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World Shipping Council

WSC

The World Shipping Council represents the liner shipping industry in policy discussions regarding maritime trade.

Lobbying Activity

Meeting with Daniel Boeshertz (Head of Unit Competition)

9 Dec 2025 · Exchange of views on EU maritime and ports security

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

30 Oct 2025 · Upcoming Commission maritime initiatives and outcome of the IMO MEPC ES

Meeting with Matthias Petschke (Director Taxation and Customs Union)

2 Oct 2025 · Exchange of views on current issues and potential solutions in relation to data protection rules for the shipping industry in the context of the Port Alliance

Shipping industry urges EU to close renewable fuel price gap

4 Sept 2025
Topic — The initiative creates strategic roadmaps for energy transitions in aviation and waterborne transport.
Message — The Council requests financial tools like reimbursements to bridge the price gap between renewable and conventional fuels. They also call for investments in port infrastructure and more flexible certification processes to speed up fuel adoption.12
Why — Bridging the price gap would protect the industry's competitiveness while it invests in green technology.3
Impact — Port authorities and Member States would lose revenue from hidden fees through mandatory transparent electricity pricing.4
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World Shipping Council demands secure, competitive and green EU ports

27 Jul 2025
Topic — The consultation defines priorities for security, competitiveness, and energy transition in ports.
Message — The council requests enhanced public-private partnerships to share intelligence and combat crime. They urge swift implementation of digital reporting and more green fuel infrastructure. They also propose removing customs barriers for shipping within the Single Market.1234
Why — Standardized reporting and reduced customs barriers would cut multi-million euro compliance costs.5
Impact — Road transport providers lose business as shipping becomes a more competitive transport alternative.6
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World Shipping Council urges EU to align emissions trading with global IMO framework

7 Jul 2025
Topic — Review of EU Emissions Trading System for maritime transport and climate targets.
Message — The organization requests strategic alignment of EU ETS with the IMO Net Zero Framework to avoid double GHG pricing burdens. They want EU ETS amendments made following IMO adoption to prevent regulatory duplication and competitive distortions affecting European ports.123
Why — This would eliminate duplicate compliance costs from two overlapping GHG pricing systems.45
Impact — Developing countries face additional costs through exports, imports, and trans-shipment through Europe.6
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Meeting with Apostolos Tzitzikostas (Commissioner) and

1 Jul 2025 · Strategic Dialogue on the EU Port Strategy

Meeting with Matthias Petschke (Director Taxation and Customs Union) and

5 Jun 2025 · Exchange of views on possible improvements to the functioning of the Trade Contact Group

Meeting with Pietro Fiocchi (Member of the European Parliament)

26 Mar 2025 · tematiche di inquinamento ambientale

Meeting with César Luena (Member of the European Parliament, Rapporteur) and European Community Shipowners' Associations

25 Mar 2025 · Pellets Regulation

Meeting with César Luena (Member of the European Parliament, Rapporteur)

6 Mar 2025 · Pellets Regulation

Response to Establishing a list of “neighbouring container transhipment ports” for the FuelEU Maritime Regulation

3 Feb 2025

The World Shipping Council (WSC) is a non-profit trade association representing the liner shipping industry, which includes operators of containerships and roll-on/roll-off (ro-ro) vessels (including vehicle carriers). Liner shipping transports two-thirds of the EUs seaborne trade by value, equivalent to EUR 1.7 trillion of imports and exports. This represents over 100 million TEU (Twenty-foot Equivalent Units) of cargo annually. Annually more than 2,000 liner ships make more than 65,000 port calls to some 130 European ports. Liner fleets connect Europe to over 900 ports worldwide, reaching key markets for Europe. WSC appreciates the opportunity to respond to the public consultation FuelEU Maritime Implementing Regulation on Decarbonising the shipping sector the list of neighbouring container transhipment ports. Please see the attached response to this call for feedback.
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Meeting with Annika Kroon (Head of Unit Mobility and Transport)

