Interferry Director of Regulatory Affairs Johan Roos delivers a periodic Regulatory Report which summarizes Interferry activities related to the IMO and regulatory updates. The Regulatory Report is sent out by email to the Interferry member mailing list and is announced on Interferry’s LinkedIn page.

Johan Roos, Director of Regulatory Affairs

Johan Roos is the Executive Director of EU and IMO Affairs for Interferry based in Brussels. Previously he was Director of Sustainability with Stena Rederi AB. He holds a Masters Degree in Environmental Sciences from the University of Gothenburg, Sweden. In the year 2000, Johan left DNV to join Stena Line, the ferry operator, to develop environmental management systems internally. From 2006-2011 he was in charge of sustainability issues for all of Stena’s shipping activities. Johan works in close relation with the European Community Shipowners Association and the International Chamber of Shipping and represents Interferry at the International Maritime Organization.

These Regulatory Reports are organized in reverse chronological order. Click a toggle “+” to read a report.

Status of CII following the IMO’s MEPC 81 and BEVs on ro-ro ships

Outcome of MEPC 81 – review of CII deferred to next year

As Interferry has IMO consultative status, we attended IMO’s 81st session of the Marine Environment Protection Committee (MEPC 81) March 18-22. Besides the IMO’s long-term greenhouse gas (GHG) emission strategy, we were expecting a review of the Carbon Intensity Indicator (CII). CII is an operational efficiency requirement that dictates how much fuel is allowed to be burned per nautical mile, in relation to ship type and ship size. No other transport mode – be it trains, planes, trucks or automobiles – is similarly regulated. The philosophy behind CII is misguided as it is impossible to devise fair rules for operational efficiency, unless all ships were identical and operated on the same route. While it is possible to regulate carbon content and ship design, operational efficiency is situational and should not be regulated. Therefore, Interferry has never supported this approach with very few industry stakeholders who believe CII is meaningful or feasible.

In fact, CII follows the same IMO approach that resulted in the Energy Efficiency Design Index (EEDI) for new ships and the Energy Efficiency Existing Ship Index (EEXI), both of which define the statistically ‘average ship’ within a category of ship. In theory, this works reasonably well for homogenous segments such as container ships and tankers, but there is no such thing as an ‘average ro-pax’, something that also holds true for several other ship types – general cargo ships for example. Interferry and other shipping industry associations have protested this repeated inappropriate use of statistics and, when first adopted, CII came with both a review clause and a gentlemen’s agreement between Port States to not impose any strict compliance. This is a clear indicator that CII doesn’t work.

While many stakeholders were hoping for MEPC 81 to be the starting point for a CII review, EU member states mutually agreed to block IMO to further discuss the technical and practical details of CII at this point in time. The review of CII was deferred to MEPC 82 which takes place in October 2024. Consequently, an already challenged timeline has become even more challenging with a revised CII expected to be agreed upon not later than spring 2025. Our view is that CII should never have been agreed in the first place and it shall never become a mandatory instrument that leads to Port State Control detentions. Rules should be fair and robust, which CII is not.

BEVs on ro-ro decks – ro-pax ferries not under scrutiny yet

Staying with the IMO, the United Nations agency is also reviewing the carriage of Battery Electric Vehicles (BEVs) and other alternative fuel vehicles on ro-ro (roll-on/roll-off) ships. The IMO makes a distinction between three categories of ro-ros: vehicle carrier – this is a multi-deck ro-ro cargo ship designed for the carriage of empty cars and trucks (primarily short-sea and deep-sea PCTCs); ro-ro cargo ship – this is a ship designed for the carriage of ro-ro transportation units or with ro-ro cargo spaces (primarily short-sea freight ro-ros); and ro-pax ship – this is a ship which carries more than 12 passengers and which has ro-ro cargo space on board (typically for coaches, trucks and passenger cars or tourist vehicles).

Although all three ship categories share the ro-ro principle, they are quite different from one another in terms of operational profiles and mandatory onboard emergency equipment. While all ro-ro ship types are under scrutiny, for now Interferry has succeeded to have ro-pax ferries temporarily put on hold, encouraging the IMO to initially concentrate on vehicle carriers (PCTCs) and ro-ro cargo ships. Unlike ro-pax ferries and ro-ro cargo ships which are typically equipped with a fixed water-based extinguishing system (also known as a drencher system), PCTCs use a CO2 fire suppression system. This system – not allowed on ro-pax ferries – fills the ro-ro space with inert gas, taking the oxygen away and extinguishing the fire. When using CO2, the fire is initially put out but there are concerns that a runaway fire in a shortcut battery may re-ignite after the CO2 suppression system runs out of extinguishing agent, rendering the operator defenseless.

Interferry was heavily engaged in a comprehensive research programme focussing on enclosed ro-ro deck fires. Known as LASH FIRE and finalised in 2023, it clearly demonstrated that ships with pressure water drencher systems can contain thermal runaway battery fires until the ship can safely proceed to port for shore-based support to extinguish the fire. Deep-sea ships cannot call for assistance from emergency services in the middle of the ocean. This is somehow different for ro-ro cargo and ro-pax ships engaged in short-sea services.

Having said this, we will continue engaging with our members and other stakeholders on the carriage of BEVs but, right now, it was important to make a clear distinction between rules for transporting new and used vehicles between continents and private cars that are stowed for just a few hours on a vehicle deck of a drencher-equipped ro-pax or ro-ro cargo ferry.

FuelEU Maritime and HSC & Light Craft Code

In this regulatory update, Interferry Regulatory Affairs Director Johan Roos draws attention to the pending FuelEU Maritime initiative – which might as well be interpreted as the EU fuel standard and a precursor of a global fuel standard. Indirectly connected to reducing the carbon content of energy used on board, he also addresses the transition from a High-Speed Craft Code (HSC Code) to a High Speed & Light Craft Code, something that is high on the association’s 2024 agenda.

To be implemented on 1 January 2025, the main objective of FuelEU Maritime – a key part of the EU’s Fit for 55 basket of measures to drastically reduce net greenhouse gas (GHG) emissions – is to increase the demand for and consistent use of renewable and low-carbon fuels. Due to its well-to-wake approach, both production and consumption of energy need to be factored in to reduce the average carbon content of energy used on board. Interferry supports the idea behind FuelEU Maritime as it guarantees a level playing field in the internal market. While the initiative is currently specific to commercial ships calling at any EU port, it will undoubtedly serve as a roadmap for the IMO quest to further reduce GHG emissions.

