Page 41 - ΝΑΥΤΙΚΑ ΧΡΟΝΙΚΑ - MARTIOS 2023

is no enforcement”. These are common
criticisms but, in my view, perhaps
premature ones. The regulation is an
International Maritime Organization
(IMO) instrument, a convention. Its
enforcement, as is the case with all
IMO instruments, lies with the IMO
Member States. It is primarily the flag
states that enforce IMO Conventions
by implementing them in their national
laws and applying them to the ships
that fly their flags. In addition, there is
a second layer of enforcement by the
Port State Controls directed at foreign
flagged ships. This is the way the whole
system is built.
So, does the regulation have teeth, or
not? Is there any “hard” enforcement?
Any consequences? The answer is that
there is no hard enforcement, yet, and
with the CII framework in its current
form, perhaps that is not a bad thing. At
least for now. We must remember that
commercial utilisation of a ship under
the present CII framework will likely
lead to a poorer rating by default. Once
a ship starts calling at ports offloading
or loading cargo while not moving, sit-
that may not be commercially worth ting at anchorages awaiting orders, or
as much as a ship with a higher rating. transporting cargo around the world,
When looking closer at the CII, what it the rating is by default negatively
really reflects, however, is a combina- affected.
tion of a certain degree of technical This framework is flawed, there is no
efficiency combined with the actual doubt about that. But it is here to stay
operation of the ship throughout the and in its current form, now may not be
previous year. We already have objective the best time to call for rigid enforce-
measures specifically for the technical ment and consequences. Our industry
efficiency of a ship: the EEXI and EEDI. is embarking on new ways of doing
Most ships are about to have a rating business, a new way for shipowners and
attached to them, and it is important to charterers to work together. There are
remember that the rating seen in isola- most certainly teething problems but
tion is not enough to conclude whether with the will from everyone involved to
a ship is inferior or not. The rating of the do their part and co-operate, I believe
ship likely says more about the trade it our industry will be able to adapt to
performed last year than whether it is yet another regulation that at least
inferior or not from a technical efficiency intends to get us one step closer to
standpoint. being greener.
Due to the nature of the CII framework, In the meantime, BIMCO and others
I believe we should be very careful are busy working out a more suitable
sticking an inferior label on ships based CII metric and scope of application
on their ratings. It seems fairer to say to ensure that the rating of a ship is
that we are labelling the trades that underpinning the business imperative
the ships performed the previous year of the market actors. Hopefully, we
rather than the ships themselves. will be able to introduce the neces-
sary changes during the review of the
Is it even enforced? CII framework to be completed before
“The CII regulation has no teeth”. “There 1 January 2026.

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