SEEMP Part III

A1: The company shall ensure that the prefilled ship particulars from our database are correct:   

• The deadweight value should be in line with the International Energy Efficiency Certificate
• The gross tonnage value should be in line with the International Tonnage Certificate
• The Ship Type should be in line with the International Energy Efficiency Certifiacte
• Ice class should be checked with reference to Finnish-Swedish Ice Class Rules corresponding to vessel’s Class Notation

SEEMP III generator is meant only for our DCS customers as an expansion of our DCS service to capture the CII scope which will be a part of the DCS delivery.

DNV provides a web application (app) for creating and submitting the plan for verification on the DNV customer portal. Company should submit plans through this app instead of manually preparing their SEEMP III plans.

The SEEMP III is subject to verification by the flag or a RO. After successful verification, a Confirmation of Compliance (CoC) will be issued.

The deadline for the initial verification of the SEEMP III is 31st December 2022. To ensure that the SEEMP is verified within the deadline it should be submitted for verification in due time. SEEMP Part III, together with Confirmation of Compliance has to be onboard from 1st January 2023.

The Carbon Intensity Indicator (CII) is a measure of how efficiently a ship transports goods or passengers and is given in grams of CO2 emitted per cargo-carrying capacity and nautical mile. The ship is then given an annual rating ranging from A to E, whereby the rating thresholds will become increasingly stringent towards 2030. The CII applies to all cargo, RoPax and cruise ships above 5,000 GT. The yearly CII is calculated based on reported IMO DCS data and the ship is given a rating from A to E. For ships that achieve a D rating for three consecutive years or an E rating in a single year, a corrective action plan needs to be developed as part of the SEEMP III and verified.

The CII applies to all ships above 5,000 GT of the following MARPOL ship types: bulk carriers, gas carriers, tankers, container ships, general cargo ships, refrigerated cargo carriers, combination carriers, LNG carriers, vehicle carriers, Ro-Ro cargo vessels, Ro-Ro passenger vessels and cruise ships.

The first DCS reporting year for which a CII will be calculated is 2023, and the first rating will be given in the first half of 2024 based on the 2023 reporting year.

In case of an inferior rating, meaning a D rating for three consecutive years or one E rating, the SEEMP III must be updated with a corrective action plan and verified before the DCS SoC can be issued. The corrective action plan should consist of an analysis of why the required CII was not achieved and include a revised implementation plan in order to achieve the required CII (middle point of the C rating).

Yes, if the vessel was not affected with inferior ratings (1xE or 3xD), then after three years the revised 3-year implementation plan documenting how the required CII will be achieved during next three years, with yearly targets, procedures for self-evaluation and improvement should be submitted by the company.

Digital certificate is sufficient.

Any enforcement mechanism from IMO in such case is still to be decided and will be part of a review to be carried out in 2025. In the meantime we do however anticipate that this may have a focus with stakeholders such as Flag, PSC, vetting and commercial parties which may impose actions or restrictions. Whether failure to implement the SEEMP III should be a detainable deficiency is still also up for discussion.

No, planning for environmental rating of C in SEEMP Part III is not enough according to SEEMP guidelines. Vessel has to plan for Required CII which is a midpoint of C environmental rating in order to meet IMO’s trajectory of decarbonization until 2050.

No. If your vessel’s CII starting point is below the required CII, you are not required to report any measures in SEEMP Part III.

Each measure's CII impact range is based on IMO's Appraisal Tool and our technical experts' industry knowledge. Of course, you can exceed these ranges. In such case, please upload a clarification why do you think that this measure would have such influence on your vessel's target CII or calculations. We do not have any specific documentation requirements.

CII starting point – value synced from the Emissions Insights, basing on submitted DCS data, used as a baseline of calculation of the target CII Required CII – CII value that has to be achieved in the upcoming 3 years Target CII – CII starting point together with the effect of the measures, has to be lower than Required CII in the submitted SEEMP Part III 

If you think that Emissions Insights’ estimated CII from 2020 or 2019 better reflects operational performance of the vessel or simply would like to use sister vessel's estimated CII, you can change your CII starting point in the generator and provide us a clarification why would you like to use this CII instead of 2021 estimated CII.

