Published 25 April 2026 · last updated 28 April 2026

SEEMP I, II and III

The Ship Energy Efficiency Management Plan (SEEMP) is the ship-specific document required by MARPOL Annex VI Regulation 22 to be kept on board every ship of 400 GT and above engaged on international voyages. Originally introduced by Resolution MEPC.213(63) in March 2012 and entering into force on 1 January 2013, the SEEMP has been progressively expanded to comprise three distinct parts. Part I is the original energy efficiency management plan, a four-step continuous-improvement cycle covering planning, implementation, monitoring and self-evaluation. Part II is the data collection plan for the IMO Data Collection System, added by Resolution MEPC.282(70) in October 2016 and applicable to ships of 5,000 GT and above from 1 March 2018. Part III is the CII operational plan, added by Resolution MEPC.328(76) in June 2021 and applicable to ships of 5,000 GT and above from 1 January 2023, requiring a documented target attained CII for each calendar year, an implementation plan, a self-evaluation procedure and (where the ship is rated D for three consecutive years or E for one year) a written corrective action plan. The three parts together form the operative interface between the ship’s energy and emissions performance and the IMO Net-Zero Framework approved at MEPC 83 in April 2025; the SEEMP is the document that translates regulatory targets into ship-specific action. ShipCalculators.com hosts the principal SEEMP-related calculators: SEEMP Part I, SEEMP Part II / DCS data collection plan, SEEMP Part III, SEEMP combined operational-measures savings, and the CII 3-year corrective action plan trigger. A full listing is available in the calculator catalogue.

Contents

Background and history

Energy management on ships before 2012

Before the SEEMP became mandatory, energy management on ships was largely a commercial discipline driven by bunker prices. The 1973 oil crisis triggered the first systematic shipping-industry interest in fuel-saving operational measures, and through the 1970s and 1980s a body of practice developed around weather routing, slow steaming, hull cleaning, trim optimisation and just-in-time arrival. This practice was codified in the late 1990s into the Ship Operating Cost Index (SOCI) maintained by INTERCARGO and the Cost Per Mile model maintained by BIMCO.

Operational practice was supplemented in the early 2000s by the Energy Efficiency Operational Indicator (EEOI), developed by the IMO Sub-Committee on Bulk Liquids and Gases (BLG, now PPR) and adopted by Resolution MEPC.1/Circ.471 in 2005 and finalised by MEPC.1/Circ.684 in 2009. The EEOI is the ratio of CO₂ emissions to transport work, expressed in g CO₂ per tonne-mile, and it became the standard voluntary metric for ship-level operational efficiency monitoring through the late 2000s.

Resolution MEPC.213(63) and the original SEEMP (2012)

The 2011 MARPOL Annex VI Chapter 4 amendments (Resolution MEPC.203(62), 15 July 2011, in force 1 January 2013) introduced the legal requirement for every ship of 400 GT and above to keep an SEEMP on board. The implementing guidelines were adopted by Resolution MEPC.213(63) on 2 March 2012, providing the ship-type-specific structure and content of the plan. The 2012 SEEMP was a single-part document focused on the four-step continuous-improvement cycle of planning, implementation, monitoring and self-evaluation, drawing on the Plan-Do-Check-Act (PDCA) cycle of ISO 9001 and ISO 14001 management-system standards.

The 2012 SEEMP was relatively flexible in form. The IMO guidelines specified a minimum content but did not prescribe a specific template; flag-state administrations and Recognised Organisations (typically classification societies) developed their own templates and approval processes. The SEEMP’s principal purpose under the 2012 framework was internal: to encourage ship operators to think systematically about energy efficiency, to document what they were doing, and to provide a basis for self-improvement.