Applying to commercial vessels of 5,000 gross tons and above, it is important to understand that FuelEU Maritime is not addressing how much carbon these ships emit, but rather the carbon content of energy being used on board. Put simply, even if a ship were to dramatically reduce fuel consumption, thereby proportionally reducing CO2 emissions, it could still be non-compliant. As such, while wind propulsion systems are considered favourable on account of being an energy source, other energy efficiency systems – air lubrication systems for instance – are not because the gains apply only to efficiency, not energy. To reiterate, FuelEU Maritime centres around the energy used on board i.e. carbon content per unit of energy rather than fuel or carbon alone.

Very few of the traditional fossil fuels burned today – including MGO and LNG for Otto (4-stroke) medium speed engines – comply with FuelEU Maritime, so the bottom line is to increase the share of renewable and low-carbon fuels in the energy mix. Come 2025, ferry operators will need to ensure that their fuel distributors give them a low blend of bio- or synthetic fuels in the regular fuel…or find other solutions to meet the requirements. Energy storage from onshore power supply (OPS) is one such possibility. This is the strategy that many ferry operators are already pursuing, but electric propulsion and an Energy Storage System (ESS) will be prerequisites when using OPS to comply with FuelEU Maritime. Relying on shore electricity simply for the hotel load while at berth will in most cases not be sufficient to meet the requirements, because the annual energy consumption at berth is relatively low compared to the total energy used onboard. Since OPS facilities are missing in many ports, especially in the Mediterranean, Interferry is urging EU member states to use money from the Emissions Trading System (ETS) to upgrade port electricity infrastructure. Alternatively, ETS money could be granted to fuel producers and suppliers to increase biofuel or e-fuel production. With billions of euros flowing to the EU ETS, the least distortive way to obtain a relatively modest share of it would be to electrify ports as well as bringing compliant fuels to the market.

FuelEU Maritime itemises a gradual reduction of carbon content. When introduced in 2025, a 2% reduction will apply when benchmarked against the 2020 reference value of 91.16gCO2eq/MJ. This will increase to 6% by 2030, 31% by 2040 and 80% by 2050. Non-compliance will be penalised, but the system is somehow fair in that the reduction targets do not have to be met on an individual ship basis. An operator or group of operators can pool a fleet of ships, so if one ship runs at, say, 50% lower carbon content, there is a surplus that can be used to offset or bank other ships in the pool. As FuelEU Maritime kicks in only about 13 months from now, we recommend our members to get prepared as soon as reasonably practical.

Meanwhile, with energy efficiency at the heart of a lightweight craft design, Interferry is pushing hard to have them included in a new High Speed & Light Craft Code, which takes out the minimum required speed currently imposed by the HSC Code. The rationale behind modifying the HSC Code to a High Speed & Light Craft Code is that it will pave the way to build many more lightweight craft than is now the case, resulting in overall reduced fuel consumption and GHG emissions. Interferry is addressing the issue at both EU and IMO levels. We expect to make good progress during 2024, as policymakers realise that sticking to the HSC Code’s threshold speed is no longer relevant in times when it’s all on hands on deck to reduce GHG emissions.

The 80th session of the IMO’s Marine Environment Protection Committee (MEPC 80) was held July 3-7. Please note the report from our friends at DNV.

This session was beforehand described by green NGOs as the last opportunity for the IMO to come to an agreement that would align international shipping with the 1.5-degree target outlined by the Paris Agreement. For this reason, Member States were hard at work finding a compromise that would eventually please none but satisfy many. It was important for all stakeholders to reach an agreement. If not, we risked that much needed technical discussions would have been put on hold. Speaking for the maritime industry, we have really been sitting on our hands for the past few sessions of the MEPC, just waiting to see enough loose ends tied up together into a coherent framework for shipowners to have enough info to make informed decisions. Although getting closer, we are not quite there yet.

On the overall IMO ambition, we saw a new set of more stringent targets. A reduction of well-to-wake GHG emissions by 20%, striving for 30% in 2030 was more or less what we were already aiming for. However, a whopping 70% reduction, striving for 80%, in 2040 compared to 2008 wasn’t on our radar. The bottom line is to reach net-zero “by or around 2050”. It is not yet quite quantifiable what these figures mean in terms of per-ship-improvements between now and 2030/2040. Given the uncertainty surrounding the CII we may well see draconian measures needed already towards the end of this decade to meet this ambitious goal.

The information to collect and report for the IMO Data Collections System (DCS) will be more comprehensive as from 2026, also including a more granular description of the energy used on board (sources and application). With a few more iterations one could hope for a harmonisation between the EU MRV system and the DCS, so that operators will only have one set of parameters on which to report.

Seeking compliance alternatives for the various GHG requirements under both the IMO and the EU, operators are asking questions on how biofuels and synthetic fuels (e-fuels) will be credited in the various frameworks. An important step to answer this was made by MEPC 80 that agreed on interim guidance (to be issued as MEPC.1/Circ.905) for the use of biofuels. The guidance takes its inspiration from what has been done by ICAO (International Civil Aviation Organization) and even refers to ICAO’s Approved Sustainability Certification Schemes and the CORSIA Sustainability Criteria (Chapter 2) for CORSIA Eligible Fuels. However, one would expect a more in-house set of parameters to be developed.

Under the ICAO approach, a biofuel needs to provide a well-to-wake GHG emissions reduction of at least 65% compared to the well-to-wake emissions of fossil MGO of 94 gCO2e/MJ and meet a number of sustainability criteria (e.g. what type of biomass may be eligible). This approach is similar, but not exactly corresponding, to the criteria and parameters established in the EU’s Renewable Energy Directive II (RED II). This means that a biofuel certified for CII improvement will not necessarily be recognised by the EU ETS and vice versa. But let’s not be too critical and rather note that with the complexity of tying up all loose ends we need to be supportive when things do move forward.

