Carbon Intensity Indicator (CII) Guide

Guide on the calculation and impact of CII on your ship

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EXECUTIVE SUMMARY

The Carbon Intensity Indicator (CII) is a measure of how efficiently a ship transports
goods or passengers. It is given in grams of CO2 emitted per cargo-carrying capacity
and nautical mile. It is an instrument wielded by the International Maritime Organization
(IMO) to achieve carbon reduction in shipping.

The goal of this guide is to provide the reader with detailed information on the
requirements, calculation and compliance of CII. Use the website to gather the latest
information regarding CII, or use the helpdesk to ask for clarifications at any time.

Key Points

• CII is an IMO mandated regulation that determines ‘carbon intensity’ or transport

efficiency for individual ships, not a fleet. The main documents stipulating the
regulation are MEPC.346(78) and MEPC.355(78) (learn more).

• CII applies to ships above 5,000 GT involved in international trade, i.e.: Bulk carriers,
Gas carriers, Tankers, Container ships, General cargo ships, Refrigerated cargo
carriers, Combination carriers, LNG carriers, Vehicle carriers, Ro-Ro cargo vessels,
Ro-Ro passenger vessels, Cruise passenger ships (learn more).

• CII is calculated by dividing annual CO2 emissions by the capacity multiplied by the
annual distance travelled. For RoRo and Cruise Passenger ships the capacity is GT,
for other ships it is deadweight. IMO DCS input is used for calculation (learn more).

• Ships are rated from A to E every year, with A being the best. A consecutive triple D-
rating or a single E-rating means non-compliance in which case a corrective plan
is required. At the time of writing, cost impact is limited (learn more).

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Figure 1. A masterclass on CII to make your life easier.

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Contents

EXECUTIVE SUMMARY 2

1.0 ABOUT CII 6

1.1 Introduction 6
1.2 Legislator and jurisdiction 7
1.3 Requirements 8
1.4 Applies to… 9
1.5 Exemptions and exceptions 9
1.6 Relation between CII, DCS and SEEMP Part III 10
1.7 Relation between the CII and EEXI 12

2.0 CALCULATING CII 14

2.1 Calculation in brief 14
2.2 Step 1 - Calculate CII Attained 16
2.3 Step 2 - Calculate CII Reference 18
2.4 Step 3 - Calculate CII Rating 20
2.5 Correction factors 22

3.0 IMPACT OF CII 24

3.1 Compliance 24
3.2 Non-compliance 24
3.3 Mitigation options 25
3.5 Costs and penalties 28

4.0 FREQUENTLY ASKED QUESTIONS 29

5.0 APPENDIX 34
5.1 References 34
5.2 CII Required 35

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Disclaimer
Sustainable Ships will not be held responsible for any damages that could arise from
using the information provided in this report or on its platform. All costs provided in this
blogs are estimated, based on anecdotal evidence from research. The numbers are for
feasibility study purposes only. Contact your supplier for firm quotes. View all terms and
conditions here.

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1.0 ABOUT CII

1.1 Introduction
The Carbon Intensity Indicator (CII) is a measure of how efficiently a ship transports
goods or passengers. It is given in grams of CO2 emitted per cargo-carrying capacity
and nautical mile1.

The CII went into effect on the 1st of January 2023. From that year onwards, each ship
has to calculate and report their CII according to the latest guidelines provided by IMO.
The yearly CII is calculated based on reported IMO DCS data and the ship is given a
rating from A to E, where A is the best category and E the worst.

Ships must achieve rating C as the minimum standard. For ships that achieve a D rating
for three consecutive years or an E rating in a single year, a corrective action plan needs
to be developed as part of the SEEMP and to be approved by the Administration or
Recognized Authority (RO).

Ships must document the CII as part of SEEMP 3, retain the Statement of Compliance to
CII onboard and at verification audits prove that they are compliant with a reduction
trajectory of 11% by 2026.

CII applies to ships above 5,000 GT of the following ships types: bulk carriers, gas
carriers, tankers, container ships, general cargo ships, refrigerated cargo carriers,
combination carriers, LNG carriers, vehicle carriers, Ro-Ro cargo vessels, Ro-Ro
passenger vessels and cruise ships.

1
The exact formula and calculation of the rating is slightly more complicated, as highlighted in chapter 2.0.

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1.2 Legislator and jurisdiction

The International Maritime Organization (IMO) is the main legislative body responsible
for CII. As such, CII is applies globally. Key documents stipulating the regulation are:

• Regulation 26.3.1 of MARPOL Annex VI Prevention of Air Pollution on board of Ships

• Resolution MEPC.346(78) 2022 Guidelines for the development of a Ship Energy
Efficiency Management Plan (SEEMP)
• Resolution MEPC.355(78) 2022 Interim guidelines on correction factors and
voyage adjustments for CII calculations (CII Guidelines, G5)

MARPOL Annex VI is the overall with regards to the prevention of air pollution on board
of ships. Resolution MEPC.346 describes the general process and requirements of CII as
part of the SEEMP. MEPC.355(78) describes CII calculations and correction factors. A
detailed list with all guidelines on the carbon intensity of international shipping by IMO
can be found here.

