【EU-ETS】How to Open MOHA?

On 31 Jan. 2024, the list of Administering Authority for Shipping Companies has been published by EC. You can check the list from below link.
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202400411

To surrender EUAs, Shipping Company shall open MOHA (Maritime Operator Holding Account) in the attributed Administering Authority.

Below is brief procedure for opening MOHA.

１．How to open MOHA

①Registering at the ’EU Login’※１ Authentication Service

②Creating a Member State Specific user ID in the Union Registry※2 

③Apply MOHA

④Submitting necessary documents

※１’EU Login’：EU Login is the European Commission's user authentication service. It allows authorised users to access a wide range of Commission web services, using a single email address and password.

※2 Union Registry：The Union Registry serves to guarantee accurate accounting for all allowances issued under the EU emissions trading system (EU ETS). The registry keeps track of the ownership of allowances held in electronic accounts.

Some Administering Authorities introduce the procedure for opening ETS accounts on their website. Please refer below links from Dutch Emission Authority.

https://www.emissionsauthority.nl/topics/eu-ets-registry-2021-2030/documents/publications/2016/10/26/manual-eu-login-account-and-urid

 ２．Required information and documents

Shipping Companies are required to input Account holder's name, address, phone number, e-mail address, IMO number, contact address of the company, etc. In case the account holder is legal entity, national administrators may ask for the submission of the registration of the legal entity etc.  If the Shipping Company is a ISM company, mandate letter between registered owner and the ISM company is also required.

Please see below regulations for reference.

COMMISSION DELEGATED REGULATION (EU) 2019/1122, ANEX Ⅲ　Table Ⅲ-Ⅰ

COMMISSION DELEGATED REGULATION (EU) 2023/2904　ANNEXⅣ

The procedures and required documents for opening an account may vary depending on the Administering Authority. It is recommended to contact your Administering Authority for accurate information. Please refer to the "Contact Points" link on the following website for contact information of each Administering Authority.

https://climate.ec.europa.eu/eu-action/eu-emissions-trading-system-eu-ets/union-registry_en#links

３．If your company is not on the list

Even if the Registered Owner decides to fulfill ETS obligations, there may be cases where the Registered Owner is not assigned a Administering Authority. According to EU Directive 2003/87 Article 3gf 1. (ｃ), it states that  'in the case of a shipping company that is not registered in a Member State and that did not carry out any voyage falling within the scope set out in Article 3ga in the preceding four monitoring years, the Member State where a ship of the shipping company has started or ended its first voyage falling within the scope set out in that Article.'

We raised our inquiry to EMSA and received below reply.

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If your company doesn’t appear on the list, the THETIS-MRV Helpdesk will also assist the company in assigning its responsible administering authority in the system, nevertheless before contacting the helpdesk we recommend following the procedures described below. The helpdesk may be contacted through the following email address: [e-mail].
If your shipping company doesn’t appear on the list, first of all, the company should create a user account in THETIS-MRV (if not already existing) and add the new company to that account.
If it is an EEA company, as per the information recorded in Thetis-MRV, it may then already send a request at the THETIS-MRV helpdesk with a view to be attributed to the administering authority of that EEA country.
If it is a non-EEA company, as per the information recorded in Thetis-MRV, the company should first ensure that all the ships under its responsibility and falling within ETS scope are assigned to its company account in Thetis-MRV, and only after, the company should send a request at the THETIS-MRV helpdesk with a view to be assigned to the administering authority of the Member State where the first port of call happened.
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