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Thursday, 22 December 22
CHINA TIGHTENS VERIFICATION OF SHIPS’ ENERGY CONSUMPTION DATA - GARD
From 22 December 2022, ships trading to Chinese ports must record their energy consumption data in accordance with the requirements of their Ship Energy Efficiency Management Plan (SEEMP). Ships must also report the consumption data from their last voyage to the Chinese authorities prior to leaving a Chinese port.
In November 2022, China MSA published the Regulation of Administrative Measures of Ship Energy Consumption Data and Carbon Intensity, (in Mandarin – an English translation courtesy of BIMCO can be found here), The regulation will come into force on 22 December 2022. A few provisions apply to both Chinese and foreign flagged ships of 400 GT and above that enter or exit Chinese ports. Most of the provisions are China’s implementation of Marpol Annex VI and not applicable to foreign flagged vessels. The regulations do not apply to military, fishing or sports vessels.
Below is a summary of the key requirements:
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Ship energy consumption data collection and reporting
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Data collection standard: Ships must collect and report ship energy consumption data in accordance with the new regulation and the Technical Requirements for Ships’ Energy Consumption Data Collection and Reporting (JT/T 1340).
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Data recording: Chinese flagged ships on international voyages and foreign ships entering or leaving Chinese ports must record the ship’s energy consumption data in the ship’s logbook or other relevant documents in accordance with the requirements of the Ship Energy Efficiency Management Plan (SEEMP). The data records must be kept onboard for at least 2 years and be available for inspection by the Chinese Maritime Safety Authority (MSA).
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Data reporting: Chinese flagged ships on international voyages and foreign ships must report the energy consumption data of the previous voyage to the MSA. For foreign flag vessels, this is done as part of the departure clearance procedures
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Reporting channels: Vessels must report the energy consumption data using the relevant maritime information platform or system nominated by the China MSA. This would usually be China MSA’s reporting portal. The MSA reporting portal does not seem to have an English language option, so we advise members to seek assistance from their local agents. Chinese flagged ships on international voyages must report the energy efficiency index data to their class society in accordance with the MARPOL Convention. Class will verify the data and submit it to the authorized MSA within the agreed time.
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Requirements on Carbon Intensity Management for Chinese flagged vessels on international voyages
The new regulation sets out specific requirements for the energy efficiency management of Chinese flagged ships on international voyages. These specific requirements are the Chinese implementation of MARPOL Annex VI and not applicable to international vessels that call to Chinese ports which will be subject to their own flag state’s implementation of SEEMP. The requirements include:
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Obtaining an International Energy Efficiency Certificate (IEEC), the preparation of a SEEMP, and issuing a Confirmation of Conformity (COC) for vessels of 5,000 GT or above whose SEEMP passes verification.
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It also contains requirements on issuing of the new COC. This is issued when the ship changes owner, operator or manager, or undergoes a major conversion, or where the vessel has been found to be non-compliant when implementing the SEEMP by the MSA in a random inspection.
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Chinese ships of 5,000 GT and above and on international voyages must report their annual energy consumption data for the previous calendar year together with supporting documents to the authorized MSA before March 31 each year. The original energy consumption data must be retained until the end of the following year.
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Ships to which Regulation 28 of Annex VI of MARPOL Convention apply must also report the annual operational carbon intensity and relevant supporting documents for the previous calendar year, which will be verified and rated by the authorised MSA.
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A vessel rated ‘D’ for three consecutive years or ‘E’ for a single year will have to update their SEEMP with a corrective action plan and submit the revised SEEMP to the authorized MSA for verification.
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Change of nationality, ownership or management of Chinese vessel
When a Chinese vessel of 5,000 GT and above on international voyages changes nationality, owner, operator or manager, it must, within one month from the date of completion of the change, report to the authorized MSA the energy consumption data of the previous calendar year and the energy consumption data of the current year up to the date of the change. A Statement of Compliance (SoC) on Fuel Consumption and Operational Carbon Intensity will be issued by the MSA after verification.
Legal consequences
Vessels that fail to report the energy consumption data in accordance with the new regulations will be subject to the penalties set out in the Administrative Provisions of China on the Prevention and Control of Marine Environmental Pollution by Vessels and Their Operations (Article 52)(in Mandarin only)
The fines for such violations are usually around CNY 2,000 (about USD 286), according to the authorities. However, as of 2022, the level of the fines has increased. Furthermore, we understand the fines will be significantly increased following the revision of the Marine Environmental Protection Law of China, which has been included in China’s schedule of legislative work.
Recommendations
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Masters of vessels calling Chinese ports should familiarize themselves with the new regulation and contact their local agents for information to ensure compliance.
