With the initial reporting validity for the IMO DCS expiring on 31 Dec 2019 and the deadline for reporting the data to the Administration / Recognised Organisation also having expired on 31 Mar 2020. A Statement of Compliance (SoC) provided by the Administration / Recognised organisation should be on board by 31 May 2020.
This statutory news is a reminder on how to stay in compliance with regulation 22A of MARPOL Annex VI
Regulation 22A of MARPOL Annex VI requires ships to collect and report data on their fuel consumption, starting from 1 January 2019. For ships to which this regulation applies it is mandatory that a valid Statement of compliance is readily available on-board for inspection together with the Confirmation of Compliance for the SEEMP part II.
The Confirmation of Compliance (SEEMP part II) and the validity of the Statement of Compliance (IMO DCS) will be verified at each Periodical Statutory Survey regardless of whether the IMO DCS is issued by Administration / RO or any other organisation approved by the flag administration. As this is a new requirement, we expect that Port State Control (PSC) will focus on the Statement of Compliance (IMO DCS) during any upcoming routine inspections. Non Compliance of IMO DCS can be a detainable deficiency.
Statement of Compliance shall be issued annually and is also required to be issued during Change of flag or Company. Statement of compliance shall be valid for the Calendar year in which statement of compliance is issued and for the first 5 months of the following Calendar year (until 31 May).