9 Jan 2025 · The meeting focused on WSJ’s analysis on the decarbonisation transition of the shipping sector

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

2 Dec 2024

The World Shipping Council's (WSC) response to the European Commissions Public Consultation on Ship recycling European list of ship recycling facilities 14th edition, can be found attached.
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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)

Meeting with Peter Liese (Member of the European Parliament)

28 Nov 2024 · Austausch

Meeting with Tom Berendsen (Member of the European Parliament)

27 Nov 2024 · Shipping

Meeting with Lara Wolters (Member of the European Parliament)

26 Nov 2024 · Maritime policy, sustainability

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

18 Nov 2024 · Priorities for European Commission 2024-2029

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

24 Sept 2024 · General exchange on current maritime topics

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

10 Sept 2024 · Decarbonization of international shipping

Meeting with Kurt Vandenberghe (Director-General Climate Action)

10 Sept 2024 · Discuss priorities for the decarbonisation of international shipping, both within the upcoming Commission mandate and at the IMO in view of the revised green house gas strategy adopted there in 2023

Response to Ship recycling – European list of ship recycling facilities (13th edition)

3 May 2024

World Shipping Council member companies represent over 90% of global liner shipping industry container and vehicle carrier capacity. We are committed to working with the EU Institutions to advancing sustainable and responsible shipping practices worldwide and support EU leadership at the IMO for more ambitious actions and higher standards when it comes to ship recycling. We welcome the publication of the 13th European list of ship recycling facilities. However, we believe the current list does not sufficiently address the needs of the global liner fleet. The number and capacity of EU-approved recycling facilities are inadequate to meet the recycling requirements of the global fleet. Therefore, we urge the EU to continue evaluating ship recycling facilities located outside the EU, monitor their compliance progress, and consider including them in the EU list as soon as they meet EU standards. Expanding the number and geographic diversity of approved facilities will significantly help in maintaining ship recycling costs within a cost-effective range. Furthermore, the EU should implement uniform auditing standards for recycling facilities within and outside Europe. Establishing these standards will facilitate the comparison of progress between EU and non-EU facilities, fostering the development of a global standard for ship recycling auditing. This comparison is crucial for promoting transparency and uniformity in how recycling practices are evaluated worldwide. The automatic inclusion of EU facilities on the approved list without rigorous and transparent standardised auditing processes should be scrutinised. Like their global counterparts, EU facilities must undergo thorough evaluations to ensure compliance with the highest safety and environmental standards. By adopting a global rather than a protectionist approach, the EU can demonstrate leadership in sustainable ship recycling, encouraging all facilities, regardless of location, to meet stringent safety and sustainability standards. Access to recycling that is safe and environmentally sound is an important factor in fleet modernization and energy transition. In this way, the SRR can support the transition of international shipping towards becoming more climate friendly by using newer, more energy efficient ships, using advanced fuels that reduce GHGs to meet decarbonisation targets. Furthermore, a transparent and uniformly audit process applied to EU listed ship recycling facilities can help to inform review of the Hong Kong Convention. This would help the EU promote better alignment with best practices in international ship recycling standards.
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Meeting with Roxana Lesovici (Cabinet of Commissioner Adina Vălean)

2 May 2024 · WSC’s Policy Priorities for the European Commission’s new mandate

Meeting with João Albuquerque (Member of the European Parliament, Rapporteur)

8 Apr 2024 · Preventing plastic pellet losses to reduce microplastic pollution

Response to Revision of the Union Customs Code

7 Nov 2023

Please find attached the WSC submission.
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Meeting with Anna Cavazzini (Member of the European Parliament, Shadow rapporteur) and Bureau Européen des Unions de Consommateurs and

7 Nov 2023 · Reform of the Union Customs Code

World Shipping Council backs EU rules clarifying ETS compliance responsibility

27 Sept 2023
Topic — EU regulation on administering shipping companies under the Emissions Trading System.
Message — The organization supports the implementing regulation as drafted, stating it provides clarity for compliance and enforcement while allowing flexibility in assigning responsibility. They emphasize the rules align with existing regulations and make explicit the necessary steps for shipowners to delegate ETS obligations.12
Why — This reduces administrative uncertainty and allows companies flexibility in delegating compliance responsibilities.3
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Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean), Roxana Lesovici (Cabinet of Commissioner Adina Vălean)