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1.3 Requirements
The below list shows a basic minimum of requirements under the regulations stipulated
by IMO.

• Revision of SEEMP to add the Ship Fuel Oil Consumption Data Collection Plan
(DCP) which includes a description of the methodology for data collecting and
the reporting processes. To be updated every three years.
• Data collection on board from 2019 onwards.
• Reporting the collected data to the Administration or Recognized Organization
(RO) in accordance with IMO DCS (Data Collection System) fuel reporting data.
• Verification of the reporting data by the Administration or RO, which are “ratings”
from A (good) to E (bad) which will be added on Statement of Compliance form.
• Retaining the Statement of Compliance issued by Administration or RO onboard,
and keeping the relevant data.

An “E” rating for a single year, or a “D” rating for three consecutive years constitutes a
low rating. Low-rated vessels are non-compliant and are to develop a plan of corrective
actions. This plan is to be approved by the Administration or Recognized Authority.

Learn more about (non-)compliance, corrective actions and mitigations in chapter 3.0.
Learn more about the relation between CII and IMO DCS in section 1.6.

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1.4 Applies to…

CII applies to ships above 5,000 GT of the following ships types:

• Bulk carriers
• Gas carriers
• Tankers
• Container ships
• General cargo ships
• Refrigerated cargo carriers
• Combination carriers
• LNG carriers
• Vehicle carriers
• Ro-Ro cargo vessels
• Ro-Ro passenger vessels
• Cruise passenger ships

1.5 Exemptions and exceptions

CII does not apply to ships below 5,000 GT, nor any ship types that have not been stated
in the previous section. New ship types can be included in the future however. Additional
correction factors apply to ship types and voyages, see section 2.5.

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1.6 Relation between CII, DCS and SEEMP Part III

CII can be viewed as part of a strengthening of the SEEMP (Ship Energy Efficiency
Management Plan), referred to by some as the ‘enhanced SEEMP’. The intention is to
ensure continuous improvement of energy efficiency and to lower carbon intensity. The
enhanced SEEMP shall include an implementation plan on how to achieve the CII targets
(called the Ship Operation Carbon Intensity Plan) which will be subject to approval and
company audits.

Starting in 2024, the CII must be calculated and reported to the Data Collection System
(DCS) verifier together with the aggregated DCS data for the previous year, including
any correction factors and voyage adjustments (see 2.5). Deadline for DCS and CII
submission is no later than 31 March each year.

Attained CII and additional CII data will be visible in IMO DCS upon submission after the
year end. After successful verification, both attained CII and acquired Environmental
Rating (A to E) will be presented on the DCS Statement of Compliance.

The attained annual operational CII and the environmental rating will be noted on the
DCS Statement of Compliance (SoC), which will be required to be kept on board for five
years.

Ships that achieve a D rating for three consecutive years or an E rating in a single year,
a corrective action plan needs to be developed. That means the SEEMP III must be
updated and verified before the SoC can be issued. The corrective action plan should
consist of an analysis of why the required CII was not achieved and include a revised
implementation plan (learn more in chapter 3.0).

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Figure 2. CII is part of IMO’s operational measures to reduce carbon emissions, i.e. SEEMP III (Ship Energy
Efficiency Management Plan).

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1.7 Relation between the CII and EEXI

The EEXI (Energy Efficiency Existing Ship Index) is a one-time certification equivalent to
the EEDI (Energy Efficiency Design Index). The CII is an operational indicator and will be
assessed annually from 2023 with yearly stricter emission limits.

The EEXI and CII are applicable to the same ship types. The difference is that CII ratings
will apply to ships 5,000 GT and above regardless of propulsion type.

EEXI calculations are based on the methodology developed for the Energy Efficiency
Design Index (EEDI) for newbuilds. The EEXI describes a vessel’s CO 2 emissions,
determining standardized CO2 emissions related to installed engine power, transport
capacity and ship speed. Emissions are calculated based on the installed power of the
main engine, fuel oil consumption, and a conversion factor between fuel and the
corresponding CO2 mass.

A ship’s CII is calculated as the ratio of the total mass of CO 2 emitted to the total
transport work undertaken in a given calendar year. A vessel’s performance rating is
determined by comparing a ship’s operational carbon intensity performance with the
average performance of others ships of the same type. Required reductions for each
ship type are expected to either increase or remain stable over time, ensuring that
international shipping achieves the IMO’s intended targets.

