Revised MARPOL Annex VI Frequently asked questions:

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Revised MARPOL Annex VI: GENERAL: Does every ship need an IAPP certificate? Not, not every ship needs an IAPP certificate. Every seagoing ship of more than 400 GT which is either registered with a flag that has ratified the MARPOL Annex VI Convention or trading internationally needs an IAPP Certificate. (reg. 6 (1)). A definition of ship is given in MARPOL 73/78 art. 2 (4): a vessel of any type whatsoever operating in the marine environment and includes hydrofoil boats, air-cushion vehicles, submersibles, floating craft and fixed or floating platforms. Are ships under 400 GT exempt from MARPOL Annex VI? No. The regulations of MARPOL Annex VI apply to all ships, except where expressly provided otherwise in regulations 3, 5, 6, 13, 15, 18 and 19 (reg. 1). This means that even though the ship may not need an IAPP Certificate due to its tonnage, the regulations still apply and have to be complied with. The following list is to give you an overview:

Ships below 400 GT Ships of 400 GT and more

> >

Ships of 400 GT and more, trading > internationally Ships of 400 GT or more, trading > internationally and to which the following applies: First scheduled dry docking on/after 2010-07-01, but latest on/after 2013-07-01.

Compliance with Revised MARPOL Annex VI required Compliance with Revised MARPOL Annex VI and recurrent surveys required Compliance with MARPOL Annex VI and recurrent surveys and IAPP Certificate required Compliance with MARPOL Annex VI and recurrent surveys and NEW FORM of IAPP Certificate required

When will the revised MARPOL Annex VI enter into force? The revised MARPOL Annex VI has entered into force 2010-07-01. Will all ships have to be surveyed again in order to receive a new IAPP certificate? Yes, they will. A new IAPP certificate will have to be issued, following a MARPOL Annex VI survey according to the new regulations. Ships keellaid before the entry into force of the revised MARPOL Annex VI shall be provided with the new IAPP certificate no later than the first scheduled dry docking after the revised MARPOL Annex VI enters into force for the ships Administration, but no later than 3 years after this date. Ships keellaid after the revised MARPOL Annex VI enters into force shall have the certificate upon delivery (reg. 6).

Gerichtsstand und Erfllungsort ist Hamburg. Es gelten die Allgemeinen Geschftsbedingungen des Germanischen Lloyd SE in ihrer jeweils neuesten Fassung. Es gilt deutsches Recht. Place of performance and jurisdiction is Hamburg. The latest edition of the General Terms and Conditions of Germanischer Lloyd SE is applicable. German law applies.

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With Revised MARPOL Annex VI in force, will all ships need a new IAPP Certificate? Yes, they will. They need this new certificate latest upon their first scheduled dry docking after 2010-07-01, but in any case 2013-07-01 (Regulation 6.2). The certificate is issued following a survey according to the new regulations. Until this occasion, the old IAPP certificate remains still valid unless instructed otherwise by the flag State Administration. As per MEPC 194(61) in new IAPP Cert form in supplement items 2.3.1 & 2.3..2 should state applicable instead of valid. When does GL intend to amend subject certificates as per MEPC194(61). The amendments have entered into force on 2012-02-01 (MEPC .194(61), 3); (MEPC 1./Circ.757, 3). MEPC 1/Circ.757, 5 states: QUOTE: Member Governments are invited to use the revised form of Supplement to the IAPP Certificate when issuing the Supplement in accordance with the revised MARPOL Annex VI in line with the provisions of MSCMEPC.5/Circ.6 on Guidance on the timing of replacement of existing certificates by the certificates issued after the entry into force of amendments to certificates in IMO instruments, as appropriate*. UNQUOTE MSC-MEPC 5/Circ.6, 3.1 states: QUOTE: in cases where the ship has not to comply with new requirements, the certificate (and its supplement, if any) is not re-issued until its expiry; UNQUOTE If the IAPP certificate in question was issued before the entry into force date of the amendment, the certificate will be reissued upon expiry of the current certificate. Revised MARPOL Annex VI: Survey requirements What does the ship owner have to observe prior to the first survey for the Revised MARPOL Annex VI? A checklist for the ship owner can be downloaded from our homepage. Revised MARPOL Annex VI: OZONE-DEPLETING SUBSTANCES: Do ozone-depleting substances have to be removed? No. With regard to MARPOL Annex VI, existing installations may remain in use. Only for new installations, there are restrictions: new installations which contain ozone-depleting substances are not allowed on ships anymore, except that new installations containing hydro-chlorofluorocarbons (HCFCs) are permitted until 1 January 2020 (reg. 12 (2)). If ozone-depleting substances are used on board, and if the ships has an IAPP Certificate, record keeping of ozone-depleting substances is mandatory. A record book has to be kept on board, together with a list of equipment of ozone-depleting substances (reg. 12, 5, 6). The form of the record book is not prescribed, but the entries which are to be made are prescribed: Entries are to be made in kgs upon each recharge and discharge of ozone-depleting substances, and upon maintenance and repair of the system (reg. 12.7).