20 Sept 2023 · World shipping summit

Response to Port State control - Further improving safety, security and sustainability of maritime transport

21 Aug 2023

The World Shipping Council (WSC) is a non-profit trade association that represents the liner shipping industry, which is comprised of operators of containerships and transoceanic vehicle carriers. Together, WSCs members operate approximately 90% of the worlds liner vessel services including more than 5,000 ocean-going vessels of which more than 2,000 vessels make more than 16,000 calls at EU ports each quarter (EuroStat and EU MRV data). The World Shipping Council (WSC) and its Member companies are pursuing ambitious global climate goals and supporting policy actions as part of our work to shape the future growth of a sustainable, safe, and secure shipping industry. WSC supports the Maritime Safety Package, and we focus our comments here on the PSC Directive. WSC recognises that Port State Control (PSC) is an important aspect of ensuring maritime safety. We also support the review and potential updating of the Ship Risk Profile (SRP) Calculator as currently implemented in The Hybrid European Targeting and Inspection System (THETIS) managed by EMSA. Our main requirement is that new parameters in a Ship Risk Profile (SRP) provide PSC Officers with improved tools for prioritizing inspections to reduce safety and environmental incidents, to protect seafarers and communities, and to improve environmental performance. The current proposal adds one parameter, the IMO CII score, that is neither predictive of environmental risk nor related to the EU Green Deal. The CII score is the wrong environmental parameter for the SRP for three reasons. First, the CII is not aligned with standards, goals, and legislation in the Fit-for-55 package. The IMO Carbon Intensity Indicator (CII) is by definition and design not a predictive metric of environmental risk or vessel safety risk. While Recital (11) of the PSC Directive suggests the Commissions interest in connecting the SRP to the Fit-for-55 package aims to reduce the EUs GHG emissions in maritime transport, CII is not linked to the EU Green Deal. FuelEU Maritime regulates the heart of the matter for the Fit-for-55 package. FuelEU directly measures GHG intensity and compliance elements within FuelEU could offer environmental parameters aligned with the Commission goals. Second, there is no evidence that a low CII score relates to increased risk of environmental pollution or an incident. The CII only provides a relative indicator of emission intensity compared with a moving fleetwide benchmark. Third, the CII is not accurately assigning an environmental risk score to a given ship; in many cases, the indicator reflects the route a given ship is serving and not the inherent emission profile of the ship. CII is highly impacted by at least two major variables that are usually unique to a given trade route, namely, port waiting times, and the prevailing weather conditions and sea state on a given route. These are among the reasons that IMO is pursuing a global fuel standard and conducting a review the efficacy of the CII design with completion date 1 January 2026 (per MEPC 80/WP.12, para 4.3). New risk parameters must improve PSC Officer inspections to ensure that the conversion to future fuels and technologies related to the EU Green Deal is safe and protective of the environment. We know that there will be changes in potential risk when shipping transitions to advanced fuels and technologies that can achieve lifecycle reductions in GHG intensity. For example, ammonia and hydrogen come with well recognized concerns about ship risk. EMSA has full competency to evaluate EU Green Deal risks important for PSC Officer inspections. The PSC Directive needs to use the right risk indicators; IMO CII is the wrong indicator for environmental risk. The Directive should directly meet its goal to connect the SRP with the Fit-for-55 package, rather than insert the CII which remains under criticism and review by European nations and the European Commission at IMO.
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Meeting with Liliane Karlinger (Cabinet of Executive Vice-President Margrethe Vestager)

11 Jul 2023 · CBER review

Meeting with Liliane Karlinger (Cabinet of Executive Vice-President Margrethe Vestager)