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Figure 3. The relation between CII and EEXI is that CII applies to the same vessels that EEXI applies to. EEXI is a
one-time calculation however, and CII is calculated every year.

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2.0 CALCULATING CII

 Skip the reading and use the CII quickscan to determine your CII Rating.
 Full formula with correction factors can be found in MEPC.355(78).
 The RoRo Passenger/Cargo ship type is not explicitly mentioned in IMO regulations,
but is used in some occasions. In case multiple ship types are available, the most
conservative case must be used.

2.1 Calculation in brief

CII is calculated by dividing annual CO2 emissions with annual distance sailed
multiplied by ship capacity. If applicable, correction factors are applied. The CII unit is
“grams of CO2 emitted per cargo-carrying capacity times nautical mile”, whereby
cargo capacity is either deadweight or gross tonnage depending on ship type.
Correction factors are similar to those used for EEXI/EEDI, in addition to factors for
specific ship types and voyage circumstances. Correction factors are described in
more detail in section 2.5.

The above formula stated the calculation of the CII attained. To get the CII rating – the
label ranging from A to E - the CII attained is compared with a CII reference for the
specific ship type, leading to a label. To somewhat simplify and showcase these
calculations, this guide divides the calculation of the CII into three steps:

Step 1) Calculate CII Attained

Step 2) Calculate CII Reference
Step 3) Calculate CII Rating

These steps are shown on the right hand side for a bulk carrier. No correction factors
have been taken into account, providing a conservative estimate. This process is
repeated for each consecutive year, which results in a table of ratings per year upon
which basis (non-)compliance is determined. This is explained in more detail in step 3.

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Step 1 - Calculate CII Attained

Ship type Bulk Carrier

GT 34,515

Deadweight 61,215 [mT]

Distance sailed 93,960 [nm/year]

Fuel consumption 8,500 [mT / year]

Fuel type HFO

Emission factor 3.114 [mT/mT]

CO2 emissions 26,469,000,000 [g/year]

CII Attained 4.60 [g/mT nm]

Step 2 - Calculated CII Reference

a 4,745

c 0.622

Capacity 61,215 Deadweight

CII Reference 5.00

Step 3 - Calculate CII Rating

Reduction (R) 11% 2026 as reference

CII Required 4.45

Attained / Required 1.03

CII Rating C

Figure 4. The steps required to calculate the CII for a single year, with a bulk carrier taken as benchmark.
Correction factors have NOT been taken into account. Use the CII quickscan to quickly determine your CII.

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2.2 Step 1 - Calculate CII Attained

CII attained is calculated using IMO DCS data. That means annual fuel consumption
and annual distances sailed as reported in IMO DCS is taken for calculations. Emission
factors used for calculation by Sustainable Ships can be found in the Sustainable Ships
emission guide.

Capacity for each ship is determined as per the table on the right hand side. Note that
ships carrying cargo generally use deadweight as capacity, and ships carrying people
use GT as capacity. The capacity is also taken from IMO DCS as fixed parameters.

Correction factors can be included in this step, which are not shown here because they
are different for each individual vessel and voyage. More information on correction
factors are shown in section 2.5.3.

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Step 1 - Calculate CII Attained

Ship type Bulk Carrier

GT 34,515

Deadweight 61,215 [mT]

Distance sailed 93,960 [nm/year]

Fuel consumption 8,500 [mT / year]

Fuel type HFO

Emission factor 3.114 [mT/mT]

CO2 emissions 26,469,000,000 [g/year]

CII Attained 4.60 [g/mT nm]

Step
Step2 1--Calculated
Additional CII Reference
Information

a
Ship Type 4,745 Capacity

c
Tanker 0.622 Deadweight

Capacity
Bulk Carrier 61,215 Deadweight

CII Referencecarrier
Combination 5.00 Deadweight

Container Ship Deadweight Deadweight corresponding to maximum

General Cargo 3 - Calculate CII Rating summer load draft, i.e. value on IEE
StepDeadweight
certification.
Reduction
Gas Carrier(R) 11% 2026 as reference
Deadweight

CII Required
LNG Carrier 4.45 Deadweight
Correction factors & voyage adjustment
Attained
RoRo / Required
Passenger and Cargo 1.03 Gross Tonnage guidelines can be taken into consideration
CII Rating
RoRo Cargo C Gross Tonnage for calculations.

RoRo Passenger Gross Tonnage

RoRo Cargo Vehicle Carrier Gross Tonnage

Refrigerated Cargo Carrier Deadweight

Cruise Passenger Ship Gross Tonnage

Figure 5. Calculation steps breakdown for CII attained, including a reference table with capacity for different
ship types.