The meeting also made progress on the ‘Guidelines on lifecycle GHG intensity of marine fuels (LCA guidelines)’. Even so, more work is required and has therefore been tasked to a Correspondence Group. So, for the time being there is still no clear path how to credit e-fuels in the IMO setting. In the EU framework, the uptake of e-fuels (dubbed Renewable Fuels of Non-Biologic Origin or RFNBOs) is actively encouraged and actually rewarded with a double credit; for every gram of GHGeq reduced through RFNBO, you are credited two grams.

Overall, IMO’s MEPC 80 made a lot of progress, but given the ambitious targets Member States have set for themselves, the IMO is struggling to keep up. Haste often makes waste, resulting in poorly developed regulations – did I hear anyone say CII…?

Concerns have been raised over ferries carrying Battery Electric Vehicles (BEVs) as there have been instances of catastrophic failure in the vehicle’s battery pack, resulting in fires that cannot be extinguished. The efficacy of conventional seawater drencher systems in relation to BEV fires has been evaluated under the auspices of LASH FIRE, an EU research project aimed to significantly reduce the risk of fires on board ro-ro ships by developing and validating effective operative and design solutions. Interferry is a member of the LASH FIRE project which runs from September 2019 to August 2023.

LASH FIRE tested a fixed water-based extinguishing or drencher system on a simulated ro-ro deck in relation to thermal runaway fire in a BEV. The drencher system was capable of containing the fire and the overall risk of carrying BEVs should be considered equivalent or lower than that of Internal Combustion Engine Vehicles (ICEVs), providing the drencher system is correctly operated and designed in accordance with SOLAS.

Relative to the total number of vehicles, the number of BEV fires is lower than that of ICEV fires. Even so, stringent measures related to the carriage of BEVs have been discussed, all the way from the installation of additional fire-fighting capabilities, to segregating BEVs on board or an outright prohibition of carrying BEVs on ro-ro decks. This stance is partially due to the fact that it is very difficult to extinguish a fire within a battery pack as a) the plastic housing of the battery pack itself acts as a shield for the extinguishing agent (e.g. water); b) the battery pack will also be shielded by the vehicle’s body and c) the chemical components within the battery cells provide a very high density energy source to sustain the fire locally. This shielding effect is mostly relevant if the fire starts in the BEV’s battery, typically caused by a short-circuit, leading to a so-called thermal runaway. When the fire does not originate in the battery, the suppression activities will hinder fire spread and significantly reduce the risk of a thermal runaway. When stowed adjacent to a vehicle that catches on fire, a BEV may also catch on fire, but in this scenario the consequences are not worse than if it were a petrol or diesel car by virtue of the unlikeliness of the BEV’s battery experiencing a thermal runaway. In fact, a non-battery related fire in a BEV will likely release less heat than one involving liquid fuel in a tank as a plastic fuel tank will catch fire much faster than a Li-ion battery.

What follows are some key findings of LASH FIRE’s test series, comparing the fire suppression performance of a drencher system for fires involving ICEVs and BEVs, respectively. The tests simulated a ro-ro space with a 5m ceiling height with a fire suppression system design in line with IMO’s revised guidelines for the design and approval of fixed water-based fire-fighting systems for ro-ro spaces and special category spaces (MSC. 1/Circ. 1430/Rev. 2). Representative of today’s modern vehicles, two pairs of geometrically similar SUV-type ICEVs and BEVs were used in the tests. The tests illustrated that while the BEV fires presented a different fire scenario to those of an ICEV fire, the performance requirements of existing fixed water-based extinguishing systems on both closed and open ro-ro decks were sufficient to contain a BEV fire, at least to a level equivalent of an ICEV fire. A fuel spill fire associated with an ICEV develops very rapidly, peaks high but burns out fast, whilst a fire starting in the battery pack of a BEV develops slower, is not as large – resulting in a lower heat release – but burns longer. The scenario of the fire in other combustibles such as tires, exterior and undercarriage plastic parts and inside the car is similar. As the drencher system was capable of containing the fire, the tests clearly illustrated that the overall risk of carrying BEV vehicles should be considered equivalent or lower than carrying ICEVs. As for the latter vehicle type, there is the additional risk of the fire spreading horizontally, i.e. when a fuel tank ruptures, burning fuel on the deck risks to spread under the adjacent cars.

As drencher systems are able to contain a BEV fire and prevent spread to other vehicles, we recommend our members to not make any special provisions for carrying BEVs, and even charge them if that’s an option, provided that equipment and training are compliant the requirements in SOLAS and ISM – which they of course always have to be!

LASH FIRE recently held a webinar on the subject of a drencher system’s efficacy in relation to BEVs which can be viewed in the video below.

Our Director of Regulatory Affairs, Johan Roos, participated in the 9th session of the IMO’s Sub-Committee on Ship Systems and Equipment (SSE 9), held in London 27 February to 3 March. SSE 9 was the last round of technical discussions with the draft amendments to be submitted for approval to the upcoming 107th session of IMO’s Maritime Safety Committee (MSC 107) later this spring (31 May-9 June). Once rubberstamped by MSC 107, the amendments to the SOLAS Convention and related codes are expected to enter into force come 1 January 2026.

Please note the summary report from our friends at DNV.

SSE 9’s highlight relative to the ro-ro passenger ferry sector was the finalized draft of new SOLAS requirements to minimize the incidence and consequences of fires on ro-ro passenger ships. SS9 also finalized the draft of interim guidelines on the safe operation of onshore power supply (OPS) facilities.

In the wake of a few major fire incidents on vehicle decks of ro-ro passenger ferries, IMO has put its shoulder to the wheel to reduce the risk of fire and the spread of it in ro-ro and special category spaces on new and existing ro-ro passenger ships. SSE 9 finalized several draft amendments to SOLAS Chapter II-2 (Construction – fire protection, fire detection and fire extinction), the International Code for Fire Safety Systems (FSS Code) and MSC.1/Circ.1430 (Revised guidelines for the design and approval of fixed water-based fire-fighting systems for ro-ro spaces and special category spaces).

All in all, Interferry is positive about the outcome of the SSE 9 deliberations on ro-ro passenger ferry fire protection for both existing and new ships (existing ships are those built before 1 January 2026). One of the key topics of discussion concerned the requirements for retroactive fire monitors on weather decks. Over the years we have successfully steered the discussions away from technical retroactive requirements, and only accepted that weather decks on existing ro-pax ship should be protected by fire monitors, i.e. water cannons, and detection systems.