After registering the vessel in MRV/DCS service, you will get the access to this vessel's calculated Reference CII in the DNV's Emissions Insights. It is based on ship's particulars and can be used as CII starting point in SEEMP Part III generator.

Clarification why does 2021 estimated CII synced from Emissions Insights not reflect normal operational efficiency of the vessel or the document with the calculations will be sufficient for verification purposes.

Correction factors are not included in your CII starting point because until June 2022, requirements for CII correction factors were not yet established by IMO. From 2023, DNV will start collecting additional data in DCS reporting scheme basing on which you will receive two separate CII values in the Emissions Insights: CII without correction factors and CII with correction factors.

Additional data will be required to be delivered to DNV in order to calculate trial CII for such vessel. DNV does not provide any benefits for using trial CII.

Refrigerated cargo carrier (MARPOL Annex VI, Reg. 2.2.22) above 5000GT are subject to CII. As per the IMO MEPC.355(78) CII guidelines G5 (attached), there are currently no correction factors for such vessels.

In case support is needed meeting the required CII and preparing the SEEMP III, you may want to consider contacting advisory services such as DNV maritime advisory for help.

Yes, SEEMP Part III is a 3-year plan and it is required to plan 3 years into the future for the vessel. Every three years after initial verification, plan has to be revised and re-verified. (e.g. for a ship delivered prior to 

1January 2023, before 2026 for 2026-2028 period, before 2029 for 2029-2031 period)

SEEMP Part III is a rolling 3-year plan. It means that if you would like to submit a new plan's revision in 2025, your vessel's SEEMP Part III will be an implementation plan for 2025, 2026 and 2027.

Change of flag is a minor revision that can be simply requested in our SEEMP Part III generator. In case of a change of company, a new SEEMP Part III should be submitted. The plan describes the way in which a company is going to utilize the vessel, therefore there is no possibility to inherit the SEEMP Part III after previous manager while acquiring the vessel.

Yes, the newbuildings also must have a verified SEEMP Part III onboard. If the delivery of the vessel was before 1 October, SEEMP Part III should also contain and implementation plan for the year of delivery. If the delivery of the vessel was after 1 October, the first year of the implementation plan should be the year after delivery.

There is no grace period as such in the regulation but for all practical purposes, DNV as class would accept up to one month to provide the confirmation of compliance for the new SEEMP III.

No, CII correction factors and voyage adjustments have to be stated in SEEMP Part III in order to get a CII deduction. It is required because the SEEMP Part III described how the data required for correction factors and voyage adjustments will be collected.

More information about the CII correction factors and voyage adjustments can be found in IMO's RESOLUTION MEPC.355(78) - 2022 INTERIM GUIDELINES ON CORRECTION FACTORS AND VOYAGE ADJUSTMENTS FOR CII CALCULATIONS (CII GUIDELINES, G5).

You are required to plan your target CII for the upcoming 2 years. The revised SEEMP including the plan of corrective actions should be verified in year ‘YYYY+1’ (i.e 2024), and it should be developed to achieve the required annual operational CII for data collected in the calendar year ‘YYYY+2’

Corrective Actions Plan shall be submitted for verification together with, but in no case later than 1 month after reporting attained annual operational CII based on annual DCS report.

No, if you receive an E-rating for a previous year (YYYY) and prepare a Corrective Actions Plan, you will not be required to prepare another CAP in case of getting another E-rating in the next DCS period. Upon identification of need of CAP and its acceptance (within revised SEEMP Part III) by end of May YYYY+1, a vessel will get approximately 19 months (from June YYYY+1 to end of YYYY+2) of time to achieve the required annual operational CII. However, the required annual operational CII also becomes more stringent after 19 months. Therefore, CAP should be developed appropriately to achieve the required annual operational CII.