods

25 Aug 2016

Recitals (3) and (4): There is an ambiguity between existing and amended Regulation 2015/757 through the delegated act as there are only mentioned three monitoring methods in amended text, recitals (3) and (4) (monitoring methods A, B and C). Method D should be referred to as the fuel consumption calculation also imply the use of emission factors. Recital (4) and Amendment to Annex I(b), (i)(b) & (iii)(b): ‘Fuel uplift’ should be replaced by ‘Bunker’ as term in use in the Maritime industry. Recital (5) + Annex II Paragraph 1 of Part A(i) and A(ii)(b): As stipulated in the final report on the work of the MRV sub-group on Shipping MRV Monitoring (Annex 5, p. 26) - as accepted by the ESSF Plenary on 28/6/2016 - The issue of (i) determining distance travelled (e.g. measurement through the water or over ground, consideration of drifting, movements for tank cleaning) and (ii) determination of time spent at sea should be subject to further guidance. It is recommended to calculate the distance travelled over ground and the time spent at sea to include waiting and drifting time whether at anchor or not. General comment: As defined under Article 3(n) of Regulation 2015/757, ‘ship at berth’ means ‘a ship which is securely moored or anchored IN A PORT FALLING UNDER THE JURISDICTION OF A MEMBER STATE while it is loading, unloading or hotelling, including the time spent when not engaged in cargo operations’. Since ‘berth’ is associated to an EU Member State’s jurisdiction, ‘port of departure’ or ‘port of arrival’ should be exclusively referred to for port located outside any MS’s jurisdiction for the purpose of monitoring distance travel and time spent at sea. Amendment to Annex I A.: For the sake of clarity, it is suggested to make a reference to Resolution MEPC 245(66)2014 as already indicated in the Explanatory Memorandum of the proposed delegated act on the monitoring methods. The following reference (text in capital letters) is suggested: ‘The following default values for emission factors for fuels used on board shall be applied, AS SET AT INTERNATIONAL LEVEL IN THE IMO IN RESOLUTION MEPC 245 (66) 2014: GUIDELINES ON THE METHOD OF CALCULATION OF THE ATTAINED ENERGY EFFICIENCY DESIGN INDEX (EEDI) FOR NEW SHIPS:’. Amendment to Annex II: The reference should be to UTC and not GMT. Additional comment: As per Article 9 §2 of of Regulation 2015/757, vessels that perform more than 300 voyages during the reporting period are exempted from the obligation to monitor the information on a per-voyage basis. However, according to Article 10(f) a company must monitor a ship’s CO2 emissions which occurred within ports under a Member State's jurisdiction at berth. Effectively, the requirement in Article 10(f) contradicts the provisions of the per-voyage exemption. This inconsistency should be addressed through the delegated act, in order to avoid creating confusions and uncertainly to short sea shipping.
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Response to Shipping Emissions Cargo Carried

25 Aug 2016

Recital (4): Delete the reference to “transport efficiency” in the category of general cargo ships and replace it with “efficiency metrics for this ship category”. This proposed wording is consistent with the final report on the work of the MRV sub-group on Shipping MRV Monitoring (Annex 1, Table, p. 9) - as accepted by the ESSF Plenary on 28/6/2016 - related to the additional data / information to be reported (on a voluntary basis) in order to facilitate understanding of the efficiency metrics for the ships falling in the category of “oil tankers”. For the same reason, this should be applicable to ships falling in the category of “general cargo ships”. The term “transport efficiency” does not constitute a legal requirement under MRV Regulation for the purposes of monitoring of other relevant information on a per voyage basis pursuant to Article 9(1) of the Regulation. On the contrary, information on “transport work” on a per voyage basis is required. Recital (7): Consistently with the final report on the work of the MRV sub-group on Shipping MRV Monitoring (Annex 1, Table, p. 10) - as accepted by the ESSF Plenary on 28/6/2016 - for ships falling in this category (“other ship types”), the following text in capital letters should be added: ‘For other ship types not falling under any of the above categories OR UNDER THE SHIP TYPE DEFINITIONS OF THE REGULATION (EU) 2015/757, a flexible approach […]’. Article 2(12): Consistently with the final report on the work of the MRV sub-group on Shipping MRV Monitoring - as accepted by the ESSF Plenary on 28/6/2016 - the ESSF Monitoring subgroup recommended that ‘Deadweight carried’ should be defined as displacement deducted by the ship's lightweight and the weight of the fuel stored on board. It should however be noted that current definition of ‘Deadweight carried’ in IMO does include fuel (IMO MEPC 69/6 - Cargo weight/volume (44)). Article 3(j): Consistently with the final report on the work of the MRV sub-group on Shipping MRV Monitoring (Annex 1, Table, p. 10) - as accepted by the ESSF Plenary on 28/6/2016 - for ships falling under ‘Ro-Pax), the following text (in capital letters) should be added at the end of Article 3: ‘FOR THE PURPOSES OF POINT (J) OF THE FIRST PARAGRAPH, THE FUEL CONSUMPTION SHOULD BE SPLIT INTO FUEL USED TO TRANSPORT PASSENGERS AND FUEL USED TO TRANSPORT CARGO USING CEN 16258. FURTHER GUIDANCE ON THE USE OF THIS STANDARD MAY BE DEVELOPED.’
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Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

27 May 2016 · ECSA annual general meeting Malta

Meeting with Henrik Hololei (Director-General Mobility and Transport)

23 May 2016 · EU maritime transport strategy, European Maritime Single Window

Meeting with Joao Aguiar Machado (Director-General Maritime Affairs and Fisheries)

7 Mar 2016 · Shipping companies' transport of shark species

Meeting with Christian Burgsmueller (Cabinet of Vice-President Cecilia Malmström), Maria Asenius (Cabinet of Vice-President Cecilia Malmström)

16 Jul 2015 · TTIP

Meeting with Margrethe Vestager (Commissioner)

8 Jul 2015 · To discuss EU State aid policy in relation to maritime transportation

Meeting with Soren Schonberg (Cabinet of Commissioner Margrethe Vestager)

2 Jun 2015 · To discuss EU State aid policy in relation to maritime transportation

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

6 May 2015 · Ship Recycling

Meeting with Violeta Bulc (Commissioner)

4 Mar 2015 · Closing Remarks: ECSA

Meeting with Friedrich-Nikolaus von Peter (Cabinet of Commissioner Violeta Bulc)

12 Dec 2014 · Priorities Comissioner Bulc and meeting new cab member

Meeting with Desiree Oen (Cabinet of Commissioner Violeta Bulc)

12 Dec 2014 · Priorities Commissioner Bulc and meeting new cab member