While the member states have shown a general willingness to provide flexibility to the actual performance requirements for existing ships, repeated attempts have been made to push the standards-to-be for existing ships to approach the (pending) standards for new ships. What’s on the table now offers reasonable flexibility for existing ships while at the same time ensuring a reasonable protection of weather decks going forward. In short, to protect areas on weather decks intended for the carriage of vehicles, passenger ships built before 1 January 2026 shall be equipped with a fixed water-based fire-extinguishing system based on monitors. As far as practicable, these monitors shall be located in positions which ensure unobstructed protection of vehicles in the area on the weather deck intended for the carriage for vehicles and as make use of existing pipes and pump capacities.

In recent years, there has been a great deal of controversy with regard to side openings on ro-ro passenger ferries. Suffice it to say that side openings will continue to be allowed also in new designs, provided there is appropriate fire protection rating (A-60) of the superstructure above the openings. This is one of the lessons learned from the NORMAN ATLANTIC disaster with certain of our members already having voluntarily implemented the protection of life-saving appliances (LSAs) located above side openings by welding the openings shut.

Side openings, but also the ends or deckheads of ro-ro spaces, shall have to be situated and arranged in such a way that a fire in the ro-ro space shall not endanger stowage areas for survival craft, embarkation and assembly stations as well as accommodation spaces, control stations and normally occupied service spaces in superstructures and deckhouses above the ro-ro space. Exemptions will apply, e.g. when openings are fitted with closing arrangements such as steel ramps and doors, when protected by steel or other fire-resistant closing devices, or as mentioned before, when the fire integrity of the ship’s side, including windows and doors, boasts A60 insulation.

The limitation of safety distance on the weather deck has been yet another hot potato for some time. Safety distance between the ship’s structural elements and the cargo stowed on the weather deck should guarantee access to assembly stations and LSAs in case of a fire event. The higher the safety distance, the more cargo stowage space on the weather deck is lost. So, we were rightfully concerned about the safety distance principle as it risked to significantly limit the cargo/vehicle stowage space on the weather deck, bearing in mind that almost every vertical structure (accommodation, side casings, funnels, storage, etc.) would require a safety distance from the stowed vehicles, despite these vertical structures already being subject to fire rating requirements.

For the side casings, the member states have agreed that unless there are spaces within the side casings which are normally manned, there is no need for a safety distance in relation to the vehicle area, effectively ensuring full transversal utilisation of the weather deck. Still, a horizontally measured safety distance of minimum 6m will apply between the designated vehicle lanes and some of the ship’s structural elements such as accommodation spaces, control stations and normally occupied service spaces in superstructures and deckhouses adjacent to the weather deck. However, there are provisions in place to reduce the safety distance to 3m if complemented with a fixed water-based fire-fighting system.

Last but not least, SSE 9 also finalized the draft of interim guidelines on the safe operation of onshore power supply (OPS) service in port. The draft of the interim guidelines, which will be submitted for approval to MSC 107, intends to prevent accidents caused by operational errors in relation to ships’ connections to shore power.

We will keep you posted on the outcome of MSC 107!

During June 6-10, 2022 the IMO Marine Environment Protection Committee (MEPC) held its 78th session.

Please note the summary report from our friends at DNV.

Regarding the issues at the forefront for ro-ro cargo and ro-ro passenger ship operations, MEPC 78 finalized the Energy Efficiency Existing Ships Index (EEXI), the Carbon Intensity Indicator (CII) and the Ship Energy Efficiency Management Plan (SEEMP) regulations, all entering into force in 2023. These instruments have been developed in Correspondence Groups and through a large number of virtual inter-sessional meetings. Effectively, the regulations were agreed in principle six months ago and MEPC 78 concluded on the supporting calculation guidelines.

Interferry members report that compliance with the EEXI requirements seems reasonably feasible. All ships need to have their EEXI technical file approved before the first annual, intermediate or renewal International Air Pollution Prevention Certificate (IAAP) survey or the initial International Energy Efficiency Certificate (IEEC) survey on or after 1 January 2023.

For the CII, the capacity parameter for ro-ro cargo ships was aligned with that for ro-ro passenger ships and changed to gross tons – on Interferry’s request.

The first reporting of the CII based on 2023 data is due no later than 31 March 2024, after which corrective action should be taken by D- and E-rated ships. However, as expressed numerous times by Interferry, the CII is not well suited for diverse segments such as ours. We see a pronounced spread, particularly in the ro-pax fleet, with a large number of individual ships falling into the D- or E-rating band – thereby forcing corrective actions that we deem unrealistic for such vessels.

Fortunately, Member States seem to have caught up to the shortcomings of this regulation, which blindly tries to establish how much fuel a given ship should consume and goes on to retroactively penalise those that do not fit this narrow template.

Interferry therefore recommends its members to stay in close connection with their Classification Societies and Flag States and establish early dialogue on their expectations for the CII’s initial three-year stint, pending the review that has already been announced for 2026.

Finally, and as a testament to how all-encompassing the Green House Gas deliberations have been for the past three years, MEPC 78 also approved a proposal for a Sulphur Emission Control Area (SECA) to be established in the Mediterranean Sea, an issue that has barely been noticed by most. The final go-ahead for a Med SECA is tasked to MEPC 79 in December.

During October 4-8, 2021 the IMO Maritime Safety Committee held its 104th session.

Please note the summary report from our friends at DNV.

Due to the pandemic, the IMO’s deliberations continue to be disrupted and quite a backlog is building up for dealing with issues at hand. The Committee decided that no proposals for work output will be taken onboard until Nov 2022 (MSC 106) the earliest.

From a ferry perspective, the most important item discussed by MSC 104 was the further development on the draft Model Regulations for domestic ferry safety, an area which Interferry has been heavily engaged over the years.

While domestic operations are outside the scope of the IMO’s responsibilities, MSC 104 approved non-mandatory model regulations on domestic ferry safety. A draft MSC resolution on the adoption of the model regulations will be considered by MSC 105 (April 2022).

More than 95% of ferry casualties world-wide occur on domestic operations in countries that do not directly, or indirectly, follow SOLAS and ISM, and as Interferry we are very pleased to see this strong development with a real potential to address true shortcomings in ferry safety.