MEPC.282(70) and Part II (2016)

The 2016 amendments to MARPOL Annex VI (Resolution MEPC.282(70), 28 October 2016, in force 1 March 2018) introduced the IMO Data Collection System (DCS) and the corresponding requirement for a ship-specific data collection plan to be approved by the Administration. The data collection plan was structured as a new Part II of the SEEMP, distinguishing it from the energy management plan of Part I.

Part II was applicable only to ships of 5,000 GT and above engaged on international voyages, in line with the IMO DCS scope. The data collection plan was required to describe the methodology that the ship would use to collect the annual fuel consumption data and other parameters required by Regulation 22A (now Regulation 27) of Annex VI. The plan was reviewed and approved by the Administration in accordance with MEPC.292(71) “2017 Guidelines for Administration verification of ship fuel oil consumption data”. The first reporting cycle under the IMO DCS commenced on 1 January 2019, with the first data submissions due by 31 March 2020.

MEPC.328(76) and Part III (2021)

The 2021 amendments to MARPOL Annex VI (Resolution MEPC.328(76), 17 June 2021, in force 1 November 2022 with effect from 1 January 2023) introduced the Carbon Intensity Indicator (CII) regime under Regulation 28 and the corresponding CII operational plan required as a new Part III of the SEEMP under Regulation 26.

Part III is applicable to ships of 5,000 GT and above engaged on international voyages. The plan must include a target attained CII for each calendar year, an implementation plan describing the actions to be taken to achieve the target, a self-evaluation procedure and, where the ship has been rated D for three consecutive years or E for one year, a corrective action plan specifying the additional measures to be implemented. The implementing guidelines for Part III are set out in MEPC.346(78) (2022 Guidelines for the Development of a Ship Energy Efficiency Management Plan, SEEMP), adopted at MEPC 78 on 10 June 2022.

The combined effect of the three parts is that every ship of 5,000 GT and above engaged on international voyages now operates under a three-pillar energy-and-emissions management framework: Part I sets the high-level strategy and operational practices, Part II provides the data infrastructure for performance measurement, and Part III closes the loop through CII-rating-driven target setting and corrective action.

Regulatory basis and applicability

Statutory basis

The SEEMP is required by MARPOL Annex VI Regulation 22 (Parts I and II) and Regulation 26 (Part III). The principal implementing resolutions are:

Resolution MEPC.213(63) of 2 March 2012 - 2012 Guidelines for the Development of a SEEMP. Original guidelines for Part I.
Resolution MEPC.282(70) of 28 October 2016 - Amendments to MARPOL Annex VI introducing Regulation 22A and the data collection plan of Part II.
Resolution MEPC.292(71) of 7 July 2017 - 2017 Guidelines for Administration verification of ship fuel oil consumption data. Implementing guidance for Part II.
Resolution MEPC.328(76) of 17 June 2021 - Amendments to MARPOL Annex VI introducing the EEXI, CII and SEEMP Part III.
Resolution MEPC.346(78) of 10 June 2022 - 2022 Guidelines for the Development of a Ship Energy Efficiency Management Plan (SEEMP). Replaces MEPC.213(63) and provides the consolidated guidance for all three parts.
Resolution MEPC.347(78) of 10 June 2022 - 2022 Guidelines for Administration verification of CII reporting and rating.

Applicability

SEEMP part	Ship size threshold	Voyage scope	Effective from
Part I	400 GT and above	International voyages	1 January 2013
Part II	5,000 GT and above	International voyages	1 March 2018 (data collection from 1 January 2019)
Part III	5,000 GT and above	International voyages	1 January 2023

Ships engaged exclusively on domestic voyages are not subject to the SEEMP requirement, although a number of flag states (Norway, the Netherlands, Singapore, the United States) have implemented analogous requirements under domestic law for ships in their cabotage trades.

The IAPP Certificate, IEE Certificate and Statement of Compliance under MARPOL Annex VI Regulations 6 and 8 record SEEMP availability and approval. The IAPP certificate calculator and the survey calculator implement the certification cycle.

