The ICS Secretariat has recently been provided with feedback from three of our member associations relating to shipowners’ experiences with EU ETS compliance. This has included the following points, which mainly relate to the setting up of the Maritime Operator Holding Account (MOHA) and submission of the monitoring plan.
More specifically:

• It is proving extremely difficult for companies without an EU address to set up a MOHA trading account. While Malta and Cyprus do not require an EU address to set up an account, they are overwhelmed with demand for new accounts.
• There is a lack of harmonization among EU Member States on requirements/process for setting up a MOHA account, and in their level of preparedness. For example, the Dutch and Belgian administrations have exhibited prompt responsiveness to queries and maintain a streamlined approach to MOHA documentation. Whereas another EU administration was reported in July as being unready to accept applications for MOHAs
• Assignment of ETS obligations under bareboat charters is troublesome as the shipowner needs to come to an agreement with the ISM company to take responsibility for ETS compliance. This is causing significant difficulties with sale and leaseback agreements which are particularly prevalent in Asia.

The ICS Secretariat have shared this feedback with ECSA and they confirm they have received similar reports from their members. Despite these initial difficulties, ECSA and ICS urge shipowners to continue being as proactive as possible in meeting their ETS obligations.
To assist their understanding of the ETS requirements, members may access the guidance that was previously shared via our circulars MC24(42) (Annex A) and MC24(86) (Annex B).

EMSA and DG CLIMA’s webinars on the EU ETS can be watched here.

In September, ICS will also release the next edition of our greenhouse gas guide, which will include a new chapter on the EU ETS requirements that apply to international shipping.

The ICS Secretariat extends its thanks to member associations for sharing this feedback, and to ECSA for their very helpful advice.