3 Jul 2023 · Review Consortia Block Exemption Regulation.

World Shipping Council urges realistic EU green shipping criteria

3 May 2023
Topic — The EU is updating technical rules for identifying sustainable investments in maritime transport.
Message — WSC requests that emission criteria use a lifecycle approach instead of zero-tailpipe metrics. They also urge the EU to align greenhouse gas intensity targets with FuelEU Maritime regulations. Additionally, they advocate for fleet-wide pooling mechanisms to make compliance more achievable.123
Why — Flexible criteria and aligned regulations would ensure shipowners retain access to necessary sustainable financing.45
Impact — Overly strict requirements could exclude shipowners from green finance by setting unattainable standards.67
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Meeting with Penelope Papandropoulos (Cabinet of Executive Vice-President Margrethe Vestager)

28 Feb 2023 · Consortia Block Exemption Regulation

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

20 Dec 2022 · ETS

Meeting with Penelope Papandropoulos (Cabinet of Executive Vice-President Margrethe Vestager)

18 Oct 2022 · Competition policies

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

14 Oct 2022 · ETS

Response to Evaluation of the Consortia Block Exemption Regulation

3 Oct 2022

For the reasons explained in the attached position paper (which includes an assessment by RBB Economics), the World Shipping Council (WSC), the International Chamber of Shipping (ICS), and the Asian Shipowners’ Association (ASA) respectfully request that the Commission extend the period of application of the CBER without amending any other provisions of the CBER.
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World Shipping Council Urges Delay in EU Customs Overhaul

18 Sept 2022
Topic — The Commission is revising the Union Customs Code to modernize e-commerce and digitalization.
Message — The Council demands the Commission prioritize finishing current IT projects before launching new reforms. They call for deeper industry consultation on specific legislative measures to ensure rules work.12
Why — Unified EU-level IT systems would eliminate costly and redundant national reporting requirements.3
Impact — National administrations might face power struggles with a proposed new central customs agency.4
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Meeting with Jörgen Warborn (Member of the European Parliament, Rapporteur) and Cruise Lines International Association

5 Jul 2022 · Sjöfartsfrågor

Meeting with Jörgen Warborn (Member of the European Parliament, Rapporteur)

20 Jun 2022 · Sjöfartsfrågor

Meeting with Jörgen Warborn (Member of the European Parliament, Rapporteur)

26 Apr 2022 · Sjöfartsfrågor

Meeting with Michael Bloss (Member of the European Parliament) and EUROMETAUX and

8 Feb 2022 · ETS

Meeting with Andrey Novakov (Member of the European Parliament, Rapporteur for opinion)

24 Nov 2021 · EU ETS

Meeting with Roxana Lesovici (Cabinet of Commissioner Adina Vălean)

19 Nov 2021 · Meeting to discuss the evolutions of the maritime sector.

Response to FuelEU Maritime

8 Nov 2021

Please find attached comments on the draft legslation by the World Shipping Council
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World Shipping Council Urges Narrower EU Carbon Market Scope

8 Nov 2021
Topic — The European Commission is revising the carbon market to include maritime transport.
Message — The council supports joining the trading system but wants it restricted to voyages within Europe. They also advocate for shared accountability between shipowners and operators.123
Why — A restricted scope prevents carbon leakage and maintains the competitiveness of European trade.45
Impact — Other industrial sectors lose revenue from selling fewer carbon allowances to the shipping industry.6
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Response to Climate change mitigation and adaptation taxonomy

17 Dec 2020

The liner shipping industry is committed to reducing its carbon and emissions footprint in line with targets set by the Paris Climate Change Accord and by the International Maritime Organisation. Progress towards those goals very much depends on new research and development leading to the widespread deployment of carbon-neutral and zero-carbon fuels and technologies on vessels. Suitable access to ship finance will be critical for the success of that green transition. Ship financing and investment can play a key role in supporting and pushing the industry towards decarbonisation. WSC welcomes the recognition that the shipping industry can be considered as making substantial contributions to climate change mitigation and adaptation and hence is eligible for green finance. However, it is vitally important that the screening criteria are clear and provide an adequate threshold for shipping companies to attain. Our detailed comments in that regard and in response to the draft Delegated Regulation can be found in the attached document.
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Response to Updating the EU Emissions Trading System