SEEMP Part I: Energy efficiency management plan

Four-step continuous-improvement cycle

The Part I framework is built on a four-step cycle:

Planning - identification of energy-efficiency measures applicable to the ship and the trade pattern; setting of measurable goals and timescales.
Implementation - execution of the planned measures, with documented procedures and responsibilities.
Monitoring - measurement of energy-efficiency performance using suitable indicators (typically the EEOI for voluntary monitoring, plus the IMO DCS data set for mandatory reporting).
Self-evaluation and improvement - review of the monitoring results, identification of areas for improvement and update of the plan for the next cycle.

The cycle mirrors the Plan-Do-Check-Act framework of ISO 9001 (quality management) and ISO 14001 (environmental management). Many shipping companies have implemented the SEEMP Part I as a sub-plan within their existing ISO 14001-certified Environmental Management System, leveraging the audit infrastructure of the parent system.

Planning phase

The planning phase requires the ship operator to identify energy-efficiency measures applicable to the specific ship and trade pattern. The 2012 IMO guidelines and the 2022 update under MEPC.346(78) list candidate measures grouped into:

Voyage optimisation: weather routing, just-in-time arrival, route optimisation, slow steaming.
Hull and propeller maintenance: hull cleaning, propeller polishing, antifouling renewal, drydock cycle optimisation.
Trim and ballast optimisation: trim optimisation software, ballast water management for trim, draft adjustment.
Engine and machinery: engine tuning, slow steaming optimisation, waste heat recovery, shaft generator usage, optimised electrical load profile.
Cargo handling: cargo heating optimisation, refrigerated cargo temperature management, cargo loading/unloading efficiency.
Other: fuel selection (for ECAs and for Net-Zero Framework compliance), in-port energy management, equipment upgrades.

The SEEMP combined operational-measures calculator implements the standard non-overlapping savings formula for combining the percentage contributions of multiple operational measures. Each measure is characterised by its expected percentage saving on baseline fuel consumption; the combined effect is computed as 1 - Π(1 - s_i ) where s_i is the fractional saving of measure i.

Implementation phase

The implementation phase requires the ship operator to put the planned measures into effect, with documented procedures and responsibilities. Typical implementation documentation includes:

Standing orders to the master regarding speed limits, weather routing service usage and JIT arrival protocols.
Cargo handling procedures incorporating fuel-efficiency considerations.
Maintenance schedules for hull cleaning, propeller polishing and engine tuning.
Crew training records demonstrating familiarity with energy-efficiency measures.

The implementation phase is verified at the annual SEEMP review and at port state control inspections targeting Annex VI compliance.

Monitoring phase and the EEOI

The monitoring phase requires the ship operator to track energy-efficiency performance over time. The principal voluntary indicator is the Energy Efficiency Operational Indicator (EEOI), defined as:

EEOI = total CO₂ emissions / (mass of cargo carried × distance travelled)

with units of g CO₂ per tonne-mile (or g CO₂ per TEU-mile for container ships, g CO₂ per passenger-mile for passenger ships, g CO₂ per car-mile for vehicle carriers, etc.). The EEOI is calculated on a per-voyage basis and aggregated across multiple voyages to give a representative annual figure for the ship. Unlike the CII, which is mandatory and uses deadweight as the denominator, the EEOI uses actual cargo mass and is therefore more sensitive to load-factor variation.

The mandatory monitoring under SEEMP Part II uses the IMO DCS data set, which provides annual fuel consumption, hours under way and distance travelled. The combination of EEOI and CII gives a comprehensive monitoring view.

Self-evaluation and improvement

The self-evaluation step requires the ship operator to compare actual performance against the planned targets and to identify areas for improvement in the next cycle. The self-evaluation is documented in the SEEMP and is reviewed at the annual SEEMP audit.