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2.3 Step 2 - Calculate CII Reference

Calculation of the CII reference is fairly straightforward, as fixed values are taken based
on ship type and ship capacity. These are shown on the right-hand side for our example
bulk carrier. The CII reference is sometimes referred to as the CII reference line as well,
as the reference formula follows an exponential line as a function of ship capacity. More
information on the line can be found in the ClassNK reference on CII (see references).

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 Distance sailed 93,960 [nm/year]

Fuel consumption 8,500 [mT / year]

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Fuel type HFO

Emission factor 3.114 [mT/mT]

CO2 emissions 26,469,000,000 [g/year]

CII Attained 4.60 [g/mT nm]

Step 2 - Calculated CII Reference

a 4,745

c 0.622

Capacity 61,215 Deadweight

CII Reference 5.00

Step
Step23--Additional
CalculateInformation
CII Rating
Ship Types
Reduction (R) Condition
11% Capacity
2026 as reference a c

Tanker
CII Required DWT Deadweight 5,247 0.610
4.45
Bulk Carrier DWT >= 279,000 Deadweight 4,745 0.622
Attained / Required 1.03
DWT < 279,000 Deadweight 4,745 0.622
CII Rating C
Combination carrier DWT Deadweight 5,119 0.622

Container Ship DWT Deadweight 1,984 0.489

General Cargo Ship DWT >= 20,000 Deadweight 31,948 0.792

DWT < 20,000 Deadweight 588 0.3885

Gas Carrier DWT >= 65,000 Deadweight 1.44050E+11 2.071

DWT < 65,000 Deadweight 8,104 0.639

LNG Carrier DWT >= 100,000 Deadweight 9.827 0.000

100,000 > DWT >= 65,000 Deadweight 1.44790E+14 2.673

DWT < 65,000 Deadweight 1.44790E+14 2.673

RoRo Passenger/Cargo GT Gross Tonnage 1,967 0.485

RoRo Cargo GT Gross Tonnage 1,967 0.485

RoRo Passenger Regular Gross Tonnage 2,023 0.460

High-speed craft Gross Tonnage 4,196 0.460

RoRo Cargo Vehicle GT >= 57,700 Gross Tonnage 3,627 0.590

57,700 > GT >= 30,000 Gross Tonnage 3,627 0.590

GT < 30,000 Gross Tonnage 330 0.329

Refrigerated Cargo DWT Deadweight 4,600 0.557

Cruise Passenger GT Gross Tonnage 930 0.383

Figure 6. CII Reference calculation, capacity and a plus c factors for different ship type according to different
conditions. Not that the ‘high-speed threshold’ taken into consideration by Sustainable Ships is 20 knts, though
this could differ in your situation.

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2.4 Step 3 - Calculate CII Rating

The final CII rating is calculated by dividing CII attained by CII required. The CII required
is dependent on the year in which CII is calculated, as it is the CII reference multiplied
by the Reduction Factor (R).

The reduction factor increases over time, which means that If the vessel keeps its
emission score same, the rating will be slightly worse year by year. Reduction will start
as per 2023 with 5% and 2% will be added yearly.

R factors for the years of 2027 to 2030 to be further strengthened and developed taking
into account the review of the short-term measure. It should be noted that the IMO
strives for carbon neutrality by 2050, which would correlate to a reduction factor of 100%
by 2050.

2.4.1 From number to letter

As is show, the CII rating is the attained number in grams per ton mile divided by the
required number in grams per ton mile. The result is again a number (typically around
1) which is transformed into a letter based on ‘d-values’. These values are fixed, ship-
specific values determined by IMO. The resulting CII rating number is compared to these
values according to the logic shown in the additional information figure to the right.

Based on this comparison, we end up with a letter for each year: the resulting CII rating.
This is used to determine compliance or non-compliance by class, which is explained
in more detail in chapter 3.0.

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 Step
Carbon Intensity Indicator (CII) Guide v. 2 - Calculated CII Reference
2024-04-30 Contact Helpdesk
a 4,745

c 0.622

Capacity 61,215 Deadweight

CII Reference 5.00

Step 3 - Calculate CII Rating

Reduction (R) 11% 2026 as reference

CII Required 4.45

Attained / Required 1.03

CII Rating C

Parameter 2023 2024 2025 2026

Reduction (R) 5% 7% 9% 11%

CII Required 4.75 4.65 4.55 4.45

CII Attained 4.60 4.60 4.60 4.60

Attained / Required 0.97 0.99 1.01 1.03

CII Rating C C C C

Figure 7. CII Rating calculations over the years with the bulk carrier as an example. Below is shown additional
information that shows how the CII rating number is transformed into a CII rating letter.