25 Nov 2020

Please find attached the WSC response to the Inception Impact Asessement Consultation.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

Please see attached PDF file for the WSC response to this consultation.
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Response to Sustainable and Smart Mobility Strategy

28 Jul 2020

The World Shipping Council welcomes the opportunity to provide feedback on the Sustainable and Smart Mobility Strategy. The attached file includes our comments regarding the Roadmap that is currently open for comment. Should any questions arise please contact Damian Viccars in our Brussels Office.
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Response to Mid-term evaluation of the Union Customs Code

16 Jul 2020

Please find attached the response of the World Shipping Council to the Road Map Consultation
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Response to Revision of Alternative Fuels Infrastructure Directive

4 May 2020

Please find attached WSC comments on the Revision of Alternative Fuels Infrastructure Directive road map consultation.
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Response to FuelEU Maritime

24 Apr 2020

Please find attached the World Shipping Council's response to the consultation.
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Response to 2030 Climate Target Plan

15 Apr 2020

The Inception Impact Assessment for the 2030 Climate Target Plan seeks to propose a more ambitious climate target for 2030 and to prepare the EU for the transition to climate neutrality by 2050. The background information appropriately references the development of an overall architecture and an enabling framework required for sustainable finance, research and development and innovation, and the deployment of new technologies at scale. Considering these goals and the maritime transport sector specifically, the World Shipping Council believes that the key to an accelerated and economically efficient transition to zero-emission ships is directly linked to our ability to identify which zero carbon fuels (green hydrogen and green ammonia are among the leading candidates) and related engineering systems are most suitable to constitute the main route for a radical energy transformation in the maritime transportation sector. This research and development work constitutes a “critical pathway” for accelerating the energy transition in the maritime sector. It is important to note that the decarbonization of transoceanic shipping faces a more challenging set of engineering issues due to the immense size of the engines used on these ships and the need to carry large volumes of fuel over long distances. As a result, we may see different solutions for smaller vessels engaged in short-sea shipping, or the use of the same fuels, but with their use requiring highly differentiated system designs. If we succeed in accelerating the development of the necessary engineering systems to use zero carbon fuels on large, medium, and smaller ships, we can expect the energy transition to proceed in a manner that is economically efficient as the technical pathways to achieve the transition will be much clearer. Greater clarity in what technical pathways are most promising will enable the development of products and systems that can be produced with a much smaller risk of stranded assets. We can also avoid the development of numerous fuel infrastructure projects that may have been undertaken with the best of intentions, but prove of limited value as certain other zero carbon fuels emerge as the primary mechanisms for reaching our climate goals as well as broader air quality objectives. Considering the above points, we would encourage the Commission to make research and development focused on zero carbon fuels and the development of engineering systems necessary to use these fuels onboard ships, a key element of the 2030 Climate Target Plan. This can be linked to efforts under consideration globally such as the proposal in the International Maritime Organization to establish an International Maritime Research and Development Board. The efforts can be mutually supportive and if both the European Union and the IMO exhibit the political will to focus resources on such work we can proceed with the confidence that the energy transition in the maritime sector will occur much sooner and with greater efficiency than may otherwise occur. Moreover, any market-based measure adopted by the EU or at a global level will function much more efficiently if the technical pathways for moving to zero carbon fuels are well developed in numerous sectors (including maritime transportation). A carbon price alone, without the necessary technical development efforts, is likely to see a slow response in the marine transport sector (i.e., maritime engineering marketplace) because the overwhelming majority of engineering expertise is devoted to technology innovation in on-road applications that involve much larger markets, smaller power demands and fundamentally different engineering solutions.
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Meeting with Roxana Lesovici (Cabinet of Commissioner Adina Vălean)

