IMO DCS stands for International Maritime Organization’s Data Collection System for fuel oil consumption of ships.
It is a mandatory regulation under MARPOL Annex VI, Regulation 27, aimed at monitoring, reporting, and reducing greenhouse gas (GHG) emissions from international shipping.
Applicability
Legal Basis
MARPOL Annex VI serves as a key pillar of the International Maritime Organization’s (IMO) strategy to reduce air pollution and greenhouse gas (GHG) emissions from ships. As part of this, the Data Collection System (DCS) requires the monitoring and reporting of fuel consumption data to enhance transparency, improve energy efficiency, and support global emission reduction goals.
The amendments adopted at MEPC 82 underscore the IMO’s ongoing efforts to improve the accuracy and granularity of data collected under the DCS. These updates further align with the shipping industry’s broader shift toward sustainability and decarbonization.
The newly introduced reporting items aim to enhance the understanding of energy usage and operational efficiency. These include:
Fuel oil consumption must now be reported separately for:
Separate recording of fuel oil consumption during idle periods, such as when the vessel is anchored or berthed, allows for a more accurate assessment of emissions during non-propulsion operations.
Operators are encouraged to report the laden distance travelled, which refers to the distance covered while carrying cargo. This additional data helps improve operational efficiency analysis when combined with fuel consumption information.
Transport work is calculated by multiplying the cargo weight by the distance travelled:
Transport Work = Cargo Weight × Distance
This metric is useful for benchmarking energy efficiency across different vessels.
Ships are required to record the total amount of onshore power consumed while docked. Tracking this metric highlights the use of energy-efficient alternatives to fuel-based power generation.
The ship records annual fuel consumption data from January 1 to December 31, including fuel type, distance, and hours underway, as per SEEMP Part II.
At the end of the year, the shipowner compiles the fuel consumption report with all supporting documents and calculations.
The report is submitted to Normec Verifavia, accredited by several flags, which reviews data for completeness, accuracy, and compliance with SEEMP and IMO guidelines and MEPC resolution.
If requirements are met, Normec Verifavia issues SOCs for Flags of Antigua & Barbuda and St. Kitts & Nevis. Whereas for partial delegated flags, the verifier will submit the Verification Reports & COCs to Flag for the issuance of SOCs. But for all other flags, Normec Verifavia will submit the verified data to Ros / Class for the issuance of SOC.
The verified report and SOC are sent to the flag administration by May 31, which forwards the data to the IMO GISIS database.
There are three acceptable fuel consumption monitoring methodologies:
By 31st May each year, the ship must carry a Statement of Compliance (SoC) for the previous calendar year’s fuel consumption, issued by a flag/class or RO.
When a vessel is sold to different management, data collection and reporting are the responsibility of the current (outgoing) management. This data is then submitted to an accredited verifier for verification, after which a partial Statement of Compliance (SOC) is issued by RO or flag under the first management.
At the time of the management change, the new management is responsible for collecting all handover documents, including the partial SOC.
Following the transfer of management, the new manager assumes responsibility for data collection and reporting. The new management must appoint an accredited verifier to carry out verification for the pending period—from the date of management change until 31.12.202x.
The Carbon Intensity Indicator (CII) rating, however, will be based on the vessel’s full-year data, covering the period from 01.01.202x to 31.12.202x.
New management will be responsible to update the SEEMP III CAP (corrective action plan).
Penalties include fines, port detention, and reputational damage, depending on the flag state or port authority involved.
