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Royal Belgian Shipowners' Association

KBRV

Mission: The RBSA proactively looks after the common interests of all shipowners and ships’ managers established in Belgium and involved in international maritime transport by sea.

Lobbying Activity

Meeting with Kurt Vandenberghe (Director-General Climate Action)

3 Dec 2025 · General discussion on the challenges Belgian Shipowners face on their path to decarbonization

Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

8 Jul 2025

The Royal Belgian Shipowners Association (KBRV) proactively looks after the common interests of all shipowners and ships managers established in Belgium and involved in international maritime transport by sea. KBRV welcomes the opportunity to provide input to the European Commission (EC) on the review of the EU ETS with this call for evidence.Please find attached our replies.
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Response to Monitoring and reporting of greenhouse gas emissions from offshore ships and zero-rating of sustainable fuels

4 Sept 2024

Please find attached feedback from the Royal Belgian Shipwoners' Association. In short, we would like to express our gratitude for the opportunity to respond to the consultation and would like to underscore that KBRV fully supports the Fit for 55 package. However, we are seriously concerned about the inclusion of the offshore sector in the MRV and ETS legislation as it has become evident that the current legislative framework is not fit for purpose when applied to this industry. In this sense, the draft delegated regulation to list offshore ships that will be included in EU MRV and EU ETS exhibits critical deficiencies. These include insufficient coverage and ambiguity. The existing list of regulated ship types, based on the STATCODE5 classification, fails to comprehensively cover the diverse range of vessels in the offshore sector, leaving significant gaps in regulation. Additionally, the ambiguous definitions and lack of future-proofing risk reclassification of ships to avoid regulation, thereby undermining the efficacy of the legislation. This situation also distorts the competitive landscape, disadvantaging European offshore companies that are leading in decarbonization efforts. To address these issues, KBRV proposes the following solutions: 1. Short-Term Solutions: Broader Negative List with Clear Exemptions ( Inclusion of vessels involved in exploration, dredging, renewables, construction and exclusion of harbour assistance tugs) 2. Long-Term Solutions: Activity-Based Definitions 3. Fit-for purpose legislation for the offshore industry with workable definitions of terms such as "voyages," "ports of call," and "crew" We strongly recommend that the Commission engages in further dialogue with industry stakeholders to refine the legislation and explore practical solutions that account for these sector-specific challenges.
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