18 Feb 2020 · Decarbonisation for shipping

World Shipping Council urges five-year extension for consortia rules

20 Dec 2019
Topic — Consultation on prolonging competition law exemptions for container shipping line consortia.
Message — The Council supports the prolongation but demands a five-year extension instead of four. They claim that European law mandates a five-year period for such regulations.12
Why — This extension ensures continued legal certainty and lower compliance costs for the shipping industry.34
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Meeting with Claes Bengtsson (Cabinet of Commissioner Margrethe Vestager)

15 May 2019 · Competition Policy

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

15 May 2019 · C-BER

World Shipping Council urges EU to renew consortia block exemption

4 Jun 2018
Topic — Evaluation of competition rules for agreements between maritime shipping companies providing international services.
Message — Shipping groups request a five-year extension to maintain a clear legal framework for maritime cooperation. They believe it promotes efficiency and helps smaller companies overcome barriers to entry through cooperation.123
Why — Shipping lines maintain low compliance costs and avoid complex self-assessments of their joint operations.4
Impact — European buyers and consumers face higher costs and reduced service quality if the exemption ends.5
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Response to EU Single Window environment for customs

30 May 2018

Please see attached response.
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Response to Reporting formalities for ships (European Maritime Single Window environment)

24 Aug 2017

Summary Section of the Uploaded WSC Response The EC Inception Impact Assessment is correct in its assessment that the EU Reporting Formalities Directive 2010/65/EC (RFD) has failed to meet its objectives of simplifying, rationalising and harmonising reporting obligations for vessels calling EU ports. In fact, administrative burdens have increased as a result of the RFD. The WSC concurs that remedial action is necessary, and continues to encourage that the most cost effective and immediate implementable measures be prioritised. The full EU-wide harmonisation of the data elements and electronic message structures used by carriers to submit cargo and conveyance related data during port calls should be the principal objective. Clear EU-wide rules requiring the reuse of data within and between Member States should also be prioritised alongside proper exploitation of existing data-rich sources such as the Entry Summary Declaration. The goal should be to achieve, wherever possible, ‘once only submission’ of data by carriers. These measures would significantly improve the efficiency and effectiveness of maritime carriers and by consequence benefit the European economies these carriers serve. ------ The World Shipping Council (WSC) is a non‐profit trade association with offices in Brussels and Washington, D.C. representing the interests of the international liner shipping industry in public policy and regulatory matters. The WSC’s global membership accounts for more than ninety percent of global liner shipping capacity. Member companies transport annually more than 40 million TEUs of EU export and import cargo, roughly EUR 1.41 trillion worth of goods. The WSC is inscribed in the EU Registry of Interest Representatives (registration no. 32416571968‐71). Further information about the association can be found at www.worldshipping.org .
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Response to Revision of the Shipping MRV Regulation

7 Jul 2017

Extract from the attached joint position paper: The European Community Shipowners’ Associations and the International Chamber of Shipping - in conjunction with the Asian Shipowners’ Association, BIMCO, INTERCARGO INTERFERRY, INTERTANKO and the World Shipping Council welcome the revision of the EU Shipping MRV Regulation undertaken for the purpose to align the EU MRV with the global IMO Data Collection System (IMO DCS). The EU MRV has to be 100% aligned to the IMO data collection system with verification carried out according to IMO rules and that reported information covering voyages from and to EEA ports will not be published. The use of the existing IMO mechanisms from the Flag State Administrations for enforcement and implementation, under a single and functional global fuel consumption data collection system, is required. A signal from the Commission confirming that it is taking the necessary steps to align the EU regime with the IMO data collection regulation would be most helpful to avoid polarisation at the next round of discussions at IMO, stimulating further progress towards the ambitious global solution that the Commission is also seeking, and which the global and EU shipping industries fully support.
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Response to Shipping Emissions Verification and Accreditation

