Is CII the answer?

As of 1 January 2023, it is mandatory for all ships to initiate the collection of data for the reporting of their annual operational carbon intensity indicator (CII) and CII rating. In addition, one must calculate the attained Energy Efficiency Existing Ship Index (EEXI) to measure the ships energy efficiency. This means that the first annual reporting will be completed in 2023, with the initial ratings provided in 2024.

Based on the ship´s CII, it will be given a rating from A-E, where A is the best score. Only the highest performing vessels will be given an A. Vessels that are performing above average will get a B, while a C-rating indicates that the ship is compliant.

Vessels performing below average will be given a D or E, depending on whether a corrective action plan must be developed immediately or not. However, if a ship is rated D for three consecutive years, an immediate action plan is required to show how a rating of C or better will be achieved.

To reduce carbon emissions and improve fuel efficiency, vessel owners and operators have several options. Some examples are:

  • Switching to low-carbon fuels
  • Speed and routing optimalization
  • Hull cleaning to reduce drag
  • Installation of energy-saving technology

The Energy Existing Ship Index (EEXI) is a rating system based on the ship´s specifications, not its actual operating performance. The EEXI is a rating system that assesses the energy performance based on key metrics such as energy consumption data, speed, power, and engine size.

Although the objective of these initiatives from the IMO is to reduce carbon emissions from the global shipping industry and to promote greener and greater fuel efficiency, there are some pitfalls. We would like to address a few of the challenges with the CII rating system.

There is no enforcement and no penalties for not being compliant. Furthermore, there is no clear definition of non-compliance. At the end of each calendar year a ship that is rated D or E can simply stop trading and just ballast around to improve its CII-rating.

The ranges between the various rating-grades are very narrow, implying that even a small change can impact the rating. Besides, the owners can just play the E-C game and be fine. E one year, then C, and then back to E again.

Finally, IMO should also consider if a rolling 12-month rating will be more logical rather than following the traditional calendar year counting. The consequences for being caught with congestion is more significant in December vs January.

IMO´s Marine Environment Protection Committee is to review the effectiveness of the implementation of the CII and EEXI requirements at the latest by 1 January 2026. Then they will develop and adapt further amendments as required.

Maritime Carbon Solutions is of the opinion that we need to focus on actual and meaningful emissions savings. MCS is ready to assist you optimizing the route and cutting the fuel consumption. Let’s go for a future that’s green, so we can keep an ocean that’s blue.