3 - Additional Information

if then explanation

CII Rating < d1 A If CII Rating (number) is under d1 value, CII rating (letter) is A

CII Rating < d2 B If CII Rating (number) is under d2 value and above d1, CII rating (letter) is B

CII Rating < d3 C If CII Rating (number) is under d3 value and above d2, CII rating (letter) is C

CII Rating < d4 D If CII Rating (number) is under d4 value and above d3, CII rating (letter) is D

CII Rating > d4 E If CII Rating (number) is above d4 value, CII rating (letter) is E

CII Number CII Letter Bulk carrier example

1.03 C The calculated CII rating is 1.03, below d3 for a bulk carrier, resulting in a C

Figure 8. The CII rating is transformed from a number to a letter based on ‘d-values’. These are fixed numeric
values specified for each ship type. Check appendix 5.2 for a full table of d-values for all ship types.

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2.5 Correction factors

Correction factors and voyage adjustments can applied to CII attained. These are
described in IMO's Resolution MEPC.355(78) - 2022 Interim guidelines on correction
factors and voyage adjustments for CII calculations (CII Guidelines, G5 chapter 4). The
below formula shows available correction factors, which are described in the
subsequent sections.

CII correction factors and voyage adjustments reporting will be verified on a case-by-
case basis. In case of uncertainties in reporting, additional documentation or evidence
might be required by the verifier.

To receive an official correction to the CII values, the correction factor must be stated in
an approved version of the SEEMP Part III. If the correction is not in the SEEMP Part III, the
correction will not be applied to the “official” CII corrected values.

Table 1. Overview of possible correction factors that can be used when calculating CII attained, as per IMO
guidelines. These are ship-specific and not taken into account into the general calculations as per previous
sections. Ensure to check validity and completeness with class for your ship!

Possible correction factors to be applied to CII attained

j Fuel type

CF,j Emission factor for fuel j

FCj Mass (in grams) of fuel j as per IMO DCS

FCvoyage,j Mass (in grams) of fuel j that can be deducted as per voyage correction factors
Quantity of fuel j removed for Ship to Ship (STS) operations or shuttle tanker
TFj
operations.
yi Numbering system for years (y2023 = 0, y2024=1 etc.)
Mass (in grams) of fuel j consumed for production of electrical power allowed to
FCelectrical,j
be deducted
FCboiler,j Mass (in grams) of fuel j consumed by the boiler allowed to be deducted

FCother,j Mass (in grams) of fuel j consumed by other consumers allowed to be deducted

fi Capacity correction factor for ice-classed ships as per EEDI

fm Factor for IA Super and IA ice-classed ships as per EEDI

fc Cubic capacity correction factor for chemical tankers as per EEDI

fiVSE Correction factor for ship-specific voluntary structural enhancement as per EEDI

Dx Distance travelled for voyage periods which may be deducted

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2.5.1 Ship correction factors

There are several correction factors listed by IMO that apply mostly to tankers, LNG
carriers and ships carrying refrigerated cargo. These include (amongst others):

• Shuttle Tanker/STS (Ship to Ship) voyages on Tanker - Correction for dynamic

positioning and cargo pump
• Tanker - Correction for cargo heating, cargo pump
• LNG carrier - Correction for cargo cooling and reliquefication
• Ship carrying Refrigerated Containers - Correction for Refrigerated Containers

2.5.2 EEDI and EEXI correction factors

Your vessel's EEXI/EEDI Technical file might contain few correction factors that are
applicable during CII calculation:

• 𝑓𝑖 - capacity correction factor for ice-classed ships

• 𝑓𝑚 - ships having ice classes IA Super and IA
• 𝑓𝑐 - cubic capacity correction factors for chemical tankers
• 𝑓𝑖,𝑉𝑆𝐸 represents the correction factor for ship-specific voluntary structural
enhancement

2.5.3 Voyage correction factors

There are several cases in which a vessel can apply voyage adjustments. Adverse
weather which may endanger safe navigation of a ship is not specified as potential for
adjustment. Therefore, vessels cannot report voyage adjustments because of
unfavourable weather.

1. Scenarios specified in regulation 3.1 of MARPOL Annex VI, which may endanger safe
navigation of a ship area within the ice edge.
2. Sailing in ice conditions, which means sailing of an ice-classed ship in a sea within
the ice edge.
3. When a vessel encounters imminent safety concerns during its voyage, including
(example situations):

• saving life at sea, i.e., search and rescue operations, evacuation.

• navigation hazards such as icebergs.
• areas that have been designated on an ad-hoc period due to prevailing
navigational hazards.
• piracy risk or other areas restricted for navigation due to war risk

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3.0 IMPACT OF CII

 Cost and time Impact of CII is limited (~ €3k) even in the case of non-compliance.
 Use the Decarbonizer to determine cost impact for your own vessel.

