The EU-ETS, which started applying to the maritime industry in January 2024, has Administration Authorities responsible for enforcing and overseeing the rules for Shipping Companies*, the entities responsible for complying with the regulations. The announcement of these Administration Authorities is scheduled to be made by February 1st.
*Shipping Company: Registered Owner or ship management company authorized by the Registered Owner
Once the Administration Authorities are announced, we would like to guide shipowners and ship management companies on what steps they need to take to smoothly comply with the EU-ETS. Please refer to the following information:
1. Shipowners and Ship Management Companies
- Determine whether the shipowner or management company will hold the ETS obligation* if it is undecided.
- Discuss the procedures, scope of responsibilities, and obligations for complying with the EU-ETS. Update ship management contracts if necessary.
* ETS obligation: The obligation to surrender emission allowances to the Administration Authorities. The entity responsible for ETS obligations must be the same as the one responsible for EU-MRV.
2. Ship Management Companies
- Confirm the Administration Authorities through THETIS-MRV.
- Contact the National Administrator* assigned to the Administration Authorities or check their webpage to confirm how to open a Maritime Operator Holding Account (MOHA). Some countries may send instructions directly to the Shipping Company assigned to their country regarding the opening of MOHA.
- Apply for the opening of MOHA within 40 working days of the Administration Authorities announcement. If performing the ETS obligation on behalf of the shipowner, submit the mandate letter exchanged between the shipowner and the ship management company. If there is no mandate letter submission, the shipowner will be considered responsible for the ETS obligations of the respective vessel.
- Please refer to the "Contact Points" under "Links" at the bottom of the webpage provided in the link below for the contact details of each country's National Administrator.
https://climate.ec.europa.eu/eu-action/eu-emissions-trading-system-eu-ets/union-registry_en#links
*National Administrator: Administrative agencies responsible for the establishment and maintenance of accounts related to the EU-ETS in each country.
3. Shipowners
- Issue a mandate letter if delegating the ETS obligation to the management company.
- If fulfilling the ETS obligation independently, proceed with the MOHA opening procedure.
The jurisdictional countries will be announced based on THETIS-MRV. Therefore, for shipowners without self-managed vessels, it is presumed that they will not be allocated a jurisdictional country on February 1st. In this case, the jurisdictional country will be determined by the first EU country where the ship owned by the shipowner visits after 2024. The shipowner needs to contact the jurisdictional country for procedures such as MOHA opening.
A draft power of mandate letter form has been released by Class NK, and it is also being considered by other industry organizations such as the PI Club. Please find the Class NK template attached for your reference.
For more information on the EU-ETS system, please refer to the following link:
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