The 2022 update under MEPC.346(78) introduced a more structured self-evaluation requirement, with mandatory reporting of:

Achievement of the target attained CII (Part III).
Effectiveness of the implemented operational measures.
Lessons learned and recommended changes for the next cycle.
Updated implementation plan for the following calendar year.

SEEMP Part II: Data collection plan

Data scope

Part II describes the methodology that the ship will use to collect the annual data required by Regulation 27 of MARPOL Annex VI and submitted to the IMO Ship Fuel Oil Consumption Database. The data set is set out in Appendix IX of the annex and includes:

IMO number and period covered (calendar year, 1 January to 31 December).
Ship-type-specific transport-work parameters: deadweight or capacity (tonnes or TEU or passengers); distance travelled (nautical miles); hours under way.
Fuel oil consumption by fuel type, in metric tonnes. The standard fuel categories are: HFO, LFO, MDO/MGO, LNG, LPG (propane), LPG (butane), methanol, ethanol, others (with sub-classification).
Methodology of fuel consumption measurement: selected from four prescribed methods (BDN reconciliation; flow meter; bunker tank monitoring; engine fuel rack indication).
EEDI value (where applicable) and ice class (where applicable).
EEXI value and CII attained (added by the 2021 amendments for ships from 2023).

Measurement methodology

Part II must specify which of the four IMO-prescribed methods is used for each fuel type. The four methods are:

Method 1 (BDN): Bunker Delivery Note reconciliation. Annual fuel consumption is calculated as initial-year ROB plus all bunkers received minus end-year ROB. Suitable for ships with large bunker tanks and infrequent bunkering.
Method 2 (flow meter): Direct measurement of fuel consumption using calibrated flow meters on the engine fuel inlet line. Most accurate but requires installation and calibration.
Method 3 (bunker tank monitoring): Periodic level measurement of bunker tanks, with consumption calculated by tank-level differences. Less accurate than Method 2 but easier to implement.
Method 4 (engine fuel rack indication): Calculation of fuel consumption from engine-rack position and engine-running hours. Suitable for backup or secondary verification only.

The BDN reconciliation calculator implements Method 1; the bunker quality dispute calculator addresses BDN integrity disputes that affect Method 1 accuracy.

Data quality assurance

Part II must describe the quality assurance procedures that the ship will follow, including:

Cross-check of fuel consumption against engine-hours and against BDN data.
Periodic verification of flow meters and tank-level sensors.
Documentation of any deviations or anomalies.
Master’s annual review and sign-off of the data set.

The 2017 IMO Guidelines (MEPC.292(71)) provide the detailed verification framework, used by classification societies and other Recognised Organisations to confirm compliance with Part II.

Reporting cycle and Confirmation of Compliance

The reporting cycle under Part II is:

31 December: end of reporting period (calendar year).
By 31 March of the following year: ship submits the verified data set to its flag Administration.
By 31 May: flag Administration verifies the data and forwards to the IMO Ship Fuel Oil Consumption Database.
By 30 June: IMO Secretariat issues the Statement of Compliance to the flag Administration, which forwards it to the ship operator.

The Statement of Compliance is required for the ship’s IAPP renewal survey and, in practice, for charter-party purposes. The IMO DCS report calculator implements the annual data submission.

SEEMP Part III: CII operational plan

Target attained CII

Part III requires the master to set a target attained CII for each calendar year, expressed in the same units as the CII attained (g CO₂ per (capacity-nautical-mile)). The target must be at or below the Required CII for the year (a “C” rating or better). For ships at risk of being rated D or E, the target should be set at the boundary required to achieve a C rating.

The target attained CII is set on a three-year forward-looking basis, with annual updates. The plan must explain the basis for the target (historical performance, planned operational improvements, planned technical retrofits, etc.) and the assumptions underlying it.