25 Aug 2016

The World Shipping Council (WSC) provides a coordinated voice for the global liner shipping industry with offices in Brussels and Washington D.C. The Council’s membership accounts for approximately 90 percent of global liner shipping capacity, including several of the world’s largest container shipping lines headquartered in the EU. These companies transport annually: over 40 million TEUs of European export and import cargo or roughly two-thirds of the EU’s seaborne trade by value; around 10 million TEUs of feeder cargo to and from the EU’s transhipment hubs and 4 million TEU of cargo moved in pure intra EU trade. The World Shipping Council is inscribed on the EU Transparency Register under number 32416571968-71. WSC offers the following comments and suggestions concerning the proposed Commission Delegated Regulation (EU) …/… on the verification activities and accreditation of verifiers pursuant to Regulation (EU) 2015/757 Chapter II Articles 6 and 16: The draft regulations in Articles 6 and 16 mandate site visits in the absence of an express and carefully documented written waiver. Site visits should not be mandatory, because the verification of data and other requirements should be able to be performed remotely in many, if not most, cases. In other words, site visits should be a tool to be used in exceptional circumstances, not a default procedure in all verification activities. A requirement for site visits or an obligation to formally “waive” such a requirement would unnecessarily and substantially increase the cost of verification activities with little or no added value in many circumstances. This matter was extensively discussed in the ESSF Subgroup and the majority of participants argued against mandatory site visits. WSC recommends that Article 6 be redrafted to indicate that site visits should be limited to circumstances where the verifier determines that a given site visit is necessary in light of circumstances unique to a given review. Articles 8, 18, and 21: Articles 8, 18, and 21 call for review of plan assessments and emission reports in every case by an “independent reviewer.” The independent reviewer is to be an individual within the verification organization that did not perform any of the work done on the applicable plan assessment or reporting verification. An independent review is neither necessary nor cost-effective, because the verification exercise is already, by definition, a review and verification of the relevant data. Indeed, mandating such a review suggests a systemic weakness in the basic review and verification process where no such weakness should occur given the already detailed procedures mandated by the regulation. Therefore, independent reviews should be limited to situations where inconsistency of the reported data raises questions requiring further explanation or examination. Article 10: Article 10 should make it absolutely clear that electronic records of the company, including electronic copies of the ship's log, are acceptable data sources. This is especially relevant as the number of data entries in the liner shipping industry will be measured in the thousands for ships engaged in a regular rotation to EU ports. General Comment on the Scope and Detail of the Verification Requirements Numerous participants in the ESSF Subgroup consistently commented that the scope and level of detail in the proposed EU MRV verification requirements are excessive, unnecessarily complicated, costly, and burdensome. WSC agrees with those concerns. A data collection system that should be a simple and straight-forward exercise has instead been transformed into a highly complicated, administratively burdensome, and costly undertaking for any ocean carrier operating in or visiting the EU.
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Response to Shipping Emissions Templates

25 Aug 2016

The World Shipping Council (WSC) provides a coordinated voice for the global liner shipping industry with offices in Brussels and Washington D.C. The Council’s membership accounts for approximately 90 percent of global liner shipping capacity, including several of the world’s largest container shipping lines headquartered in the EU. These companies transport annually: over 40 million TEUs of European export and import cargo or roughly two-thirds of the EU’s seaborne trade by value; around 10 million TEUs of feeder cargo to and from the EU’s transhipment hubs and 4 million TEU of cargo moved in pure intra EU trade. The World Shipping Council is inscribed on the EU Transparency Register under number 32416571968-71. Before turning to comments on specific items within the proposed regulations, WSC urges the Commission to consider at the earliest possible opportunity the IMO Ship Fuel Consumption Database that the International Maritime Organization is expected to finalize in October of this year. Regulation (EU) 2015/757 of 29 April 2015 expressly states that the EU GHG regulations for shipping may be revised to align with international requirements covering the same subject matter. A global system, such as the one that the IMO is expected to adopt, provides a more accurate and complete basis upon which to analyse vessel GHG emissions and to consider potential further steps to reduce those emissions. Regional systems by definition cannot effectively address emissions whose global effects do not depend on where those emissions occur. WSC offers the following comments and suggestions concerning the proposed Commission Implementing Regulation (EU) …/… on templates for monitoring reports and documents of compliance pursuant to Regulation 2015/757: 1) Article 2, paragraph 1: Template of the monitoring plan: Paragraph 1 should be amended to make it clear that the template provided in Annex I is an indicative example and that flexibility is allowed so long as the required substantive information is provided in a manner generally consistent with the model template; 2) Article 2, Paragraph 2: Template of the monitoring plan: WSC commends the EC in providing the flexibility to divide the monitoring plan into a company-specific part and ship-specific part. This approach will avoid unnecessary duplication of information for companies operating multiple ships while also allowing for the identification of relevant monitoring information that is unique to a given ship. We note that a conforming clarification should also be made at Chapter II, Article 4, Paragraph 1 of the draft delegated regulation on verification activities.
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Response to Shipping Emissions Cargo Carried

