Further to our previous circular, ref, O(23)55, on 19th Dec 2023, requesting members submit vessel performance data to the ICS CII data collection system, which was set up to support the review of the CII rating system at MEPC81, this has now become an urgent issue. Unfortunately, there were no discussions at MEPC 81 but it was decided to carry out the CII review at MEPC82 (30/9 to 4/10) and whatever is agreed at this meeting will be ratified at MEPC83 for implementation from 1.1.2026, which is when it becomes a statutory requirement with fines levied for non compliance.

Thus, MEPC82 is really that last chance to influence the IMO to make practical and sensible changes to the CII which at present is not “fit for purpose” . The last date to submit ship performance data to the ICS is the 15th June as papers need to be submitted to the IMO by 30th June but the earlier the data can be submitted the better.

The ICS thanks members who have already submitted data but much more is needed to prove that the issues are widespread and now urgently requests that shipowners and shipmanagers participate in the Data Collection System.

The system can be accessed via the webpage of the ICS website at – https://www.ics-shipping.org/supporting-shipping/ics-cii-data-collection-system/ Data will be anonymised.

The ICS Secretariat would particularly like to hear from shipowners and shipmanagers who have good reason to believe that their ships have been unfairly rated, as these may form compelling case studies, not only for the identification of system weaknesses but also for system improvements.

Ideal candidates for such case studies would be groups of close sister ships, which are:

• Operated by the same company.
• Relatively new, say less than 5 years old.
• All having been assigned widely varying CII ratings by the Flag Administration or RO due to different circumstances.
• Having a limited range of operational factors outside of the control of the owner or manager that are causing the large variance in rating (e.g. adverse weather, cargo handling, waiting time, or short voyages.)
• Ship CII ratings that are being impacted by the consequences of the Baltimore bridge incident or by the recent need to avoid the Red Sea could also form the basis of informative submissions to IMO.
• For such special cases, the ICS Secretariat would welcome direct contact from ship owners and managers via chris.waddington@ics-shipping.org

In case of any queries about the system, please contact Chris Waddington, Technical Director – at Chris.Waddington@ics-shipping.org.

Attached below is a self explanatory paper the ICS submitted to MEPC81 setting out the reasons for collecting ship performance data.

Your cooperation to supply relevant data would be greatly appreciated.

MEPC 81-6-2 – Data collection system to support the CII review (ICS)