Implementation plan

The implementation plan describes the specific actions the master and crew will take to achieve the target. The 2022 IMO guidelines (MEPC.346(78)) require the implementation plan to cover:

Operational measures: speed management, weather routing, hull cleaning frequency, trim optimisation, JIT arrival protocols, cargo loading optimisation.
Technical measures: planned retrofits, propeller polishing, engine tuning, energy-saving devices.
Fuel switching: planned use of low-carbon fuels (biofuels, bio-LNG) and the percentage of total energy expected from these sources.
Operational restrictions: any limitations imposed by charter party, regulatory or commercial constraints.

The SEEMP combined operational-measures calculator supports the quantification of the combined savings from multiple measures, providing the input for the target setting and implementation plan.

Self-evaluation procedure

The self-evaluation procedure describes how the ship operator will measure progress against the target during the year. The 2022 IMO guidelines require:

Quarterly review of attained CII trajectory against target.
Annual review of overall performance and corrective action where the trajectory diverges from target.
Documentation of the self-evaluation in the SEEMP.

Corrective action plan triggers

Where the ship is rated D for three consecutive years or E for one year, Regulation 28.10 of MARPOL Annex VI requires the master to produce a written corrective action plan as part of the next annual SEEMP Part III review. The corrective action plan must:

Identify the root causes of the underperformance.
Specify the additional measures to be implemented (typically a combination of operational, technical and fuel-switching measures).
Set a timeline for achieving a C rating.
Be approved by the Administration or its Recognised Organisation at the next survey.

The CII 3-year corrective action plan calculator implements the trigger logic and the structure of the corrective action plan as specified in MEPC Circular MEPC.7/Circ.16.

Documentation of operational measures

The 2022 IMO guidelines provide a template for documenting operational measures within the implementation plan. Each measure is characterised by:

A description of the measure.
The expected percentage saving on baseline fuel consumption.
The implementation timeline (start date, full deployment date).
The responsible party (master, chief engineer, ship operator, charterer).
The verification method (how the measure’s effectiveness will be confirmed).

The SEEMP Part III calculator implements the documentation framework.

Verification and survey

IAPP / IEE survey integration

SEEMP availability is verified at the initial survey and at each annual survey under MARPOL Annex VI Regulations 5 and 8. The verification confirms that:

A current SEEMP is available on board (Part I for all ships ≥ 400 GT; Parts I, II and III for ships ≥ 5,000 GT engaged on international voyages).
The SEEMP has been approved by the Administration or its Recognised Organisation.
The plan reflects the actual operations of the ship.
The corresponding implementation, monitoring and self-evaluation records are available.

The survey calculator and the IAPP certificate calculator implement the survey-cycle logic. The IEE Certificate (introduced by the 2011 amendments) records the SEEMP and the EEDI / EEXI compliance status.

Port state control

Port state control inspectors verify SEEMP compliance under the regional Memoranda of Understanding (Paris MOU, Tokyo MOU, USCG). The Paris MOU 2020 Concentrated Inspection Campaign (CIC) on Annex VI compliance found that approximately 8% of inspected ships had SEEMP-related deficiencies, predominantly relating to:

Outdated SEEMP not reflecting current operational practices.
Missing implementation records (no evidence of operational measures being applied in practice).
Missing self-evaluation records.
For ships subject to Part III, missing or incomplete CII operational plan.

The PSC NOx calculator implements the port-state-control inspection-targeting logic for Annex VI compliance.

Recognised Organisation role

Classification societies and other Recognised Organisations conduct most SEEMP approvals and verifications under formal authorisation from flag administrations. The IACS Common Procedural Requirements (PR 39 for Annex VI) harmonise the SEEMP approval process across the major class societies, ensuring consistent application regardless of flag.

Practical implementation: operational measures

Speed management and slow steaming

Slow steaming is the single most powerful operational lever for fuel and CO₂ reduction. The cubic relationship between speed and fuel consumption (P ∝ v³ for the resistance-dominant high-speed regime) means that a 10% speed reduction produces approximately a 27% reduction in main-engine power demand. The engine cube-law fuel calculator implements the relationship.

