TECHNICAL AND REGULATORY NEWS No.
32/2024 – STATUTORY
ENERGY EFFICIENCY COMPLIANCE
AFTER ALTERATIONS OR CONVERSIONS
Relevant for ship owners and managers as well as flag states. December 2024
The EEXI requirement came into effect on 1 January 2023, and all affected ships should now
comply. To maintain compliance, any ship undergoing changes that affect its EEXI and/or EEDI
may need to recalculate these. This statutory news outlines impacts on and necessary actions for
energy efficiency certification following ship modifications.
What is a “major conversion”? the ship to meet the EEDI requirements by using the reduc-
Under MARPOL Annex VI (Regulation 5.4), the Energy Effi- tion factor corresponding to the contract date of the conver-
ciency Existing Ship Index (EEXI) and, if relevant, the Energy sion. In such cases, a ship originally subject only to the EEXI
Efficiency Design Index (EEDI), must be recalculated and sur- will also need to comply with the EEDI, and a ship already
veyed on board in the event of a major conversion, as defined subject to the EEDI may face a more stringent EEDI require-
in Regulation 2.2.17. ment (a higher EEDI phase). However, most major conversions
will not fall into this extensive category.
A major conversion includes:
• Any substantial change in hull dimensions or capacity, Approval of EEXI/EEDI Technical File
except a decrease of assigned freeboard if no other altera- If the conversion is considered major, the EEXI and, if rele-
tions to the ship structure are made. vant, the EEDI should be recalculated, and the new Technical
• Any substantial increase in total engine power for propul- File(s) submitted for approval. Any necessary actions to meet
sion (5% or more). the requirements should be included in the project, such as
• A change of the MARPOL ship type as noted on the Interna- limiting the propulsion power. If installing a new or adjust-
tional Energy Efficiency Certificate (IEEC). ing an existing overridable power limitation, an approved
• A conversion intended to substantially prolong the life of Onboard Management Manual (OMM) for Shaft Power
the ship. Limitation (SHaPoLi) or Engine Power Limitation (EPL) will be
• Significant modifications that would require the ship to required.
meet new requirements as if it were newly built.
• Any substantial alterations impacting energy efficiency, For ships subject to the EEDI, if the new attained EEDI is equal
such as modifications that could cause the ship to exceed to or less than the new required EEXI, it can be considered
the applicable required EEXI or EEDI (if relevant). the new attained EEXI. Consequently, the attained EEXI will
be verified using the EEDI Technical File, eliminating the need
If it is unclear whether a conversion is considered major, the for a separate EEXI Technical File.
flag administration will have the final say. For typical scenarios
that may constitute a major conversion, please see DNV’s Approval is managed through DNV’s digital EEXI self-service
overview Re-certification of the EEXI. tool on the Veracity platform. This tool can be accessed via
the “Vessel Services” tab under “Fleet Status”. A detailed
EEDI compliance for extensive major conversions guideline on how to use the tool is also available on the same
If a major conversion is so extensive that the ship is consid- page. The only exception is for MARPOL ship type changes,
ered newly constructed, the flag administration may require which are currently not supported by the tool.
DNV AS, Veritasveien 1, 1363 Høvik, Norway, Phone: +47 67 57 99 00, www.dnv.com/maritime DNV Disclaimer of Liability Page 1/2
Survey and certification after ship alteration When DNV serves as both the class and DCS verifier, essen-
Upon completing the alteration, a survey shall be conducted tial data for the CII calculation will be automatically captured
to confirm the new EEXI and, if relevant, the EEDI. This survey upon updating the IEEC. For ships not classed by DNV but
will also verify any measures installed due to the new calcu- where DNV acts as the DCS verifier, a copy of the new IEEC,
lations, such as power limitations. Once the survey is com- along with the new load line certificate if there is a change in
pleted, a new IEEC will be issued to reflect the updates. deadweight, should be submitted via DATE.
The validity of the IEEC will be verified during annual statu- Recommendations
tory surveys. Additionally, the PSC guidelines include checks When planning any alterations, it is essential to determine
to determine if the ship has undergone a major conversion or early on whether the changes will be considered a major con-
if there have been changes affecting aspects covered by the version under MARPOL Annex VI. Assess the potential impact
EEXI or EEDI Technical Files. of the alterations and ensure that the ship remains compliant
upon completion of the alteration.
EEXI/EEDI calculations for non-major conversions
Conversions that have an impact on energy efficiency, but References
which are not considered major conversions, will not require • Re-certification of the EEXI
re-approval of the EEXI/EEDI Technical File(s) or a new IEEC.
• Efficient handling of propeller retrofits
However, re-approving the Technical File(s) and issuing a
new IEEC should be considered to reflect, for example, an • EEXI advisory services by DNV Maritime
improved energy efficiency index, especially in cases where
• EEXI | Energy Efficiency Existing Ship Index
SHaPoLi/EPL installations may be removed, or the power
limitation is reduced. • Energy Efficiency Design Index advisory service
• Energy Efficiency Design Index Calculator
SEEMP/CII for ship alterations
When making alterations, it is important to consider their
impact on the SEEMP III and the CII calculation as well. An
alteration may affect the SEEMP III, which outlines the future
attained and target CII as well as future measures in the
three-year implementation plan. Key parameters used in
the CII equation – such as MARPOL ship type, deadweight
For customers:
and gross tonnage – are particularly important. Therefore, DATE – Direct Access to Technical Experts via My Services on Veracity.
the DCS verifier should be informed in order to make the
Otherwise:
necessary updates and correctly verify the CII to assign an Use our office locator to find the nearest office.
appropriate rating.
APPENDIX:
EEXI vs EEDI
While both the EEXI and the EEDI aim to enhance energy efficiency and reduce emissions, EEXI focuses on improving the
efficiency of ships that are already in service and EEDI targets new ships during their design phase.
EEXI (Energy Efficiency Existing Ship Index) EEDI (Energy Efficiency Design Index)
Applies to:
Certain ship types, including EEDI ships, depending Certain ship types, depending on type of propulsion,
on the type of propulsion and independent of contract contracted on or after 1 January 2013, the requirement
date. becomes stricter over time based on the contact date.
Purpose:
To set energy efficiency standards for existing vessels, To set energy efficiency standards during the design
requiring them to meet these standards through retrofit- and construction phase.
ting and optimization measures.
DNV AS, Veritasveien 1, 1363 Høvik, Norway, Phone: +47 67 57 99 00, www.dnv.com/maritime DNV Disclaimer of Liability Page 2/2
