The EESC considers that the proposed partial alignment will lead to burdensome and ineffective double monitoring and reporting requirements, since reporting obligations remain under two different systems: a regional (EU MRV Regulation) and a global (UN IMO) one. As a result, ships will have to fulfil monitoring and reporting requirements under both the EU Regulation and the global UN IMO DCS. The EU and UN IMO reporting templates are different, which increases the workload, administrative burden and costs for ships' crews and maritime transport.
A complete alignment of the EU MRV Regulation with the UN IMO would not only serve the purpose of creating an internationally unified reliable data base for ships' CO2 emissions, but would also be in line with the better regulation agenda of the European Commission, which aims for targeted regulation in order to achieve its objectives and bring benefits to the European economy at minimum cost. It would also ensure an international level playing field for the European fleet.