Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels

Effective Dates:  N/A

 

The purpose of this Marine Advisory is to draw the attention of ship-owners, operators, inspectors, masters and crew to the most common MARPOL Annex VI deficiencies raised during Port State Control (PSC) inspections of Liberian flagged vessels.

From the PSC reports, the Administration has compiled a list of most common MARPOL Annex VI deficiencies and has included in the table below Guidance to avoid these deficiencies:

 

Technical files and if applicable, monitoring manual

(MARPOL Annex VI/Reg. 13)

• Each diesel engine which is certified to NOx Tier I, II or III must be issued an Engine International Air Pollution Prevention (EIAPP) Certificate and a NOx Technical File approved by the vessel’s RO on behalf of the Administration.  The EIAPP and TF are to be maintained on board the vessel.

• The lMO ID number of fuel injection nozzles and other spare parts are to match those in the NOx technical file,

• If an engine uses the Direct Measurement and Monitoring method, this is to be documented in an Onboard Monitoring Manual, approved by the vessel’s RO on behalf of the Administration.

• Refer to Liberia MN POL-009/Applicability, Section 7.0 and 12.2.13.

 

Record book of engine parameters

(MARPOL Annex VI/Reg. 13 and NOx Technical Code/6.2.2.7))

A ship equipped with a marine diesel engine required to undergo an Engine Parameter Check method shall maintain on board:

1. A Record Book of Engine Parameters;

2. An engine parameter list of an engine’s designated components and settings and/or the documentation of an engine’s load-dependent operating values approved by the Administration; and

3. Technical documentation of engine component modification when such a modification is made to any of the engine’s designated engine components.

 

Record book of engine parameters (NOx Technical Code/6.2.2.8)

• A record of the component identification numbers of engine parts that affect NOx emissions shall be made in the "Record book of engine parameters" and ensure they match the official "NOx Technical File" and "EIAPP Certificate". Key components include fuel injectors, pumps, camshafts, charge air coolers, pistons, and turbochargers, all of which need to be logged with their original and replacement ID numbers when a change is made.

 

Approved method

(MARPOL Annex VI/Reg. 13.7.1 to 13.7.5)

• A marine diesel engine with a power output of more than 5,000 kW and a per cylinder displacement at or 90 L installed on a ship constructed on or after 1 January 1990 but prior to 1 January 2000 shall comply with the Tier I emission limits standards, provided that an approved method for the engine has been certified by an Administration of a Party and notification of such certification has been made to IMO. Section 2.2.1 of a vessel’s IAPP Supplement is to be completed appropriate depending of the ship-specific application of this regulation.

Refer to Liberia MN POL-009/12.2.6 to 12.2.8.

 

Exhaust Gas Recirculation (EGR)

(MARPOL Annex VI/Reg. 13)

 

Ships equipped with EGR to comply with NOx levels shall:

1. Meet the EGR bleed-off water discharge standards

2. Have on board a manual for EGR bleed-off discharge system and EGR Record Book approved by the RO on behalf of the Administration

3. Have on board certificates of type approval and operating and maintenance manuals of oil content meters (15 ppm alarm)

Refer to Liberia MN POL-009/12.2.9.

 

EGR or Selective Catalytic Reduction (SCR)

(MARPOL Annex VI/Reg. 13)

• Ships installed with EGR or SCR and unable to comply with relevant NOx Tier III levels prior to entering a NOx ECA shall immediately notify the relevant coastal State(s) and the Administration.

Refer to Liberia MN POL-009/12.2.9 and 12.2.10.

 

Diesel engine air pollution control (MARPOL Annex VI/reg. 13.6)

• The tier and on/off status of marine diesel engines installed on board a ship which are certified to both Tier II and Tier III or which are certified to Tier II only shall be recorded in the engineering log book or electronic record book approved by the Administration, suitable for that purpose at entry into and exit from an emission control area designated under regulation 13.6 of MARPOL Annex VI, or when the on/off status changes within such an area, together with the date, time and position of the ship.

Refer to MN POL-009/12.2.5.

 

Fuel Sulphur Content and Fuel Oil change-over procedure and SOx Records

(MARPOL Annex VI/Reg. 14)

• The Sulphur content of any fuel oil carried for use on board a ship when operating outside a designated Sox ECA shall not exceed 0.50% m/m.

