The International Chamber of Shipping (ICS) has raised concerns with the French Government about a new requirement for foreign ship owners to provide information about CO2 emissions, using a detailed methodology that has not been discussed internationally.
ICS believes that the unilateral application by France of these new CO2 reporting requirements to foreign ships cuts across the principles of global regulatory uniformity and the primacy of IMO as the regulator of international shipping.
French Transport Code
The new and very detailed rules that have been added to the French Transport Code apply across all transport modes, although the Director General for Maritime Transport is responsible for their enforcement in the maritime sector. The rules came into effect in October.
ICS Wants Director General to Wait with Enforcement
ICS has therefore suggested that the Director General advise that these requirements will not be enforced on international shipping pending the outcome of discussions on the monitoring and reporting of fuel consumption and CO2 emissions currently taking place at IMO.
According to ICS, shipping companies are still trying to understand the detail of the new CO2 reporting requirements, the English translation of which has only recently come to the attention of the shipping industry.
Concerns about Validity of Methodologies
Serious concerns are already being raised by international companies about the validity of the methodologies that have been developed by France, as set out in the “Methodological Guide for Transport Services” produced by the Ministry of Ecology, Sustainable Development and Energy.
IMO Regulation on Mandatory Monitoring of CO2
The IMO Marine Environment Protection Committee is now in the process of developing global regulations for the mandatory monitoring and reporting of fuel consumption and CO2 emissions by ships trading internationally.
The development of these regulations will be considered by the next meeting of the IMO Marine Environment Protection Committee in March 2014. It is also the subject of a draft EU Regulation proposed by the European Commission.