Please note the brief from our friends at DNV.

After intense discussions on mandatory technical and operational requirements to reduce CO2 emissions from international shipping, MEPC 76 adopted MARPOL amendments including EEXI, SEEMP and CII.

We can note that the EEXI seems to be feasible for most ferries, and for non-compliant ships the option of engine power limitation should be a practical solution. All international ships need to have their EEXI verified by the first renewal survey after 1 January 2023.

Comprehensive calculation guidelines have been developed for the CII, but its application is not as straightforward as the EEXI and – importantly – the consequences of not meeting CII requirements are very uncertain. Currently the IMO Member States seem to favour ‘soft implementation’, but how individual States enforce the approach is as yet unknown.

MEPC 76 agreed on CII reduction rates up until 2026 – providing an 11% improvement compared to 2019 – but could not conclude on the full period until 2030, which is the first target year for the short term measures agreed by the IMO in 2018. Member States were very far from each other on their target reductions by 2030, with some opting for 10% and others wanting beyond 50%. This uncertainty adds to Interferry’s major concerns over the implications of the CII for such a diverse segment as the ferry industry. While we might agree that the world’s merchant fleet can on average improve by 11, 20 or even 30% over the coming decade, we must note that, within our sector, we have individual ships that are more than 60% off the starting point and therefore need to find such an improvement before even considering how to meet the yet-to-be-finalised eventual CII target.

With a heavy agenda of high-level issues, MEPC 76 was unable to address the many technical and practical details that need to be resolved. To this end, a Correspondence Group was established and will begin work in early July to be concluded by end-August. Interferry will focus on two principal issues within the CG: (1) how to deal with High Speed Craft in the CII framework; and (2) how to distribute the CII burden within the ro-ro cargo segment – which is so diverse that some ships, simply due to their main dimensions, risk taking on a disproportionate share of the overall burden.

European Union proposals

Alongside the outcomes from MEPC 76, further details have been circulating among industry sources about a unilateral European Union initiative known as Fuel EU Maritime. It must be stressed that the information below has not been verified by any public announcements from the EU Commission, but this potential regulation – in combination with the IMO developments – would be of fundamental significance for our industry.

What is known is that the pending regulation will be applied to all ships >5,000 GT operating from an EU port (i.e. also for domestic operations) and will consist of several parts:

  • Fuel standard
    Gradual introduction of low-carbon content fuel, similar to what is already in place for road fuels. In relation to the 2020 GHG content of maritime fuels used, improvements have been set at 2% by 2025, 6% by 2030, 13% by 2035, 26% by 2040, 59% by 2045 and 75% by 2050
  • Mandatory use of On-shore Power Supply (OPS) at berth
    From 1 January 2030, containerships and passenger ships will have to connect to OPS and use it for all energy needs at berth. Until 2035, ships that cannot connect due to lack of compatible port infrastructure will be exempted, but from then on such exemptions will only be tolerated five times per year. As far as is known, there is no commensurate requirement that the ports are obliged to provide the OPS facility
  • Monitoring, reporting and verification
    The current MRV scheme will be further expanded, with declaration of well-to-wake emission factors, higher resolution of when fuels were used (i.e. different phases of the voyage) and the introduction of ‘compliance units’ forming the basis of a future emissions trading system
  • Penalties
    It is unclear if the EU can actually introduce mandatory penalties for non-compliance, but the draft proposal includes harsh fines for a ferry not connecting to OPS when in port

During May 5-14, the IMO Maritime Safety Committee held its 103rd session. Please note the summary report from our friends at DNV.

Due to the pandemic, the IMO’s deliberations have been somewhat disrupted and no new work outputs are currently taken onboard. Three hours’ worth of on-line deliberations per day is far less time than normally allocated for the Committee.

Much of the discussion revolved around autonomous ships, where ferry operations are highly relevant both as technical platforms for testing and with a view to complement current safety systems with more advanced automated collision and grounding avoidance systems.

As is well known, the IMO takes its time when it comes to developing new international requirements and the development of autonomous ships technologies is well ahead of the regulatory process. This is all in good order, but it should be recognized that companies wishing to proceed with autonomous solutions will rely heavily on guidance from interested Flag States and Classification Societies.

From a ferry perspective, the most important item discussed by MSC103 was the development of a new instrument for domestic ferry safety, an area which Interferry has been heavily engaged over the years.

Thanks to a strong initiative by China, supported by many other countries, some of which also afflicted by poor domestic ferry safety, the IMO is developing so called Model Regulations for Domestic Ferry Safety, which may serve as a non-mandatory for countries wishing to upgrade their current set of requirements, enforcement tools and governance.

There is apprehension amongst some prominent Member States, as they are concerned that the IMO is moving in on domestic sovereignty, an argument which Interferry cannot fully understand, as the IMO does not have the power to regulate anything. This is an attempt to provide support to countries that have fallen behind, which has nothing to do with countries who have already got their house in order.

More than 95% of ferry casualties world-wide occur on domestic operations in countries that do not directly, or indirectly, follow SOLAS and ISM, and helping countries move towards the high international requirements should be at the very top of IMO’s agenda.


In 2018, international shipping became the first industry segment to reach an accord on greenhouse gas (GHG) emissions. The IMO’s 180 Member States committed to a global 40% energy efficiency improvement by 2030 and a 50% improvement in absolute CO2 emissions by 2050 as compared to 2008 values.

Historically, the IMO regulatory framework has evolved around a few ship types – bulk carriers, tankers and containerships – that represent the majority of world trade and therefore most of shipping’s CO2 emissions. However, the methodologies developed for homogenous deep-sea vessels do not necessarily fit well with the much more diverse segment of ro-ro ship types, which have very different capabilities in reaching CO2 reductions.


The IMO has set 1 January 2023 for the implementation of two new compliance instruments – the Energy Efficiency Existing Ship Index (EEXI) and the Carbon Intensity Indicator (CII). Under this extreme timescale, all discussion and ratification is to be finalised by June 2021.


This is basically a copy/paste of the Energy Efficiency Design Index (EEDI) introduced for new designs since 2015. Existing ships will likewise have to be certified to a technical efficiency standard, or lose their licence to operate. The EEXI is highly unusual in being a retroactive requirement – it obliges ships built before EEDI Phase 2 (from 2020) to match this level. An EEXI Technical File recording a ship’s emissions reduction rates must be in place by the first annual, intermediate or renewal survey after 1 January 2023.