• The Sulphur content of any fuel oil used on board ships when operating within a designated Sox ECA shall not exceed 0.10% m/m.  Current ECA’s are North American, United States Caribbean Sea, the Baltic Sea, the North Sea, and the Mediterranean Sea, and on 01 March 2026, the Canadian Arctic and the Norwegian Sea.

• The maximum Sulphur content of marine fuels for use while at berth in EU ports is 0.10% m/m.

• Vessels using separate fuel oils when entering or leaving an ECA must carry a written procedure showing how the fuel oil change-over procedure will be done, allowing sufficient time for the fuel oil service system to be fully flushed of all fuel oils exceeding the applicable Sulphur content prior to entry into an ECA.  The use of a “fuel oil change over calculator” is one way of ensuring the change-over is done in time. Refer to Liberia MN POL-009/12.3.8.

• The volume of low Sulphur fuel oils in each tank as well as the date, time, and position of the ship when any fuel-oil-change-over operation is completed prior to the entry into an ECA or commenced after exit from such an area, shall be recorded in the engineering log book or in a record book or log book in electronic format (electronic record book) approved by the Administration. (The Administration’s Marine Sulphur Record Book may also be used for this purpose.)

 

Alternative arrangements (SOx) - EGCS

(MARPOL Annex VI/Reg. 14)

• An exhaust gas cleaning system (EGCS) used as an equivalent or alternative arrangement to achieve the relevant Sulphur limit must be approved by the Administration. Refer to POL-009/12.3.9 and 12.3.10.

• Ships operating with an EGCS shall have on board an EGCS record book approved by the vessel’s RO on behalf of the Administration.

 

Incinerator, including operations and operating manual

(MARPOL Annex VI/Reg. 16)

• Shipboard incinerators are to be approved by the vessel’s RO on behalf of the Administration and issued a Type Approval certificate. Refer to Liberia MN POL-009/12.3.8.

• Incinerators are to be provided with a manufacturer’s operating manual which is to be retained on board the vessel and which specifies how to operate the incinerator within its applicable limits.

 

It is recommended that shipowners, operators, masters and crew inspect their vessels to ensure that these deficiencies are not present on board their vessels and if it is found that one or more exist, to resolve this as quickly as possible, using the noted references and other guidance.

For more information, please refer to the links below.

• Appendix 18 of the Procedures for Port State Control, 2023, IMO Assembly Resolution A.1185(33)
• Paris MOU PSCC Instruction 58/2025/16 Guidelines On MARPOL ANNEX VI
• Marine Notice POL-009

 

If you have any questions or concerns, please contact the Regulations and Standards Department at RegsAndStandards@liscr.com.

Refers to: Ship-owners, Operators, Masters and Managers of PHRS certified vessels

Effective Dates:  N/A

 

As the reporting cycle for 2025 emissions approaches, it is essential for all operators to prepare for the upcoming verification milestones. To support timely compliance and ensure that PHRS can complete verification activities without delay, please review the key actions and deadlines outlined below.

This update covers requirements under:

 

• FuelEU Maritime (FuelEU)
• EU Monitoring, Reporting and Verification (EU MRV)
• EU Emissions Trading System (EU ETS)
• IMO Data Collection System (DCS) & Carbon Intensity Indicator (CII)

 

Key Submission Deadlines

 

FuelEU

• 31 January 2026 – Submission of the ship-specific FuelEU report to the accredited verifier.
• 31 March 2026 – Completion of verification.
• 30 April 2026 – Verified FuelEU data must be confirmed in THETIS, including any applicable flexibility mechanism records.

Refer to the FuelEU Timetable for a complete overview of compliance milestones, including issuance of the Document of Compliance and payment of any penalties.

 

EU MRV

• 31 March 2026 – Ship-level and company-level emissions data must be submitted to THETIS and verified.

Note: Some Administering Authorities may request verified data earlier, but not before 28 February 2026.

 

EU ETS

• 31 March 2026 – Verified company emissions data (as reported in THETIS under EU MRV) must be entered into the Union Registry via the Maritime Operator Holding Account (MOHA) and validated by the Administering Authority.
• If data is not submitted by 1 April 2026, the MOHA will be blocked.

If a company no longer falls within EU ETS scope (e.g., no EU/EEA port calls in the reporting year), it may request that its MOHA be designated as “excluded.”

 

IMO DCS & CII

• 31 March 2026 – Submission of annual emissions data.
• 31 May 2026 – Verification completed and Statement of Compliance issued on behalf of the Administration.
• 30 June 2026 – Verified data submitted to the IMO GISIS system by the verifier.