Typical SEEMP Part III implementations include speed management protocols specifying:

Service-speed limits for normal operations.
Weather-dependent speed adjustments (slowing in head winds and seas).
Emergency response procedures permitting speed increases in safety-critical situations.
Voyage-economic speed optimisation (balancing fuel cost against time-charter daily hire).

Weather routing

Weather routing services (provided by Applied Weather Technology, MeteoGroup, StormGeo and others) provide voyage-by-voyage routing recommendations that balance distance, time and fuel consumption. Typical fuel savings reported in industry case studies are in the range of 2% to 5% on long-distance voyages (e.g. trans-Pacific or trans-Atlantic), with higher savings of 5% to 10% achievable in seasonally challenging routes (e.g. winter North Atlantic).

Hull cleaning and propeller polishing

Hull biofouling progressively increases hull resistance and therefore fuel consumption. Typical fuel-consumption penalties for an unmaintained hull are in the range of 10% to 30% over a five-year drydock cycle. Periodic hull cleaning (using a remotely-operated cleaner) and propeller polishing can recover 80% to 90% of the lost performance. Typical SEEMP implementations include:

Hull cleaning every 6 to 12 months for ships in warm-water trades.
Propeller polishing every 12 to 24 months.
Antifouling renewal at each drydock (every 5 years for most ship types).

Trim optimisation

The optimum trim of a ship varies with speed, draft and cargo distribution. Trim optimisation software (e.g. FORCE Technology FlowTechZ, NAPA Logbook, Eniram Trim) uses real-time hydrodynamic models to recommend the optimum trim for current operating conditions. Typical fuel savings are in the range of 1% to 4%.

Just-in-time arrival

Just-in-time (JIT) arrival means slowing the ship to arrive at the pilot station precisely when berth is available, rather than racing to anchor and waiting. JIT requires coordination with the port and the cargo handling operation, supported by digital communication platforms (e.g. PortXchange, Pronto). Typical fuel savings are in the range of 2% to 7%, depending on the trade pattern and the typical wait time at the destination.

Combined savings

Operational measures are typically combined within a SEEMP Part III implementation plan. The combined fuel saving from multiple non-overlapping measures is computed as:

Combined saving = 1 - Π (1 - s_i )

where s_i is the fractional saving of measure i. The SEEMP combined operational-measures calculator implements this formula for the standard set of measures (slow steaming, weather routing, hull cleaning, trim optimisation, JIT arrival, fuel switching, energy-saving devices) and reports the equivalent CII improvement and annual cost saving in USD.

A typical bulk carrier implementing slow steaming (10% saving), weather routing (3% saving), hull cleaning (5% saving), trim optimisation (2% saving) and JIT arrival (4% saving) would achieve a combined saving of approximately 22% on baseline fuel consumption, equivalent to a 22% reduction in attained CII and approximately USD 700,000 annual saving for a ship consuming 10,000 t HFO at USD 600/t.

Charter-party considerations

BIMCO CII clauses (2022)

The BIMCO CII Clause for Time Charters, published in November 2022, addresses the practical issue of the CII rating being driven primarily by charterer-controlled operational decisions (speed, route, port choice) while the regulatory consequence falls on the shipowner. The clause:

Requires the charterer to provide voyage instructions consistent with achieving a C rating.
Allows the shipowner to modify voyage instructions (including reducing speed) to maintain the rating.
Allocates the cost and CII consequences of the charterer’s instructions.

The clause has been widely adopted in time charters from 2023 and is now standard in the major dry-bulk trades. The companion BIMCO EU ETS Clause addresses the parallel issue under EU ETS Maritime.

Voyage charter considerations

For voyage charters, the CII consequences of a single voyage are typically minor (a single voyage rarely changes the annual rating). The principal SEEMP-related considerations in voyage charters are:

The bunker quality and sulphur compliance (addressed by Regulation 18 / BDN).
The fuel-switching obligations on entering and leaving ECAs.
The vessel’s compliance with Regulation 14 sulphur limits.