Put simply, the EEXI is a measure of a ship’s installed power and its speed when using a given proportion of this power. For ships that exceed EEXI restrictions, the most common mitigating measure will be Engine Power Limitation (EPL), a system that suppresses main engine rpm except in emergency situations. EPL will likely enable an average speed reduction among single-engine vessels, but is unlikely to improve the operational profile of most ferries, which require significant power redundancy through multi-engine installations.

Due to the uniquely diverse range of ro-ro type designs and operations, Interferry has always maintained that the EEDI is not a fair way to regulate energy efficiency for newbuilds, so it would be correspondingly inappropriate to impose the same methodology on existing ships. The IMO has recognised this by agreeing that the EEDI Phase 2 reduction rate for ro-ro cargo and ro-ro passenger ships should be only 5% more stringent than Phase 1, as opposed to the 20% mandated for most other shipping segments.


In addition to one-off EEDI or EEXI technical certification, ships must thereafter conform to the CII, a continuous improvement plan for operational efficiency. A ship’s annual output of CO2 per ton per nautical mile will be documented and compared with the average performance for that ship type in the base year 2008, with a general requirement to better the 2008 value by 40%. A ship that falls short must improve performance during the following year(s) until it meets the target.

This can be achieved in several complementary ways, typically by reducing fuel consumption through technical and operational measures. Since the target is to reduce CO2 output, it will also be particularly relevant to explore solutions such as low-carbon fuels, hybrid propulsion and using shore power at berth. As such, the introduction of the CII will affect the operational profile of many ships.


Given how quickly these new instruments have had to be developed, some fundamental challenges still need to be resolved at two upcoming IMO meetings, each being held remotely. The inter-sessional working group on GHG reductions will meet from May 24-28. The deliberations then conclude at the Marine Environment Protection Committee meeting from June 10-17 (MEPC76).

Interferry has submitted the following special requests to these sessions:

  1.  High Speed Craft are currently bundled up with conventional ro-pax ships in the CII dataset. Interferry wants separate treatment for HSC because they are a fundamentally different ship type whose energy efficiency cannot be measured on the same basis as mono-hull steel ships
  2. The dataset for ro-ro cargo ships includes the con-ro sub-segment. This really skews the statistical average since almost all the large ships – more than 25,000 DWT – are con-ro vessels, making CII compliance all the more difficult for pure ro-ro cargo ships. Interferry has therefore proposed that the ro-ro cargo fleet is defined in two parts, below and above this tonnage
  3. Development of the CII included discussions on how to measure capacity for the different ship types, but a decision has yet to be taken. Interferry has requested that GT rather than DWT should be used for all ro-ro types, after conducting analysis showing this was a fairer basis for implementation on such vessels


MEPC 76-7-14 – Establishing High Speed Craft as a new sector in the CII framework

ISWG-GHG 8-3 – Choice of metrics for capacity for ro-ro cargo ships and using a GTDWT-distinction for the ro-ro cargo sector

Interferry sets out guidelines for COVID-19 restart of passenger services

After collecting a large number of suggestions on how to mitigate the spread of COVID-19 in relation to ferry operations, a task force of Interferry members has identified the key measures necessary to support the safe, gradual start-up of suspended passenger services during the pandemic.

The guidelines are available here in PDF format.

Designed to ensure social distancing and enhance sanitisation, the guidelines cover shoreside and shipboard measures to protect passengers, staff and crew ranging from booking, check-in and boarding procedures to onboard limitations in passenger numbers and facilities.

Due to the large diversity in ferry operations, both onboard and ashore, we have focused on high-priority issues as visualised in the flowchart (pg. 2 in the guidelines PDF), but also encourage each operator to develop solutions that are bespoke to their own businesses.

Interferry supports the widespread implementation of measures but does not advocate any new regulations. Our aim is to work closely with operators, port authorities, flag administrations and other stakeholders to encourage confidence that passenger ferry travel can resume as soon as possible.

The measures have already been shared in draft format with several national administrations and also discussed in a conference call with the European Commission. The call on May 4 took place between Commissioner for Transport Adina Valean, members of her cabinet and five Interferry representatives – CEO’s Götz Becker of Germany-based FRS, Niclas Mårtensson of Stena Line, Christophe Mathieu of Brittany Ferries and Spiros Paschalis of Greece’s Attica Group, together with myself. The Commissioner expressed high appreciation of the extensive input and confirmed that it would be considered in her preparations for an announcement due on May 13 regarding recommendations for relaunching transport links.

It is likely that certification of enhanced measures to mitigate communicable diseases will be introduced on a voluntary and subsequently mandatory basis. We are heavily involved to ensure that any suggested or imposed measures are relevant, reasonable and do in fact support a restart of suspended services.

Johan Roos – Director of Regulatory Affairs, Interferry

Please note the excellent summary report from our friends at DNV GL.

Building on already very good fire safety regulations, work to further improve measures on ro-pax vessels continued at the IMO last month when SSE7 – the seventh annual session of the Ship Systems & Equipment sub-committee – set out to draft SOLAS amendments due in force from 1 January 2024.

Interferry was represented by Darren Johnston of BC Ferries, the outgoing Chair of our fire safety working group; Stena’s Lisa Gustin, the incoming Chair; our Regulatory Committee Chair John Garner, of JG Maritime Solutions; Palle Jensen, from Scandlines; and myself.

Interferry, the International Chamber of Shipping and the Royal Institution of Naval Architects had submitted a paper stressing that some of the EU proposals that were still options to become mandatory had been proven as not cost effective – by the EU’s own FIRESAFE II study – while others had not been properly discussed in the sub-committee.

In particular this related to:

  • the proposed prohibition of so called open ro-ro spaces
  • the prescriptive safety distances for lifesaving appliances relative to openings
  • the proposed mandatory transverse walkways every 40 metres on ro-ro decks

Eventually, a great deal of progress was made in steering clear of unjustified mandatory requirements, but two key issues could not be resolved – the open spaces proposal and how to assess which requirements should apply to existing (pre-2024) ships. Consequently, all such outstanding items were referred to a correspondence group for ongoing discussion until reporting to SSE8 next March.

