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reporting requirements of the EU MRV Regulation
                                                                    and the IMO DCS. Furthermore, in April 2018, the
                                                                    IMO agreed on an Initial Strategy for the reduction
                                                                    of GHG emissions from ships to reduce total annual
                                                                    GHG emissions from international shipping by at
                                                                    least 50% by 2050, compared to 2008.

                                                            IMO- levels of ambition
                                                                    The Initial Strategy’s levels of ambition are:
                                                                    (i)  Strengthening  the  energy  efficiency  design
                                                                    requirements for ships to reduce their carbon
                                                                    intensity (ii) Reducing CO2 emissions per transport
                                                                    work, as an average across international shipping, by
                                                                    at least 40% by 2030, pursuing efforts towards 70%
                                                                    by 2050, compared to 2008. (iii) Pursuing efforts
                                                                    consistent with the Paris Agreement temperature
                                                                    goals - the 2015 Paris Agreement was agreed
                                                                    upon by parties to the United Nations Framework
                                                                    Convention on Climate Change, according to which
                                                                    the global temperature rise this century should be
                                                                    kept well below 2 degrees, and preferably to 1.5
                                                                    degrees Celsius, compared to pre-industrial levels.

                                                            The advantages and disadvantages of incorporating
                         by Directive 2018/410 emphasises the  international shipping into EU-ETS, according to the ECSA-
                         need to act on shipping emissions.  ICS study dated July 2020
                       –  Monitoring,  reporting  and  verification       –  Potential advantages: it is a proven
                         (MRV) is to be effected according to              mechanism for allocating carbon permits
                         Regulation 2015/757 (as amended by                and trading platforms; by allowing the
                         Delegated Regulation 2016/2071) - EU              price on carbon, it is ensured that CO2
                         MRV Regulation.                                   emissions are reduced in the most
                       –  The European Commission also supports            economical way; the already-implemented
                         the implementation of international energy        EU MRV system for ships trading
                         efficiency rules and standards, i.e., the         internationally to and from the EU can
                         Energy Efficiency Design Index (EEDI) and         serve as a basis for the implementation
                         the Ship Energy Efficiency Management             of the EU-ETS in shipping.
                         Plan (SEEMP).                                    –  Potential  disadvantages:  risk  of
                                                                           undermining IMO negotiations on the
          Obligations of companies under the EU MRV Regulation             implementation of the Initial Strategy on
                 From 2019, the companies, through THETIS MRV,             the Reduction of GHG from Ships; greater
                 submit to the Commission and the flag States a            uncertainty over the price of emitting a
                 satisfactorily verified emissions report for each ship    tonne of CO2, as it depends on supply and
                 that has performed maritime transport activities          demand; significant administrative burden
                 in the European Economic Area in the previous             and cost compared to other MBMs;
                 calendar year. In addition, from 2019, companies          unlikely to address the complexity of the
                 shall ensure that their vessels visiting ports in         shipping market (numerous ship types,
                 the European Economic Area carry on board a               contractual relationships, etc.); funds
                 document of compliance issued by THETIS MRV by            raised from carbon allowances bought by
                 June of each year; this obligation may be subject to      the shipping sector are not retained in the
                 inspections by Member States’ authorities.                shipping sector.

          IMO Data collection system and the initial greenhouse   Proposal for an International Maritime Research and
          emissions strategy                                Development Fund
                 In March 2018, the IMO adopted a mandatory Fuel    In March/April 2020, ICS, BIMCO, CLIA,
                 Oil Data Collection System (DCS), which came into   INTERCARGO,  INTERFERRY, INTERTANKO,
                 effect on 1 January 2019, by which ships calling into   IPTA and WSC submitted to the IMO a Proposal
                 European Economic Area ports must comply with the   to establish an International Maritime Research


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