SEEMP and the IMO Net-Zero Framework

The IMO Net-Zero Framework approved at MEPC 83 in April 2025 introduces the GHG Fuel Intensity (GFI) standard and the Remediation Unit pricing mechanism. The interaction with the SEEMP is structured as follows:

SEEMP Part I continues to provide the high-level energy-management framework.
SEEMP Part II continues to provide the IMO DCS data infrastructure, with extensions for the GFI-specific data points (fuel pathway certification, methane slip measurement where applicable).
SEEMP Part III continues to provide the CII operational plan, complemented by a new SEEMP Part IV covering the GFI compliance plan.

The new SEEMP Part IV (GFI Operational Plan) will be added as part of the implementing guidelines to be adopted at MEPC 84 in October 2025. The expected structure mirrors Part III: a target attained GFI for each year, an implementation plan covering fuel switching and operational measures, a self-evaluation procedure, and a corrective action plan triggered by RU obligation thresholds.

The GFI compliance calculator and the GFI attained calculator provide the computational basis for SEEMP Part IV target setting and self-evaluation.

Industry guidelines and best practices

IMO MEPC.346(78) Guidelines

The 2022 IMO Guidelines for the Development of a SEEMP (MEPC.346(78)) consolidate the previous guidance from MEPC.213(63), MEPC.282(70) and MEPC.328(76) into a single document. The Guidelines provide:

The structure and content of the three parts.
A model SEEMP template.
Sample operational measures with typical savings ranges.
Sample data collection methodology descriptions.
Sample CII operational plan structures.

Class society guidance

The IACS member classification societies have issued their own SEEMP guidance documents:

ABS: Energy Efficiency Management Plan Guidance (2023 edition).
DNV: SEEMP III Best Practices Guide (2023 edition).
Lloyd’s Register: SEEMP Guidance for Owners and Operators (2023 edition).
Bureau Veritas: SEEMP Implementation Guide (2023 edition).
ClassNK: SEEMP Part III Approval Guidance (2023 edition).
Korean Register: Energy Management Plan Manual (2024 edition).
China Classification Society: SEEMP Approval Procedures (2024 edition).
Russian Maritime Register: SEEMP Guide for Russian Flag Vessels (2023 edition).

Industry initiatives

International Chamber of Shipping (ICS): ICS SEEMP Guide (4th edition, 2023) is the most widely-used industry-level reference.
BIMCO: provides standard SEEMP templates for time-charter and voyage-charter operations, integrated with the BIMCO CII Clause.
INTERCARGO: Bulk Carrier SEEMP Guidance focused on the specific operational considerations of dry bulk trades.
INTERTANKO: Tanker SEEMP Guidance focused on tankers and the specific ECA/IMO 2020 fuel-switching considerations.
World Shipping Council: provides container-shipping-specific guidance.
CLIA: provides cruise-vessel-specific guidance.

Critical assessment

Has the SEEMP delivered measurable efficiency gains?

The Fourth IMO GHG Study (2020) attributes approximately 9% of the 2008-to-2018 reduction in shipping carbon intensity to the SEEMP and the broader Annex VI Chapter 4 framework. The principal contributions come from:

Increased adoption of slow steaming as the standard operational practice.
Wider use of weather routing services.
Increased frequency of hull cleaning.
Better trim management through software tools.

The SEEMP’s principal limitation as a regulatory instrument is its prescriptive flexibility: the regulation requires a plan but does not specify the content in detail, leaving the substantive choices to the ship operator. This flexibility is intentional (allowing adaptation to ship-specific circumstances) but it also means that compliance is sometimes superficial. The 2021 introduction of the CII rating addressed this by linking the SEEMP Part III to a measurable annual outcome.

Is the audit infrastructure adequate?