3.1 Compliance
Compliance means to receive a maximum amount of two (2) D-ratings. For example,
you receive a C-rating in 2023 and 2024, and a D-rating in 2025 and 2026, your vessel
is compliant. In this scenario, no specific actions or consequences are defined by IMO.
It is nevertheless advised to closely monitor CII performance in order to avoid having to
take drastic measures unexpectedly. Compliance requirements might change of the
CII revision of 2025.

Figure 9. You are compliant to CII. You do not have to do anything.

3.2 Non-compliance
An E-rating in a single reporting year, or a D-rating for three consecutive years
constitutes a “low-rating”. Low-rated vessels are non-compliant and are to develop a
Corrective Actions Plan as part of SEEMP Part III. This plan shall be submitted to and
approved by the Administration or Recognized Authority before DCS Statement of
Compliance for that year can be issued. Guidance and available plans are discussed
in the next section.

Figure 10. You are non-compliant to CII. You need to submit a Corrective Actions Plan.

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3.3 Mitigation options

To achieve compliance in the case of means to submit a Corrective Actions Plan that
includes measures to either reduce CO2 emissions with same distance travelled; or
increase distance travelled with same CO2 emissions. Sustainable Ships generally works
with a CO2 reduction approach.

Either approach would work however and lead to the same result, as it would both
decrease the CII rating. Below are stated several options that can be included in a SEEMP
Corrective Actions Plan. You can use the Decarbonizer to quickly (and freely) determine
possible actions for your ship and to download the corresponding plan. Below is an
overview of potential measures for our bulk carrier example, though these is certainly
not an exhaustive list. Contact the helpdesk for customization options for your ship.

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Figure 11. Use the Decarbonizer to make your own SEEMP Corrective Actions Plan in a matter of minutes.

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3.3.1 SEEMP Corrective Actions Plan

Option 1 - small CO2 reduction required (<10%)

In case a small reduction is required, Sustainable Ships advises to make use of
operational measures for shipowners. These include Engine Power Limitation or slow
steaming, on top of simply ensuring your vessel is in good condition. These are generally
the most cost-effective and least impactful on your day-to-day operations. Charterers
will also have a major influence over the CII of the ships they charter by selecting the
speed, hence discussion with them on speed is advised. Overall cost impact for these
measures are negligible frequently coincide with costs benefits.

Option 2 - moderate CO2 reduction required (10% - 30%)

In case a moderate reduction is required, Sustainable Ships advises to make use of a
combination of shore power implementation and biofuels on top of the operational
measures discussed in option 1. Shore power is required in any case after 2030 and
could lead to 4% reduction in CO2. Biofuels are the least invasive fuel in terms of
operational impact and can be blended or used as a drop-in fuel to arrive the exact
amount of CO2 reduction required. Total costs would be in the order of €1.5M CAPEX (for
shore power) and €500k yearly for added OPEX. Use the Decarbonizer to verify this for
your vessel as significant changes appear on a case-by-case basis.

Option 3 - significant CO2 reduction required (>30%)

These cases should be rare, but would not incur significant efforts in order to achieve.
On top of the previously mentioned actions (shore power and biofuels), wind-assisted
propulsion, a new coating and potentially even the switch to alternative fuels is required.
Sustainable Ships does not recommend this in light of CII regulation however, as these
are subject to evaluation in 2025. Consequently the increased use of biofuels is
recommended. This would result in an added CAPEX of €2M for a total of €3.5M
approximately, and yearly added operational expenses in the order of €2M for our bulk
carrier example. Use the Decarbonizer to verify this for your vessel as significant
changes appear on a case-by-case basis.

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3.5 Costs and penalties

3.5.1 For compliance

Total cost for calculating and approval of a CII rating should be in the order of €1,500 -
€3,000 per ship. Total time for calculations and approval of CII rating should be in the
order of 10 hours. SEEMP Part 3 that includes CII rating is to be updated every three years.

3.5.2 For non-compliance

In addition to compliance costs, an additional corrective action plan has to be made
as discussed in the previous section. Pending on the severity of the outcome, this could
take 10-100 hours plus of course the costs for complying, ranging from a small
operational measure to a complete refit required.

Overall impact on costs and operations seems limited however, as currently only a
corrective action plan is required. No penalties are incurred upon non-compliance.
Technically speaking, the Administration or Recognized Authority could withhold issuing
the State of Compliance upon non-compliance, but upon delivery of an approved plan
this should not be an issue.

It seems therefore that until revision of CII in 2025, cost impact of CII is mostly limited to
administrative work.

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4.0 FREQUENTLY ASKED QUESTIONS

 The below frequently asked questions are a collection of questions from DNV,
ClassNK, Lloyd’s and the Sustainable Ships platform.
 Use the Regulator AI to ask and clarify more questions.