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Before leaving a Chinese port, a vessel subject to the new regulation must submit reports to MSA detailing the vessel’s energy consumption for the last completed voyage preceding the arrival at that port.
In addition to JT/T 1340, please also see the Energy Consumption Data Collection Record Form and the Data Report Format for the Energy Consumption of Ships annexed to the previous Regulation on Data Collection and Management for Ship Energy Consumption ,when preparing the reports which are normally uploaded by the agent to China MSA’s reporting portal.
Source: Gard
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- Australian Coal Association
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- Marubeni Corporation - India
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- SMG Consultants - Indonesia
- Barasentosa Lestari - Indonesia
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- IHS Mccloskey Coal Group - USA
- Jaiprakash Power Ventures ltd
- Global Coal Blending Company Limited - Australia
- GVK Power & Infra Limited - India
- Port Waratah Coal Services - Australia
- Indian Energy Exchange, India
- Ministry of Finance - Indonesia
- Toyota Tsusho Corporation, Japan
- Semirara Mining Corp, Philippines
- Planning Commission, India
- SN Aboitiz Power Inc, Philippines
- Bukit Asam (Persero) Tbk - Indonesia
- Borneo Indobara - Indonesia
- IEA Clean Coal Centre - UK
- Gujarat Electricity Regulatory Commission - India
- VISA Power Limited - India
- White Energy Company Limited
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- Coal and Oil Company - UAE
- Bank of Tokyo Mitsubishi UFJ Ltd
- Lanco Infratech Ltd - India
- Vizag Seaport Private Limited - India
- Star Paper Mills Limited - India
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- Energy Development Corp, Philippines
- Rio Tinto Coal - Australia
- Larsen & Toubro Limited - India
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- Kepco SPC Power Corporation, Philippines
- Baramulti Group, Indonesia
- Bulk Trading Sa - Switzerland
- Globalindo Alam Lestari - Indonesia
- Africa Commodities Group - South Africa
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- Oldendorff Carriers - Singapore
- Indonesian Coal Mining Association
- Sakthi Sugars Limited - India
- Kumho Petrochemical, South Korea
- GN Power Mariveles Coal Plant, Philippines
- Ministry of Mines - Canada
- Coalindo Energy - Indonesia
- Cement Manufacturers Association - India
- ASAPP Information Group - India
- ICICI Bank Limited - India
- Asmin Koalindo Tuhup - Indonesia
- Grasim Industreis Ltd - India
- Indian Oil Corporation Limited
- Uttam Galva Steels Limited - India
- Trasteel International SA, Italy
- Wood Mackenzie - Singapore
- Xindia Steels Limited - India
- Ambuja Cements Ltd - India
- Meenaskhi Energy Private Limited - India
- Georgia Ports Authority, United States
- Antam Resourcindo - Indonesia
- Metalloyd Limited - United Kingdom
- London Commodity Brokers - England
- Electricity Generating Authority of Thailand
- Vedanta Resources Plc - India
- Jorong Barutama Greston.PT - Indonesia
- Pendopo Energi Batubara - Indonesia
- Bahari Cakrawala Sebuku - Indonesia
- Petrochimia International Co. Ltd.- Taiwan
- PowerSource Philippines DevCo
- Karaikal Port Pvt Ltd - India
- Chamber of Mines of South Africa
- Parliament of New Zealand
- Energy Link Ltd, New Zealand
- TNB Fuel Sdn Bhd - Malaysia
- Indika Energy - Indonesia
- McConnell Dowell - Australia
- LBH Netherlands Bv - Netherlands
- Ministry of Transport, Egypt
- Sindya Power Generating Company Private Ltd
- Thai Mozambique Logistica
- Holcim Trading Pte Ltd - Singapore
- Merrill Lynch Commodities Europe
- Meralco Power Generation, Philippines
- Bhatia International Limited - India
- Dong Bac Coal Mineral Investment Coporation - Vietnam
- AsiaOL BioFuels Corp., Philippines
- Heidelberg Cement - Germany
- Neyveli Lignite Corporation Ltd, - India
- Aboitiz Power Corporation - Philippines
- Orica Australia Pty. Ltd.
