2024 IMO DCS/CII
Verification Results and Status

The CII(Carbon Intensity Indicator) regulation, applying to ships engaged in international voyages of 5,000 GT and above, is enforced under Regulation 28 (Operational Carbon Intensity) of Annex VI of MARPOL(the International Convention for the Prevention of Pollution from Ships ) adopted by the IMO. The first verification under this regulation took place in 2024. The CII, representing a ship’s GHG emissions, is derived from reported and verified operational data in compliance with Regulation 27 (Collection and reporting of ship fuel oil consumption data) of MARPOL Annex VI.

Under the CII regulation effective since November 2022, ships subject to this regulation collected and reported their operational information for the period from January 1 to December 31, 2023. The CII values and ratings for each vessel were determined based on the reported data, with ratings assigned from A to E according to the IMO's CII rating criteria.

KR conducted the verification and certificate issuance this year through its GHG reporting and verification system for ships, KR GEARs. The following summarizes the current status of the verified CII ratings.

CII verification results of 2024

In compliance with IMO Regulation, KR verified a total of 1,652 ships by July 2024, of which 1,374 ships were subject to the CII regulation. The distribution and percentages of CII ratings across all verified ships are outlined below.

Additionally, by analyzing the results by ship type, the vessels were classified into 12 categories^*. Ro-Ro cargo ships (vehicle carriers), Ro-Ro cargo ships, and Ro-Ro passenger ships were grouped under "Ro-Ro ships," while combination carriers and refrigerated cargo carriers were categorized as "Other ship types." The distribution of verified vessel types under the CII regulation is shown below.

* Ship type subject to CII regulation : Bulk Carrier, Gas Carrier, Tanker, Container Ship, General Cargo Ship, Refrigerated cargo Ship, Combination carrier, LNG Carrier, Ro-Ro cargo ship(vehicle carrier), Ro-Ro cargo ship, Ro-Ro Passenger Ship, Cruise passenger Ship with non-conventional propulsion

And the following charts display the proportions of CII ratings for each ship type.

The graph below compares the distribution of CII ratings across different ship types.

KR’s verification results for CII ratings showed a ratio of 4:6 between high ratings (A~B) and low ratings (C~E). An analysis by ship type reveals that over 50% of the ships for Container Ships, Gas Carrier, General Cargo Ships had high ratings. By contrast, bulk carriers and Ro-Ro ships demonstrated a higher proportion of low ratings, with 75% of bulk carriers and 89% of Ro-Ro ships falling into the low-rating categories.

Comparison with 2023 IMO DCS Verification Results

To assess the 2024 CII values and ratings, a comparison was made with the IMO DCS data from 2023. The 2023 data was adjusted using the same reduction rates applied in 2024 to enable a direct comparison of the CII rating distribution.

A comparison of the overall CII rating distribution indicates a decrease in the number of ships rated E in 2024 compared to 2023.

And the table below compares high and low CII rating distributions by ship type.

Container ships, general cargo ships, and gas carriers saw an increase in the proportion of high CII ratings in 2024 compared to 2023. Conversely, bulk carriers, tankers, LNG carriers, and Ro-Ro ships showed little change in rating distribution.

Additionally, a comparison of average ship speed per year^* by ship type for the 2023 and 2024 data revealed that, with the exception of LNG carriers and general cargo ships, all ship types experienced a speed reduction in 2024 compared to 2023.

General review of CII Verification Results and Status

Since this is the first year of CII regulation enforcement, there have been limited cases of adopting low-carbon fuels, such as biofuels, or implementing energy-saving technologies and GHG reduction technologies, largely due to practical challenges.

Analysis of data from 2023 and 2024 showed that the proportion of high-rated ships (A or B) increased by approximately 7%, while the proportion of E-rated ships decreased compared to the previous year. Vessels assigned an E rating in CII verification for a single year are required to implement improvement measures within their SEEMP (Ship Energy Efficiency Management Plan) Part III, which is subject to verification by a classification society. Fewer vessels belonged to E rating in 2024 than in 2023, likely due to efforts to mitigate administrative burdens and ensure compliance with the regulations.

Upon reviewing CII ratings by ship type, the distribution for most ship types, except for container ships and general cargo ships, remained similar in 2024 compared to 2023. This outcome suggests that the unique operational characteristics of each ship type should be considered when assessing their CII performance.

For container ships, the proportion of high CII ratings (A or B) increased from 44% in 2023 to 61% in 2024. An examination of the reported data, based on the assumption that the improvement results from ship speed optimization, indicated a reduction of approximately 4.6% in speed compared to 2023. In contrast to regular liner ships, such as container ships, bulk carriers often face extended port waiting times, leading to shorter voyage distances, which negatively impact their CII values.

Ro-Ro ships, particularly Ro-Ro cargo ships (vehicle carriers), continue to report a high proportion of lower CII ratings (C, D, E). These ratings reflect the economic challenges inherent in their operations, often driven by shippers’ requirements or loading schedules. Despite a reduction in operating speeds in 2024 compared to 2023, these vessels still require relatively high speeds due to their operational demands, which contributes to the lower ratings.

LNG carriers and gas carriers, sharing operational similarities with Ro- Ro ships, may also be subject to lower CII ratings due to their operational profiles. However, as they primarily use LNG, which has a lower emission factor than conventional fossil fuels (HFO, LFO, MG/MDO), their CII ratings generally outperform those of Ro-Ro ships.

Apart from ten vessels verified in 2024 that used low-carbon fuels (biofuels), there were limited instances of implementing optimal measures to improve CII ratings. With CII standards tightening each year, ships currently rated C may fall to a D rating in the coming years if operational data remains unchanged. This underscores the growing need for vessels to develop and implement action plans to achieve regulatory compliance. Therefore, it is essential for the maritime industry and related sectors to closely monitor regulatory compliance by analyzing annual CII rating trends.