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Revised MARPOL Annex VI: MARINE DIESEL ENGINES: What is an EIAPP Certificate? An EIAPP Certificate is the abbreviation for Engine International Air Pollution Prevention Certificate. It is a document which shows that an engine complies with emission limits defined in regulation 13 of MARPOL Annex VI. An EIAPP Certificate is issued for an individual engine (serial-number based). The EIAPP Certificate comes with an approved IMO NOx Technical File. What is an approved IMO NOx Technical File An approved IMO NOx Technical File is a booklet of emission-relevant information about an engine, approved by an Administration or classification society on its behalf. Upon approval of the IMO NOx Technical File, the Administration of Classification society issues an EIAPP Certificate. The IMO NOx Technical Files generally contains three parts: Information about the engine group or engine family, emission test report; information about the on-board-verification of the engine. Who issues an EIAPP certificate and approves of an IMO NOx technical file? The Administration of the flag state the ship is flying assumes full responsibility in every case (NOx Technical Code 2.1.1.1 + 2.3.6). However, the Administration may delegate the survey and certification to Recognized Organizations then acting on the Administrations behalf (reg. 5 (3) (a)). GL is a Recognized Organization which is authorized to act on behalf of a number of flag states. Where can new EIAPP certificates/IMO NOx technical files be obtained in case of loss of original documents? Generally, in case of loss, new documents should be obtained from the entity that issued the original documents (NOx Technical Code 2.1.1.1 + 2.3.6, reg. 5 (3) (a)). It may be possible that GL reissues EIAPP certificates (but no restamping of Technical Files), even if the original documents were not issued by GL - provided no non-conformities with MARPOL Annex VI and the NOx Technical Code exist. If reissuance by GL is desired, a photocopy of both the approved IMO NOx technical file and the EIAPP Certificate including supplement should be submitted to GL in order to determine if reissuance is possible. Shall EIAPP certificates be issued on behalf of the flag state the ship is currently flying? Yes, they must (NOx Technical Code 2.1.1.1). This means that EIAPP Certificates have to be reissued upon flag change and have to be kept on board beginning with the first survey which is conducted under the new flag. Upon reflagging to a previous flag, the EIAPP Certificates can generally be reused (NOx Technical Code, Appendix 1), exceptions may apply, e.g. when the certificate form was changed. The approved IMO NOx Technical Files remain unchanged. If EIAPP certificates are reissued, the certificate number changes and does not correspond to the number in the technical file. Is that correct? Yes, it generally is. The EIAPP certificate number is a number for tracing the certificates. The certificate number of the first certificate ever issued for an engine, which also refers/corresponds to the approval number of the technical file, can be found on page 2 of the supplement to the certificate. The ship was keellaid before, and finished after 2000. Engines were built and installed after 2000. Do they need EIAPP certificates? EIAPP certificates are required for diesel engines with a power output of more than 130 kW which are installed on a ship constructed (=keellaid) on or after 1 January 2000, and for each diesel engine which undergoes a major engine conversion on or after 1 January 2000 (reg. 13 (1) (a)). Therefore, if engines were installed before completion of a ship keellaid before 2000-01-01, even if the completion was after 2000-01-01, and if the engines were not altered with regard to their emission relevant components and settings, they are not required to have EIAPP certificates or approved IMO NOx technical files. If they were altered with regard to their emission relevant components and settings (so called major conversion), EIAPP certificates and approved IMO NOx technical file are required.
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Does a GL ship necessarily have to have GL EIAPP certificates? No. EIAPP certificates issued by the Administration or another Recognized Organization are valid, correctness provided. (NOx Technical Code 2.1.1.1 + 2.3.6, reg. 5 (3) (a)). Why is an on-board-verification for the engines required? The on-board verification is required in order to confirm continued compliance with MARPOL Annex VI (NOx Technical Code 2.4.3).

Will new EIAPP certificates also be required due to Revised MARPOL Annex VI? Generally, no new EIAPP Certificates are required for engines which are already installed and remain unchanged, but see also Approved Method below. What is an approved Method according to reg. 13, 7.1? An Approved Method is a retrofit for a particular engine, or a range of engines, which ensures that an engine which formerly did not comply with MARPOL Annex VI emission limits becomes compliant with emission limit Tier I (NOx technical code 1.3.17). An Approved Method is required if it is published by the IMO for a particular engine or for a range of engines. It shall be installed upon the first renewal survey following 12 months of the publication (reg. 13,7,2). The following engines may be affected: Engines installed on ships constructed on or after 1 January 1990 and before 1 January 2000, with a power output of more than 5,000kW and a cylinder displacement of above 90 litres. Whether or not any of these engines are affected depends on whether or not the engine manufacturer launches a retrofit and has it published with IMO. A list can be found here: MEPC.1_Circ.743 MEPC 1-Circ. 738 MEPC.1/Circ.738/Add.1 MEPC.1/Circ.764 MEPC.1/Circ.764/Add.1 MEPC.1/Circ.765 MEPC.1/Circ.770

