Environment and regulation

The three layers that decide what goes in a SEEMP and the deadline after a D or E rating (MARPOL Annex VI Regulation 26)

Regulation 26 of the 2021 revised MARPOL Annex VI sets SEEMP carriage and content requirements according to ship tonnage and type. Operational ratings may require the plan to be updated with corrective actions.

Ships of 400 GT and above subject to chapter 4 carry SEEMP Part I

Read regulation 26 within chapter 4 applicability. MEPC.1/Circ.925 describes Part I for ships of 400 GT and above. Check the exclusions and exceptions in regulation 19; tonnage alone does not decide every case.

1 Each ship shall keep on board a ship specific Ship Energy Efficiency Management Plan (SEEMP). This may form part of the ship’s Safety Management System (SMS).

Two things are written in: the plan is ship specific, and it may form part of the Safety Management System. Whether it sits as a separate document or inside the SMS is left open. Developing and reviewing it takes into account the guidelines adopted by the Organization.

Additional requirements apply from 5,000 gross tonnage

For a ship of 5,000 gross tonnage and above, the SEEMP has to include a description of the methodology used to collect the data required by regulation 27.1 and the processes used to report that data to the ship’s Administration.

The additional SEEMP requirements specify how data will be collected and reported, as well as the measures planned for the ship.

Further content requirements depend on tonnage and ship type

Where a ship is 5,000 gross tonnage and above and falls into one of the categories the Annex lists, four more items had to be in the SEEMP on or before 1 January 2023.

What has to be included	Content
Methodology and reporting process	How the attained annual operational CII required by regulation 28 will be calculated and reported
The required CII for the next three years	The value set by regulation 28
An implementation plan	Documenting how the required CII will be achieved over those three years
A self-evaluation and improvement procedure	A procedure for assessing and correcting itself

The three-year implementation plan is prospective. It must set out future measures rather than only report the previous year’s result.

A poor rating reopens the document

Regulation 28 documents the attained CII against the required CII to produce a rating from A to E. The middle point of rating C equals the required CII. And a poor rating comes back to the SEEMP.

A ship rated D for three consecutive years or rated E has to develop a plan of corrective actions to achieve the required CII. Revising the SEEMP to carry that plan is the next step, and a deadline attaches.

8 The SEEMP shall be reviewed to include the plan of corrective actions accordingly, taking into account the guidelines to be developed by the Organization. The revised SEEMP shall be submitted to the Administration or any organization duly authorized by it for verification, preferably together with, but in no case later than 1 month after reporting the attained annual operational CII in accordance with paragraph 2 of this regulation.

preferably together with is the recommendation and in no case later than 1 month is the ceiling. It counts from reporting the attained CII. And regulation 28 has that report made within three months after the end of the calendar year. The two deadlines run into each other.

There is more after the plan is filed. A ship rated D for three consecutive years or rated E has to duly undertake the planned corrective actions in accordance with the revised SEEMP. Filing the document does not close it out.

This document is subject to verification and company audits

.3 The SEEMP shall be subject to verification and company audits taking into account the guidelines to be developed by the Organization.

Verification and company audits are written in together. Having the document on board and the document actually being used are two separate things to confirm.

Worth confirming

The passages above come from pages 42 and 45 of the 2021 revised MARPOL Annex VI (MEPC.328(76)). The reduction factor and reference value that produce the required CII, and the detail of the rating calculation, are set by guidelines developed by the Organization. Whether that ship falls into a third layer category, what the ratings of the last three years were, and whether the three-year implementation plan in the SEEMP still matches current performance are where the actual judgement starts.

Check rating history alongside the actual reporting date

These fictional cases apply the conditions in regulation 28. Years are performance years, not submission years.

Ratings for 2023 → 2024 → 2025	Corrective-action plan decision
D → D → D	Required after 3 consecutive D ratings
C → C → E	Required because of E
D → C → D	This history alone does not meet the trigger

The last case still requires implementation and evaluation of the existing SEEMP. If CII for 2025 is reported on 2026-02-20, a ship needing a plan must submit the revised SEEMP no later than 2026-03-20. If reported on 2026-03-31, the limit is 2026-04-30. Assigning 2026-04-30 to every ship would make the first case late. Confirm the schedule with the verifier using the actual reporting receipt.

Keep evidence before closing an action

Section 15 of MEPC.1/Circ.925 connects causes, measures, schedules, responsibilities and effects. The following is a fictional review note designed by Bellbook, not a measured improvement claim.

Review item	Fictional note
Observation and hypothesis	Fuel use increased under comparable conditions; hull fouling remains unconfirmed
Evidence to examine	Align draught, weather, speed and meter corrections; inspect hull findings
Action and responsibility	Technical lead reviews inspection evidence and sets any necessary maintenance scope and schedule
Effectiveness review	Compare equivalent conditions before and after maintenance; recalculate projected annual CII
Closure decision	Separate work completion from effectiveness; revisit causes and further action if results are insufficient

The SEEMP action review CSV provides fields for evidence, targets, owners, deadlines and review outcomes. It is a blank working aid, not an approved SEEMP or official verification form. Derive targets from ship records instead of inserting an arbitrary savings percentage.

Separate plan verification from annual performance verification

MEPC.347(78) addresses periodic Part III verification upon content updates and at least every 3 years, plus additional verification for corrective-action plans. Keep the plan’s Confirmation of Compliance distinct from the annual data and rating Statement of Compliance. Retain separate evidence of submission, verification and implementation.

You can consult the cited source documents

These links lead to the official publishers of the documents discussed here. Match the edition and provisions cited in the article, and check subsequent amendments and flag-state implementation before applying them.

Bellbook manages company audit schedules and findings per ship

The provision states that the SEEMP is subject to verification and company audits. Bellbook keeps the audit schedule and the findings that came out of it, with deadlines, per ship, so what is still open before the next audit shows up in the list.

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