- Madhucon Powers Ltd - India
- Mjunction Services Limited - India
- Altura Mining Limited, Indonesia
- Tamil Nadu electricity Board
- TeaM Sual Corporation - Philippines
- Chettinad Cement Corporation Ltd - India
- Global Business Power Corporation, Philippines
- Bharathi Cement Corporation - India
- India Bulls Power Limited - India
- Bhushan Steel Limited - India
- Salva Resources Pvt Ltd - India
- Sree Jayajothi Cements Limited - India
- Tata Chemicals Ltd - India
- Anglo American - United Kingdom
- Offshore Bulk Terminal Pte Ltd, Singapore
- CIMB Investment Bank - Malaysia
- Indo Tambangraya Megah - Indonesia
- Leighton Contractors Pty Ltd - Australia
- Asia Pacific Energy Resources Ventures Inc, Philippines
- Electricity Authority, New Zealand
- Kartika Selabumi Mining - Indonesia
- Kaltim Prima Coal - Indonesia
- Power Finance Corporation Ltd., India
- Rashtriya Ispat Nigam Limited - India
- Maharashtra Electricity Regulatory Commission - India
- International Coal Ventures Pvt Ltd - India
- Renaissance Capital - South Africa
- PNOC Exploration Corporation - Philippines
- Alfred C Toepfer International GmbH - Germany
- Attock Cement Pakistan Limited
- The University of Queensland
- Central Java Power - Indonesia
- Eastern Coal Council - USA
- CNBM International Corporation - China
- European Bulk Services B.V. - Netherlands
- Independent Power Producers Association of India
- Indogreen Group - Indonesia
- Sinarmas Energy and Mining - Indonesia
- Minerals Council of Australia
- Price Waterhouse Coopers - Russia
- SMC Global Power, Philippines
- Singapore Mercantile Exchange
- MS Steel International - UAE
- Jindal Steel & Power Ltd - India
- Interocean Group of Companies - India
- The State Trading Corporation of India Ltd
- Pipit Mutiara Jaya. PT, Indonesia
- Bayan Resources Tbk. - Indonesia
- Standard Chartered Bank - UAE
- Romanian Commodities Exchange
- Ceylon Electricity Board - Sri Lanka
- Siam City Cement - Thailand
- Coastal Gujarat Power Limited - India
- Dalmia Cement Bharat India
- Samtan Co., Ltd - South Korea
- Bukit Baiduri Energy - Indonesia
- Semirara Mining and Power Corporation, Philippines
- Medco Energi Mining Internasional
- Ind-Barath Power Infra Limited - India
- Kohat Cement Company Ltd. - Pakistan
- Truba Alam Manunggal Engineering.Tbk - Indonesia
- San Jose City I Power Corp, Philippines
- Iligan Light & Power Inc, Philippines
- Sojitz Corporation - Japan
- Aditya Birla Group - India
- Krishnapatnam Port Company Ltd. - India
- Bhoruka Overseas - Indonesia
- The Treasury - Australian Government
- Directorate Of Revenue Intelligence - India
- Kideco Jaya Agung - Indonesia
- Bukit Makmur.PT - Indonesia
- Intertek Mineral Services - Indonesia
- Wilmar Investment Holdings
- Manunggal Multi Energi - Indonesia
- Bangladesh Power Developement Board
- Simpson Spence & Young - Indonesia
- Agrawal Coal Company - India
- Gujarat Mineral Development Corp Ltd - India
- Straits Asia Resources Limited - Singapore
- Posco Energy - South Korea
- Parry Sugars Refinery, India
- Savvy Resources Ltd - HongKong
- Siam City Cement PLC, Thailand
- OPG Power Generation Pvt Ltd - India
- Mercator Lines Limited - India
- South Luzon Thermal Energy Corporation
- Banpu Public Company Limited - Thailand
- Deloitte Consulting - India
- Videocon Industries ltd - India
- Billiton Holdings Pty Ltd - Australia
- Therma Luzon, Inc, Philippines
- Directorate General of MIneral and Coal - Indonesia
- Mintek Dendrill Indonesia
- Edison Trading Spa - Italy
- Timah Investasi Mineral - Indoneisa
- Kobexindo Tractors - Indoneisa
- Orica Mining Services - Indonesia
- Binh Thuan Hamico - Vietnam
- Carbofer General Trading SA - India
- Petron Corporation, Philippines
- Goldman Sachs - Singapore
- Maheswari Brothers Coal Limited - India
- Kalimantan Lumbung Energi - Indonesia
- Latin American Coal - Colombia
- Makarim & Taira - Indonesia
- Central Electricity Authority - India
- Global Green Power PLC Corporation, Philippines
- Eastern Energy - Thailand
- Sarangani Energy Corporation, Philippines
- Malabar Cements Ltd - India
- Karbindo Abesyapradhi - Indoneisa
- Commonwealth Bank - Australia
- PetroVietnam Power Coal Import and Supply Company
- New Zealand Coal & Carbon
- PTC India Limited - India
- GAC Shipping (India) Pvt Ltd
- Filglen & Citicon Mining (HK) Ltd - Hong Kong
- Formosa Plastics Group - Taiwan
- Sical Logistics Limited - India
- Thiess Contractors Indonesia
- Mercuria Energy - Indonesia
- Economic Council, Georgia
- Cigading International Bulk Terminal - Indonesia
- GMR Energy Limited - India
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