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LR: New IMO CII Guidelines require SEEMP Part III revisions

The IMO’s Carbon Intensity Indicator (CII) reduction factors used to determine the required annual operational CII for ships of 5,000gt and above, have been set through to 2030.  This means that the currently approved Ship Energy Efficiency Management Plans (SEEMP) Part III now needs to be revised to include an implementation plan addressing these new factors and then to be resubmitted for approval.
This is the result of the IMO having adopted Amendments to the 2021 Guidelines on the Operational Carbon Intensity Reduction Factors Relative to Reference Lines (CII Reduction Factors Guidelines, G3) (Resolution MEPC.338(76)) (MEPC.400(83)), which introduces reduction factors (Z) for the required annual operational CII for the years 2027, 2028, 2029 and 2030.
These reduction factors (Z) for the CII relative to the 2019 reference lines are:
Year Reduction factor (Z)
2027 13.625%
2028 16.250%
2029 18.875%
2030 21.500%
SEEMP Part III revisions required
Ships which currently have an approved SEEMP Part III (Ship Operational Carbon Intensity Plan) will need to have this revised to include an implementation plan demonstrating how the required CII will be met for the three-year period 2026 - 2028, as per the Guidelines for the Verification and Company Audits by the Administration of Part III of the Ship Energy Efficiency Management Plan (SEEMP) (MEPC.347(78)).
Deadlines for revised SEEMP Part III
The revised SEEMP Part III, which must include the implementation plan for the 2026-2028 period and the required annual operation CII, needs to be amended and approved by 31 December 2025
Class societies will request from shipowners and managers to submit their plans before the above date to guarantee approval and issuance of the Confirmation of Compliance required by MARPOL Annex VI Regulation 5 on behalf of the ship’s flag Administration before 1 January 2026. Please check with your class society to find out the exact date of this deadline.
Finally, new ships which are now entering into service, and existing ships for which a new SEEMP Part III is being developed resulting from change in Management Company or Flag, or both, can include the implementation plan extended to 2028 to avoid reapproval before 31 December 2025.