4.1 What is CII?

The Carbon Intensity Indicator (CII) is a measure of how efficiently a ship transports
goods or passengers and is given in grams of CO2 emitted per cargo-carrying capacity
and nautical mile. The ship is then given an annual rating ranging from A to E, whereby
the rating thresholds will become increasingly stringent towards 2030. The CII applies
to all cargo, RoPax and cruise ships above 5,000 GT. The yearly CII is calculated based
on reported IMO DCS data and the ship is given a rating from A to E. For ships that
achieve a D rating for three consecutive years or an E rating in a single year, a corrective
action plan needs to be developed as part of the SEEMP and approved.

4.2 How is CII calculated?

CII is calculated as the amount of CO2 emitted in grams per ton of cargo and nautical
mile. Correction factors will be added to the CII calculation in a separate guideline that
will be developed next year.

For the time being, using actual cargo carried rather than capacity (i.e. the EEOI) can
only be reported voluntarily and not for CII rating purposes.

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4.3 To which ship types does CII apply?

CII applies to ships above 5,000 GT of the following ships types:

• Bulk carriers
• Gas carriers
• Tankers
• Container ships
• General cargo ships
• Refrigerated cargo carriers
• Combination carriers
• LNG carriers
• Vehicle carriers
• Ro-Ro cargo vessels
• Ro-Ro passenger vessels
• Cruise passenger ships

4.4 Is verification of the CII to be carried out by the ships' Classification Society or may
this be done by another Recognized Organization (RO)?
Verification of the CII may be carried out by another RO than the one that Classes the
ship, since this is a verification that can be carried out remotely. It should however be
the same verifier as for IMO Data Collecting System for fuel oil consumption of ships
(IMO DCS) since the CII is to be calculated based on the collected and reported ship
fuel oil consumption data which has been submitted to the DCS.

4.5 Is an additional authorization for the RO's necessary for attained CII verification?
the RO's are already authorized to conduct the surveys and to issue the certificates as
regulated in MARPOL Annex VI, and the new requirements regarding EEXI and CII are
amendments to MARPOL Annex VI, no separate authorization is required. The Appendix
to Annex 1 to the Agreement between the NL and RO dated 03 April 2014 already provides
for this (link).

4.6 Which CII is to be used for a ship which may fall into more than one ship category?
For ships which are falling into more than one categories of ships, as per MARPOL Annex
VI, regulation 28(.1), the most stringent attained annual operational CII, as calculated
for the categories the ship may fall into, shall be used.

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4.7 Can time in port be included in the voyage period for when applying voyage
adjustments?
When an ice-classed ship sails in ice conditions to and from a port within the same sea
area within the same ice edge.

• the period of time the ship is in that port (port period) may be included in either
the voyage period to that port or the voyage period from that port; and
• all fuel consumption for that port period may be included in the voyage
adjustment to the calculation of the attained annual operational CII.

4.8 Why does the CII use 2019 as a reference and not 2008 like the IMO GHG Strategy?
The reference year for CII is 2019 because this is the first year with verified DCS data
reported to the IMO. Otherwise, the reference line would have to be established based
on highly uncertain AIS data. The reduction factors are relative to 2019 and are adjusted
considering achieved improvements between 2008 and 2019.

4.9 What is the difference between the CII and the EEXI?
The EEXI is a one-time certification equivalent to the EEDI (Energy Efficiency Design
Index) phase 2 or 3 concerning design parameters of the vessels. The CII is an
operational indicator and will be assessed annually from 2023 with yearly stricter
emission limits. The EEXI and CII are applicable to the same ship types. The difference is
that CII ratings will apply to ships 5,000 GT and above regardless of propulsion type.
Learn more here.

4.10 What is the relation between the CII, IMO DCS and SEEMP?
CII can be viewed as part of a strengthening of the SEEMP (Ship Energy Efficiency
Management Plan), referred to by some as the ‘enhanced SEEMP’. The intention is to
ensure continuous improvement of energy efficiency and to lower carbon intensity. The
enhanced SEEMP shall include an implementation plan on how to achieve the CII targets
(called the Ship Operation Carbon Intensity Plan) which will be subject to approval and
company audits. CII calculations are based on data collection in IMO DCS. Learn more
here.

4.11 Can consumption due to avoidance of bad weather be deducted from CII calcs?
According to the published IACS guidelines on CII correction factors, adverse
weather/tropical storm/cyclones are not considered as a reason to use FC-voyage
correction factor. Therefore, consumption related to avoidance of bad weather cannot
be deducted from CII.

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4.12 My vessel did not meet the Required CII and got a D-Rating. What are the
consequences?
Currently, there are no consequences announced by IMO for not meeting the Required
CII and receiving a D-Rating for your vessel's performance in the previous reporting
year. If a vessel would get a D-Rating 3 years in a row, you would be obliged to submit
a SEEMP Part III Corrective Actions Plan before DCS Statement of Compliance can be
issued. The situation may change after revision of the regulations from IMO in 2025.

