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Web Alert: IMO fuel oil consumption data collection system (IMO-DCS)

23 March 2018

The Club's previous web alert on MEPC-70 outcome mentioned about IMO’s introduction of the Data Collection System (IMO-DCS), which runs in parallel to the European Union Monitoring, Reporting and Verification (EU-MRV) regulation, but on a different timeline.
IMO-DCS entered into effect on 1 March 2018, with first data 'calendar year' beginning 1 January 2019. It requires ships ≥ 5,000 GT to submit to their Administration annual reports on fuel oil consumption. This requirement was added to chapter 4 of MARPOL Annex VI under Regulation 22A.
In essence both EU-MRV and IMO-DCS are developed in the context of reduction of greenhouse gases (GHG)/carbon dioxide emissions; with a target to measure and potentially reduce the CO2 emissions in the maritime industry. 
Both schemes overlap in various areas; however, two new sets of regulations, running on two different timescales, may pose some challenges for the members. The table below sets out the core components of the two systems alongside each other for ease of comparison 





Ships ≥ 5000 GT


Warships, naval auxiliaries, fishing vessels, wooden ships of primitive build ships not propelled by mechanical means and government ships used for non-commercial purposes.


Monitoring voyages

Voyages to/from EU ports


Shipboard Plan

EU Monitoring Plan

SEEMP with amendment

Monitoring period

Starting 1 January 2018

Starting 1 January 2019

Range for monitoring


Not specified

Data of cargo carried

Actual amount of cargo

Design deadweight (DWT)


Fuel consumption & CO2 emissions

Fuel consumption & CO2 emissions


Distance & Time

Distance & Time


Transport work (based on actual cargo carried)



Robust verification procedures based on ISO 14064

Practical verification procedures considering the administrative burden (under discussion)


Accredited by European national accreditation bodies

Flag State or Recognised Organisation

Reports to

European Commission

Flag State


Document of Compliance (June 2019)

Statement of Compliance

Centralized database

'THETIS MRV' operated by EMSA

Ship fuel oil consumption database managed by IMO


Annual reporting data including the individual ship information will be made available to the public

Anonymous data will be made available to IMO member states

Based on this table, it is recommended to streamline the procedures, systems and responsibilities to ensure common and consistent set of procedures valid for both EU-MRV and IMO-DCS.

Members are encouraged to start considering the methodology for collecting the fuel oil consumption data that is most appropriate for each ship, which may be similar to the methodology selected for the EU-MRV Regulation since the acceptable methodologies are the same between the two schemes. The Ship Energy Efficiency Management Plan (SEEMP) shall be amended using the template outlined in Appendix 2 of MEPC.282 (70); and data collection plan should be submitted to the Flag State (or Class) for approval by December 2018.