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VERIFAVIA SARL

VERIFAVIA

Verifavia is a worldwide independent environmental verification, certification and auditing body for aviation (airlines and business jets), airports and maritime transport (shipping and ports).

Lobbying Activity

Response to Count your transport emissions: CountEmissions EU

17 Dec 2021

Verifavia values the opportunity to comment on Count Emissions EU Impact Assessment consultation. Verifavia Shipping strives to be the maritime industry’s first choice for the provision of emissions verification and hazardous materials preparation and maintenance services. Verifavia Shipping was the first company to provide EU Monitoring Reporting and Verification (MRV) services and the first independent verifier to provide International Maritime Organisation’s (IMO) Data Collection System (DCS) verification for a number of flag states. By combining its innovative approach and streamlined procedures with the technical expertise and industry knowledge, Verifavia Shipping provides a smooth, flexible and competitive service, enabling customers to navigate compliance effectively and efficiently. Verifavia is keen to highlight that an EU Directive (Directive 2009/16/EC) is restricting many of the services that Verifavia can provide because Verifavia is not a Classification Society or ‘Recognized Organization’. In practice, Verifavia has even stricter implementation of the impartiality and independence requirements compared to Class Societies, and has full technical knowledge of marine fuel and emissions. However this Directive says that only a ‘Recognized Organization’ can issue some certificates and therefore our organization does not qualify. Verifavia SARL is accredited by COFRAC as a Global EU MRV Verifier (and soon by UKAS for UK MRV). Verifavia is also the First Independent Verifier to Provide IMO DCS Verification and CSI Verification. As an ISO 14065 accredited verification body, Verifavia can also conduct carbon emissions verification according to the ISO 14064-3 standard and the GHG Protocol. The accreditation we hold recognises our expertise in providing verification services to the maritime industry. Furthermore, it states that the data we verify is standardized and reliable. Reliance on accredited organisations is pivotal to the vast majority of existing verification schemes to confirm they are credible and trustworthy. Through comprehensive audits of procedures, processes, and competencies undertaken by EU-approved accreditation bodies, accredited verifiers from independent organisations have been identified, tested and authorised so there must now be a level playing field for all these accredited verifiers moving forward. Verifavia has invested a considerable amount of time, effort and money to achieve accreditation, to acquire resources and technical expertise, to support the EU MRV Regulation and to gain credibility, visibility and acceptance in the international shipping markets. In particular, the team has been actively involved in the working groups on EU MRV under the umbrella of the European Sustainable Shipping Forum (ESSF), responsible for providing the European Commission with technical expertise for the drafting of the Delegated Regulations pursuant to the EU MRV (in 2015-2016), and for drafting the guidance documents addressed to shipping companies, verifiers and NABs (in 2016-2017). Verifavia believes that the authorization of independent verifiers is instrumental to the creation of a healthy and fair competitive market where the maritime sector benefits from the existence of multiple players and lower verification costs. Any artificial restriction of the market will place unjustifiable and additional burdens on the industry, which would work against the industry’s overall interest. Moreover, a higher number of verification bodies would help ensure timely and thorough execution of verification work and prevent possible shortfalls in qualified verifiers. Forthcoming regulation should address this inconsistency and make it possible for truly independent verifiers to act on all certificates / services related to verification of fuel / emissions / energy efficiency for the shipping sectors. We trust the European Commission will take into account. Don't hestitate to contact us if needed.
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