N
o e
e
7
Da ish No
-Pape
o the o sultatio o the e isio of
the poli y o
o ito i g, epo ti g a d e ifi atio of
CO e issio s f o
a iti e t a spo t
The Danish Government finds it positive and relevant that the Commission has initiated a process to align
international rules on monitoring, reporting and verification of CO2-emissions from maritime transport,
particularly to align the MRV-regulation with the IMO DCS-regulation, and welcomes the opportunity to
o
e t o the Co
issio ’s pu li o sultatio
.
As the maritime transport is responsible for approximately 2.5 % of global GHG emissions, Denmark finds it
important to monitor and report the GHG emissions from the sector in order to establish relevant and
ade uate easu es to edu e the se to ’s GHG e issio s i the lo g u a d to e su e that the se to
contributes to achieving the long-term goals of the Paris Agreement. The measures should contribute to
the global goal of GHG reductions and should be applied in a non-discriminatory manner to all ships,
regardless of their flag.
To ensure a reasonable administrative burden, Denmark is in favour of aligning the two systems rather than
having two diverging systems (as is currently the case with MRV and IMO DCS) and appreciates the good
work that has been carried out in this regard.
Denmark supports the development of a green maritime sector and is thus in favour of a system which
focus on energy efficiency in the maritime transport sector. In that context, Denmark finds it relevant that
p o isio s fo t a spo t o k also i ludes al ulatio s ased o the a tual a go a ied, hi h i plies
that the current definition in MRV annex II, A, 1., (c) should be maintained. Maintaining this definition
assures that the energy efficiency of ships will also be part of the data that will be collected and will form
the base for the future regulation of the sector. Denmark considers this issue very important and would
consequently encourage that it is considered to maintain the MRV-regulation with its adequate definition
of transport work, if it is not possible to negotiate a common definition of transport work that includes
cargo carried.
Denmark emphasises the need for transparency but could fear that the MRV rules, which favour
transparency on single ship level, could interfere with the trade secrets of ship owners, whereas the
transparency rules of the IMO DCS do not seem to pose this risk.
Denmark can therefore support the ongoing work to align the rules that regulate and reduce GHG-
emissions from the maritime transport sector.
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