4.13 How will my vessel's CII be calculated in case of major conversion?

In case of a ship undergone major conversion, including extensive changes of carrying
capacity and/or ship type during the year, defined by regulation 2.2.17 and regarded by
the Administration as a newly constructed ship as per regulation 5.4.3, the required and
attained annual operational CII should be calculated and verified as per a newly
constructed ship for the period after conversion.

For the year of conversion, the attained CII and required CII should be calculated and
verified as per a newly constructed ship for the period after conversion. Data for partial
year before conversion should still be reported for verification but will not be included
in the calculation and verification of the attained annual operational CII.

4.14 Can a period spent dry-docking or anchored be deducted from CII calculations?
No, currently there is no CII correction factor nor voyage adjustment that would deduct
period spent at the dry-dock or anchored from CII calculation. If the vessel was not
connected to an onshore power supply, this period would simply be considered as
consumption without distance travelled.

4.15 Do I need to provide any evidence on reported CII correction factors and voyage
adjustments?
CII correction factors and voyage adjustments reporting will be verified on a case-by-
case basis. In case of uncertainties in reporting, additional documentation or evidence
might be required by the verifier.

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4.16 How will my vessel's CII be calculated in case of change of DWT and/or GT?
In case of DWT and/or GT change, SEEMP Part III to be revised and submitted for
verification. If change of DWT and/ or GT is identified as a CII reducing measure in
SEEMP part III and/ or CAP, all future required annual operational CII should be
calculated and verified using the original DWT or GT value before DWT or GT conversion.

The attained annual operational CII which is to be used to assess compliance should
be calculated and verified using the new DWT or GT value after conversion. Except for
the year of conversion where the attained CII should be calculated and verified based
on the average DWT or GT value weighted on distance travelled before and after
conversion.

If change of DWT and/ or GT IS NOT identified as a CII reducing measure in SEEMP part
III and/ or CAP, required annual operational CII should be calculated and verified using
DWT or GT value after conversion. For the year of conversion, both required CII attained
CII should be calculated and verified based on the average DWT or GT value weighted
on distance travelled before and after conversion.

4.17 What happens to the CII and Reduction Factor (R) after 2026?
As per Q1 2024, this is still unknown. CII requirements will be evaluation in a planned 2025
revision by IMO. Currently, IMO is aiming for approximately 20-30% reduction in 2030
and 100% reduction in 2050. These values are adhered to by Sustainable Ships as a
guideline for the longer term, but a more likely scenario towards 2030 is simply a
continuation of the 2% yearly increase of the Reduction Factor (R).

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5.0 APPENDIX

5.1 References

IMO MEPC.346(78) 2022 Guidelines for development of SEEMP

IMO MEPC.355(78) 2022 Interim guidelines on CII calculations
ClassNK CII (Carbon Intensity Indicator)
DNV CII Frequently Asked Questions
DNV CII – Carbon Intensity Indicator
Bureau Veritas EEXI and CII: dual regulations reducing ship’s carbon impact
Sustainable Ships Emissions calculation guide

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5.2 CII Required

See section 2.4 for more information.

Table 2. d1 - d2 - d3 - d4 for different ship types under different conditions.

Ship type Condition d1 d2 d3 d4

Tanker 0.82 0.93 1.08 1.28

Bulk Carrier 0.86 0.94 1.06 1.18

Combination carrier 0.87 0.96 1.06 1.14

Container Ship 0.83 0.94 1.07 1.19

General Cargo 0.83 0.94 1.06 1.19

Gas Carrier >=65.000 DWT 0.81 0.91 1.12 1.44

Gas Carrier < 65,000 DWT 0.85 0.95 1.06 1.25

LNG Carrier >= 100.000 DWT 0.89 0.98 1.06 1.13

LNG Carrier <100.000 DWT 0.78 0.92 1.10 1.37

RoRo Passenger / Cargo 0.76 0.89 1.08 1.27

RoRo Cargo 0.76 0.89 1.08 1.27

RoRo Passenger 0.76 0.92 1.14 1.30

RoRo Cargo Vehicle Carrier 0.86 0.94 1.06 1.16

Refrigerated Cargo Carrier 0.78 0.91 1.07 1.20

Cruise Passenger Ship 0.87 0.95 1.06 1.16

Table 3. Reduction factors (R) in % for the CII required relative to CII reference from now until 2026. Evaluation
of CII and consequently reduction factor is planned for 2025. The ultimate goal of IMO is to achieve 100% CO2
reduction in 2050, with an intermediate goal of 40% in 2030. This would translate into similar reduction factors,
although these are quite high on such a short timeline.

2023 2024 2025 2026 2027+

Reduction Factor (R) 5% 7% 9% 11% t.b.d.

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