CircularsNews
March 2010

Yeni liman cüzdanları nedeniye Brezilya limanında karsılıasılması muhtemel sorunlar

The European Union’s Emissions Trading System (EU ETS) was extended to cover emissions from shipping as of 1st January 2024.

The EU ETS is limited by a 'cap' on the number of emission allowances. Within the cap, companies receive or buy emission allowances, which they can trade as needed. The cap decreases every year, ensuring that total emissions fall.

Each allowance gives the holder the right to emit:

  • One tonne of carbon dioxide (CO2), or;
  • The equivalent amount of other powerful greenhouse gases, nitrous oxide (N2O) and perfluorocarbons (PFCs).
  • The price of one ton of CO2 allowance under the EU ETS has fluctuated between EUR 60 and almost EUR 100 in the past two years. The total cost of emissions will vary based on the cost of the allowance at the time of purchase, the vessel’s emissions profile and the total volume of voyages performed within the EU ETS area. The below is for illustration purposes:
  • ~A 30.000 GT passenger ship has total emissions of 20.000 tonnes in a reporting year, of which 9.000 are within the EU, 7.000 at berth within the EU and 4.000 are between the EU and an outside port. The average price of the allowance is EUR 75 per tonne. The total cost would be as follows:
  • ~~9.000 * EUR 75 = EUR 675.000
  • ~~7.000 * EUR 75 = EUR 525.000
  • ~~4.000 * EUR 75 * 50% = EUR 150.000
  • ~~Total = EUR 1.350.000 (of which 40% is payable in 2024)
  • For 2024, a 60% rebate is admitted to the vessels involved. However, this is reduced to 30% in 2025, before payment is due for 100% with effect from 2026.
  • Emissions reporting is done for each individual ship, where the ship submits their data to a verifier (such as a class society) which in turns allows the shipowner to issue a verified company emissions report. This report is then submitted to the administering authority, and it is this data that informs what emission allowances need to be surrendered to the authority.
  • The sanctions for non- compliance are severe, and in the case of a ship that has failed to comply with the monitoring and reporting obligations for two or more consecutive reporting periods, and where other enforcement measures have failed to ensure compliance, the competent authority of an EEA port of entry may issue an expulsion order. Where such a ship flies the flag of an EEA country and enters or is found in one of its ports, the country concerned will, after giving the opportunity to the company concerned to submit its observations, detain the ship until the company fulfils its monitoring and reporting obligations.
  • Per the EU’s Implementing Regulation, it is the Shipowner who remains ultimately responsible for complying with the EU ETS system.

There are a number of great resources on the regulatory and practical aspects of the system – none better than the EU’s own:

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02003L0087-20230605

https://climate.ec.europa.eu/eu-action/transport/reducing-emissions-shipping-sector_en

https://climate.ec.europa.eu/eu-action/eu-emissions-trading-system-eu-ets/what-eu-ets_en

Degerli ilgili,

Asagıda Skuld'dan alınan sirkuleri bulabilirsiniz.

Alınan bilgilere gore, Turkiye Deniz Otoritelerinin yenilenen liman cuzdanları hakkında hali hazırda diplomatik yollarla Brezilya Hukumetini bilgilendirmis  olmalarına ragmen, Paranagua/Brezilya limanına yanasan bir Turk gemisine yeni liman cuzdanı olan bir personel nedeniyle ceza kesilmistir. Konu hadise halen sorusturma asamasında olup cezanın geri cekilmesi soz konusu ancak yine de  Brezilya limanlarına gidecek Turk Gemilerinin alması tavsiye edilen onlemler asagidaki kulup sirkulerinde ozetlenmistir.

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WEB ALERT: BRAZIL - TURKISH SEAFARERS

Published 17.03.2010

We have just been advised that the Brazilian Immigration Authorities in Paranagua have imposed a fine on a Turkish flag vessel carrying a crew with the new Turkish Seaman Books.

The matter is still under investigation, and although we hope it will be possible to persuade the local authorities to recall their demands, we have found it prudent to bring the matter to the attention of those of our members who employ Turkish seafarers on vessels that are likely to call Brazil.

As we understand the facts, the Turkish Maritime Authorities have duly notified the Brazilian Government of the new Seaman Books via the usual diplomatic channel, but the information has apparently not been communicated from the central Brazilian authorities to the local immigration authorities.

If you have a vessel likely to call Brazil in the near future, we suggest the following:

To obtain a copy (in the Portuguese language) of the notification sent by the Turkish Embassy in Brazil to the central Brazilian Government, and to the extent possible a copy of the message whereby the notification is acknowledged by the Brazilian Ministry of Foreign Affairs.

A copy of these documents should be kept onboard the vessel, and the master should be instructed to bring the correspondence to the attention of the Immigration authorities prior to their examination of the seaman books onboard the vessel.

Your local agents in the port of call should be alerted to the above problem, and the documentation carried on board.

SKULD Copenhagen
Claims and FD&D

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