25 Aug 2016

The World Shipping Council (WSC) provides a coordinated voice for the global liner shipping industry with offices in Brussels and Washington D.C. The Council’s membership accounts for approximately 90 percent of global liner shipping capacity, including several of the world’s largest container shipping lines headquartered in the EU. These companies transport annually: over 40 million TEUs of European export and import cargo or roughly two-thirds of the EU’s seaborne trade by value; around 10 million TEUs of feeder cargo to and from the EU’s transhipment hubs and 4 million TEU of cargo moved in pure intra EU trade. The World Shipping Council is inscribed on the EU Transparency Register under number 32416571968-71. Before turning to comments on specific items within the proposed regulations, WSC urges the Commission to consider at the earliest possible opportunity the IMO Ship Fuel Consumption Database that the International Maritime Organization is expected to finalize in October of this year. Regulation (EU) 2015/757 of 29 April 2015 expressly states that the EU GHG regulations for shipping may be revised to align with international requirements covering the same subject matter. A global system, such as the one that the IMO is expected to adopt, provides a more accurate and complete basis upon which to analyse vessel GHG emissions and to consider potential further steps to reduce those emissions. Regional systems by definition cannot effectively address emissions whose global effects do not depend on where those emissions occur. WSC offers the following comments and suggestions concerning the proposed Commission Implementing Regulation (EU) …/… on determination of cargo carried for categories of ships other than passenger, ro-ro and container ships pursuant to Regulation (EU) 2015/757: 1. Paragraph (5) of the draft preamble states “In the case of vehicle carriers, the determination of cargo carried should follow a flexible approach based on two different options. In order to better reflect the special relevance of volume, it is appropriate to allow for data on a different additional parameter to be provided on a voluntary basis.” This statement introduces confusion with respect to vehicle carriers as Article 3(h) stipulates that cargo carried for vehicle carriers shall use “the mass of the cargo on board, determined as the actual mass or as the number of cargo units or occupied lane meters multiplied by default values for their weight.” Article 3(h) allows for the use of different methods, but all the methods provided for are weight based options. However, paragraph (5) of the preamble states that cargo carried for these ships should be based on two different options, that volume is of special relevance, and that it is important to allow for reporting of additional parameters on a voluntary basis. Given that all of the options listed in Article 3(h) are weight-based, the preamble language needs to be changed or clarified. 2. During discussions within the ESSF task group on vehicle carriers, and later in the ro-ro task group, it was explicitly pointed out that lane meters are not used by vehicle carriers and are not standard industry practice. Lane meters may be used by ro-pax vessels and other ro-ro ships, but lane meters are not used by companies operating vehicle carriers as defined in IMO regulations. As a result, WSC recommended that “occupied lane meters” should not be included as a measurement option for vehicle carriers. Recognizing this situation, WSC recommends that Article 3(h) be modified as follows: “for vehicle carriers, as the mass of the cargo on board, determined as the actual mass or as the number of cargo units multiplied by default values for their weight.” 3. WSC member companies operating vehicle carriers have repeatedly stressed the view that cargo carried would best be handled as a fixed design DWT figure consistent with the international data system to be adopted
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