Finally, it should be noted that the carriage of Alternatively Powered Vehicles – electric, hydrogen, LNG and so on – is a rapidly emerging issue. As such, we can expect this to be established as a new agenda item by the next IMO Maritime Safety Committee in November 2020.

Johan Roos – Director of Regulatory Affairs, Interferry

Please note the excellent summary report from our friends at DNV GL.

The IMO sub-committee for Pollution Prevention and Response in February 2020 saw very detailed discussions regulations for prohibiting the use and carriage of HFO as fuel in the Arctic, revised the guidance on ballast water system commissioning and – for the ferry industry – a very welcome discussion on scope of work for the impact of EGCS discharge water on the environment.

This last point is a constructive way to try to harmonize different countries’ practices for the discharge of scrubber water, in their ports and coastal areas. After the strong encouragement by the EU Commission back in 2012-2015, for ship owners concerned with the 2015 SECA rules, to install scrubbers as a compliance method, there has been a push back by some member states, considering the current discharge rules to be too lenient / uncertain.

The EU COM and the EU Member States have now finally taken the right step and put the question to the IMO if it can develop harmonized rules for such discharges. Interferry’s position is that any regulations need to be fact-based and that the general grandfathering principles in IMO instruments shall prevail, meaning that compliant scrubbers installed in good faith shall continue to be allowed to be operated also in a revised regulatory regime.

A cross-industry assessment on the accumulation of detrimental substances from ship scrubbers was presented to PPR 7. The study shows that even at relatively high loads of scrubber usage for berthed ships, the long-term effects are very small. This is one of several studies on the topic and PPR 7 invites for additional submissions providing more facts, to next year’s PPR 8.

Johan Roos – Director of Regulatory Affairs, Interferry

With climate change now redefined as The Climate Emergency, the political will to take action on maritime greenhouse gas (GHG) emissions has developed dramatically over the past few months. This follows previously agreed IMO mandates for a global 40% energy efficiency improvement by 2030 and a 50% improvement by 2050 as compared to 2008 values.

Towards these targets, the IMO has proposed short-term measures to be implemented by 2023. The suggested measures include not only stricter requirements on the Energy Efficiency Design Index, shaft power and speed, but also a retroactive application – meaning that existing ships will need to be adapted to meet the efficiency standard of new designs. More so than in any other shipping segment, the viability of existing ro-ro and ro-pax vessels will be at risk if such proposals fail to recognise the sector-specific dictates of ferry design and operation.

The ferry sector is already widely acknowledged as the shipping industry’s leader in the drive towards zero emissions. Long before the IMO’s latest regulatory proposals, many ferry operators have embraced their societal role in helping to protect the planet by taking it upon themselves to decarbonise. However, while clearly supporting the general objective of environmental sustainability, Interferry is concerned at the unprecedented potential restrictions now facing the ferry community. We are currently preparing submissions for imminent IMO meetings, where we will provide our input to ensure that the solutions taken forward are ferry-appropriate.

Meanwhile, as background guidance for members, we present the following interview with Poul Woodall, environment and sustainability director at DFDS and chair of Interferry’s GHG Working Group.

Q: Greenhouse gases have been on the IMO and European Union agendas for a long time, so why do things suddenly seem so urgent?

PW: These are unprecedented times not just for the ferry sector but for the shipping industry in general. We have never faced a challenge like this. The reason it’s so urgent is due to the timetable the IMO has imposed on itself, particularly under pressure coming from the EU.

GHG has been on the agenda for quite a while, but now we have a deadline of 2023 to implement a number of short term measures. That’s a very short time in the workings of the IMO. We must decide what the measures are, how we measure them and how we police.

The big one is the energy efficiency index for existing ships – EEXI – combined with the operational efficiency target. EEXI covers the physical as opposed to operational aspects of an already existing ship. It’s the next step towards 2030.

Q: We already have technical efficiency requirements for new ships. Why can’t these be imposed on older ships?

PW: Newbuild requirements are a tough call, but we can’t apply them to existing ships in any reasonable way because they were built at different times to different standards. Furthermore, the newbuild requirements can be addressed from a design perspective, but you cannot reshape the hull of an existing ship.

Q: Is there anything particular to ro-ro and ro-pax ships that makes it more difficult for them to reduce their CO2 emissions?

PW: EEDI and EEXI will measure efficiency on the basis of a ship’s ability to carry weight. That’s not relevant to the ferry sector, where carrying ability is measured by volume. We must work out how to better measure ferries’ performance on this basis. Our definition of what makes an efficient ship has to be different because our cargo – which includes passengers – is so different to the majority of ships.

Q: Can’t operators just slow down to improve their performance per passenger or cargo unit transported?

PW: The speed issue has two aspects. The first is technical – and just slowing down doesn’t necessarily make a ship more efficient. But there is another side to this. The ferry business is part of the infrastructure of society. It’s like a bus service – and that’s not more efficient if you slow down and have to adjust timetables. We don’t have the option to go slower because of the product we offer to society. In this respect there is wide recognition that ferries are a special case, but authorities are increasingly looking at ways to tap into every potential.

Q: Is the IMO timeline realistic?

PW: Shipping in general will never get to the 2050 objective – a 50% reduction in absolute terms as compared to 2008 – with the way the industry is today. I’m fairly confident we will achieve the 2030 target for a 40% improvement on relative efficiency with current technology, but for 2050 we will need fossil-free fuels. The question then is about what the fuels will be and what can be scaled up to the requirements of maritime transport.

Q: What happens if the EU is not satisfied with the outcome of the IMO’s work?

PW: In November the new EU Commission said shipping should be part of the EU Emissions Trading Scheme (ETS) and said it would implement its own system. By June 2020 it will come up with specific proposals. In my opinion that would be a disaster because it’s a regional solution and shipping is global. Making local regulations disturbs the whole competitive playing field.

Q: What must Interferry do to support a positive outcome on these rapid developments?

PW: The speed with which new regulations are being proposed makes this a very complex situation. It must not be rushed through. We have to make sure that we have covered all the bases, but time is short – the next meeting of the IMO’s Marine Environmental Protection Committee takes place in the first week of April.