What does the shipowner have to do with regard to engines installed on ships constructed on or after 1 January 1990 and before 1 January 2000, with a power output of more than 5,000kW and a cylinder displacement of above 90 litres? The shipowner will have to observe the respective information on the IMO homepage and have the information readily available upon survey, in order to demonstrate to the surveyor that either an Approved Method does not exist, exists but is not commercially available (i.e. could not be purchased even though existing on the market), or has been applied. This will then be entered in the IAPP certificate accordingly (reg, 13, 7.2, 7.3)

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Revised MARPOL Annex VI: AMENDMENTS With regard to special designated areas: Emission Control Areas (ECAs) are introduced. SOx Emission Control Area (SECA) no longer exist. The reason for this is to allow the application of stricter limits also for other emissions than SOx (e.g. NOx) in certain areas (reg. 2, 8). With regard to ozone-depleting substances (ODS), there are two new requirements: Firstly, an Ozone Depleting Substances list of equipment shall be maintained. Secondly, an Ozone Depleting Substances Record Book shall be kept if a ship has rechargeable systems that contain ODS. This record book may form part of an existing log-book or electronic recording system as approved by the Administration (reg. 12, 6). Entries in the Ozone Depleting Substances Record Book shall be recorded, in terms of mass (kg), immediately upon each recharge, repair or maintenance of equipment containing ODS, upon discharge of ODS into the atmosphere or to land-based reception facilities, and supply of ODS to the ship (reg. 12, 7). With regard to engines, new emission limits apply: NO emission limit: applies to engines installed on a ship keellaid before 2000-01-01 UNLESS they have undergone a major conversion and UNLESS for an engine with more than than 5,000 kW power output and 90 litres per cylinder displacement on a ship keellaid on or after 1990-01-01 and 2000-01-01 an Approved Method exists. TIER I: - applies to engines installed on ships constructed (keel laid) on or after 2000-01-01 and before 2011-01-01 - applies to installation of additional engines or non-identical replacement on or after 2000-01-01 and before 2011-01-01, even if the keel laying date of the ship was earlier. - applies to substantial modification of engine installed on ships keellaid before 2011-01-01 - applies to engines with a power output of more than 5,000 kW and a per cylinder displacement of more than 90 litres, installed on ships constructed on or after 1990-01-01 and before 2000-01-01, provided that an Approved Method (NOx reduction method) for that engine exists. TIER II: - applies to engines installed on ships constructed on or after 2011-01-01 - applies in the case of installation of a non-identical replacement engine or additional engine on or after 201101-01 - applies to substantial modification of engines installed on ships keellaid on or after 2011-01-01. - applies when Tier III does not apply because the replacement engine cannot comply with Tier III (Reg. 13.2.2) - applies when Tier III does not apply because the combined propulsion power of the ship is less than 750 kW and it is demonstrated to the satisfaction of the Administration that the ship cannot comply with the standards of Tier III because of design or construction limitations of the ship (reg. 13.5.2.2). - applies when Tier III does not apply because the ship has a length of less than 24 metres and is used solely for recreational purposes (reg. 13.5.2.1). Tier III: Applies in ECAs only - applies to engines installed on ships constructed on or after 2016-01-01 and in ECAs only. - applies in the case of installation of a non-identical replacement engine or additional engine on or after 201601-01, in ECAs only. - applies to substantial modification of engine installed on ships keellaid on or after 2016-01-01 and in ECAs
only.

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With regard to fuel oil quality, new limits apply: d) The sulphur content of the fuel shall not exceed: 4.5 % prior to 1 January 2012, 3.50% m/m on or after 1 January 2012 and 0.50% m/m on or after 1 January 2020 outside designated ECAs (reg. 14, 1). The reduction to a limit of 0.50% m/m on or after 1 January 2020 outside designated ECAs will be reviewed by the IMO, which may lead to the 0.50% limit becoming effective only on 1 January 2025 (reg. 14, 10). While ships are operating in an ECA, the sulphur content of fuel used on board ships shall not exceed the following limits: 1.50% m/m prior to 1 July 2010, 1.00% m/m on or after 1 July 2010, and 0.10% on or after 1 January 2015 (reg. 14, 4). With regard to tankers, crude oil tankers shall have an approved VOC management plan (reg. 15, 6). This may also apply to gas carriers only if the type of loading and containment system allows safe retention of nonmethane VOCs on board or their safe return ashore (reg. 15, 6). IMO will circulate a list of ports requiring tankers to have VOC emission control (reg. 15, 4). With regard to incinerators, shipboard incineration of the following substances is prohibited in addition to those mentioned in MARPOL 73/78 Annex VI 1997: sewage sludge and sludge oil which is not generated on board the ship, and exhaust gas cleaning system residues. With regard to reception facilities, each Party undertakes measures to ensure the provision of adequate reception facilities of ODS (reg. 17, 1.1). If the ship has been allowed by the Administration to use equivalents to those required by MARPOL Annex VI, these have to be listed in the IAPP certificate (reg. 4).

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