Interferry is highlighting the special challenge to our sector not only at the IMO and EU but also to the rest of the shipping industry. We are trying to communicate what needs to be looked at differently. There is no doubting the need for the next package of regulations, but we want the commercial realities of the ferry industry to be taken into account when setting the targets and measuring the improvements. You can’t change everything with one big brush because one size does not fit all. For existing ro-ro and ro-pax vessels to comply, it’s all about the metrics.

Further details are available in the following documents:

An online workshop document prepared by Interferry’s GHG Working Group

An Interferry briefing on the EU Emissions Trading Scheme

During June 5-14, the IMO Maritime Safety Committee held its 101st session. Please note the excellent summary report from our friends at DNV GL.

From a ferry perspective, I can complement DNV GL’s summary by noting that much time was spent on discussing fuel safety issues ahead of the 2020 global sulphur cap and the development of interim guidelines for testing of autonomous ships, none of which have any implications that are specific to the ferry industry.

The MSC approved new draft interim guidelines on ro-pax fire safety, which is an area where Interferry has been very engaged over the past few years. Together with industry partners, Interferry raised concerns that some aspects of the guidelines where not well enough discussed and although voluntary in nature, guidelines should avoid recommending construction measures unless properly justified.

For instance, the draft interim guidelines stipulates safety distances for Life Saving Appliances in relation to openings in ro-ro decks, but those very distances were taken from an EU study which clearly caveats that the distances need further research. It would be very unfortunate if a few new ships between now and the next proper SOLAS amendments follow such guidance when they can soon turn out to be inaccurate. Many member states shared the concerns raised by us and it is clear that application of the guidelines must be done in a pragmatic manner.

Building on a proposal originating in the UK to review the testing standards of life jackets, the MSC agreed to establish a new output called “The in-water performance of SOLAS lifejackets”. This has caused some concerns as to the perception of the safety levels of existing life jackets, but we must not avoid working with incremental improvement – even if some see a potential phase-out threat for the existing stock of millions of life jackets. The member states usually understand the implications of over-doing things.

By far the most exciting outcome of the session was that the MSC agreed to establish a new output on “Measures to improve domestic ferry safety” building on a proposal from China and with explicit support from the IMO Secretary General. Interferry has been working with the IMO for a long time, urging the organization to engage more deeply in domestic ferry safety in developing countries, since this is almost without exception where we see fatalities in the ferry industry.

With this new output and work plan established, we will have a much better defined platform for our continued involvement. I always say that over the past decades, the international community has invested 99% of its passenger ship related safety resources to address only 1% of the problem. Hopefully now we will see a strong turnaround.

Finally, many thanks to Serge Buy of the Canadian Ferry Association for standing in as our spokesperson for parts of the deliberations!

Johan Roos – Director of Regulatory Affairs, Interferry

MAY 2019 • Interferry Outcome of MEPC74

As a result of our partnership with DNV GL, Interferry is pleased to provide it’s members with DNV GL’s overview of IMO developments in their MAY 2019 IMO MARINE ENVIRONMENT PROTECTION COMMITTEE report and MAY 2019 TECHNICAL AND REGULATORY NEWS report.

With regards to the impact of MEPC74 on the ferry industry, Interferry’s Director of Regulatory Affairs, Johan Roos, highlights four developments:

  • Clear progress on current and future GHG requirements
  • The 2020 global sulphur cap
  • Discharge water from scrubbers
  • Potential new requirement for sewage treatment plants


The main take-away was that the Member States are beginning to resolve the political dimensions of the GHG issue, and now try to conclude how to assess and refine the various potential measures that could be imposed on the short term (already from 2023). Such measures include stricter EEDI, shaft power limitations, speed requirements, operational indices, etc.

As Interferry we will intensify the work in our internal working group on GHG, with a view to come to the next GHG Intersessional meeting in November, armed with proposals of our own on how to best proceed for our segments.

Among many potential items, it should be noted that non-conventional propulsion will be included into the EEDI framework, which means that (new) diesel-electric ferries will also need to meet a required EEDI. One important dimension in this context is that with the expectation that many ferries in the future will have some electric/hybrid arrangement, we will need to consider very carefully how to deal with the EEDI going forward.

We should also note that while some other segments have seen their EEDI timeline tightened, for ro-ro ships there has been no change as of yet. As the already agreed upon Phase 3 requirements for 2025 will be challenging to meet, we should begin to plan for a better option for the IMO than to just proceed to a new Phase 4 sometime in the future. It is possible that an operation requirement would be preferred over a design requirement that is not perfectly anchored in actual energy efficiency improvements.


For ferry owners and operators, the enforcement of the global sulphur cap of 0.5% as from 1 January 2020 will be a challenge, both financially and logistically, but there is nothing that affects ferries in any particularly distinct way compared to other segments.

In order to plan well in advance for switchover procedures, members are invited to note the ICS Guidelines on the matter.


Scrubbers (Exhaust Gas Treatment Systems – EGCS) were for a long time promoted by the EU Commission as an alternative means of compliance ahead of the 2015 introduction of the Emission Control Areas.

The EU Member States, however, have different views on to what extent discharge waters from EGCS shall be allowed within their respective waters. The IMO has now agreed to an EU request that the IMO should develop “harmonization of rules”.

MEPC74 duly noted that: “The tendency of States to introduce local or regional restrictions or prohibition measures was a worrying development, especially if no scientific background information or justification was provided.”

This matter is now scheduled to be completed by 2021 and from Interferry’s side we will offer our input to the process, while maintaining our position that:

  • Already existing installations – before a certain date (yet to be determined) – have been made in good faith and in compliance and shall not be affected by any future changes.
  • Any new requirements should be based on scientific facts.


MEPC74 agreed to review the possibilities in introducing monitoring and control mechanisms for the performance of Sewage Treatment Plants (STP) on board ships. This means that for all ships, including ferries, there will be a discussion on how to continuously demonstrate that the type approved STPs maintain their performance and also a requirement to log the use of STPs.

Previously, Interferry has been engaged on the establishment of the Baltic Sea as a special area, in which discharge of untreated sewage will soon be prohibited, for which the operators’ preferred solution is to discharge their sewage to shore facilities.

This recent development, however, relates to operators world-wide and the Interferry membership is invited to indicate how prevalent the use of STPs is and what performance standards they meet.