The audit infrastructure for the SEEMP has been strengthened substantially since 2018, with the IMO DCS providing an objective data set that can be cross-checked against the SEEMP Part III target. Class society audit teams have grown rapidly through 2022 to 2025 to meet the demand for SEEMP Part III approval and verification.

The principal remaining gap is in the verification of operational measures: while the SEEMP documents the planned measures, verification that they are actually applied in practice requires either continuous monitoring (which adds cost and complexity) or sampling-based verification (which is statistically uncertain). The IMO is considering tightening the verification framework as part of the implementing guidelines for the Net-Zero Framework.

Industry positions

Industry positions on the SEEMP are generally supportive, with the principal points of debate being:

Burden of proof: should the ship operator bear the burden of proving that operational measures are being applied, or should the regulator bear the burden of proving they are not?
Charterer responsibility: how should the responsibility for SEEMP outcomes be allocated between shipowner and charterer?
Measurement uncertainty: how should the SEEMP handle the inherent measurement uncertainty in fuel consumption (typically ±2% to ±5%)?

These questions are addressed pragmatically in the BIMCO clauses and in the class society guidance documents but remain open at the IMO regulatory level.

Future outlook

The principal regulatory developments expected through 2030 are:

MEPC 84 (October 2025): adoption of SEEMP Part IV (GFI Operational Plan) implementing guidelines, in parallel with the formal adoption of the Net-Zero Framework.
MEPC 85 (mid-2026): revision of MEPC.346(78) to incorporate the SEEMP Part IV structure and the GFI-specific data points for SEEMP Part II.
MEPC 86 (late 2026 / early 2027): review of CII reduction factors beyond 2026; coordination with SEEMP Part III implementation.
MEPC 90 (2030): comprehensive 5-year review of the SEEMP framework against actual implementation experience.

By 2030 the SEEMP framework is expected to have evolved from its current four-pillar structure (Parts I, II, III plus the new Part IV) into a more integrated regulatory tool that ties together energy management, data collection, CII rating and GFI compliance in a single document. The 2030-to-2040 trajectory under the Net-Zero Framework will impose much steeper compliance demands on the SEEMP, with operational measures alone unlikely to be sufficient and fuel switching becoming the dominant compliance lever.

References

IMO MEPC. Resolution MEPC.213(63) - 2012 Guidelines for the Development of a Ship Energy Efficiency Management Plan (SEEMP). IMO, 2 March 2012.
IMO MEPC. Resolution MEPC.282(70) - Amendments to MARPOL Annex VI (Regulation 22A and the data collection system). IMO, 28 October 2016.
IMO MEPC. Resolution MEPC.292(71) - 2017 Guidelines for Administration verification of ship fuel oil consumption data. IMO, 7 July 2017.
IMO MEPC. Resolution MEPC.328(76) - Amendments to MARPOL Annex VI (EEXI, CII, SEEMP Part III). IMO, 17 June 2021.
IMO MEPC. Resolution MEPC.346(78) - 2022 Guidelines for the Development of a Ship Energy Efficiency Management Plan (SEEMP). IMO, 10 June 2022.
IMO MEPC. Resolution MEPC.347(78) - 2022 Guidelines for Administration verification of CII reporting and rating. IMO, 10 June 2022.
IMO. MARPOL Consolidated Edition 2022, Annex VI Chapter 4. IMO, London, 2022.
IMO. Fourth IMO GHG Study 2020. IMO, London, 2020.
International Chamber of Shipping. ICS Guidance on the Development of a Ship Energy Efficiency Management Plan (SEEMP). 4th edition, ICS, London, 2023.
BIMCO. BIMCO CII Clause for Time Charters. BIMCO, Copenhagen, November 2022.
BIMCO. BIMCO EU ETS Clause for Time Charters. BIMCO, Copenhagen, 2023.
INTERCARGO. Bulk Carrier SEEMP Guidance. INTERCARGO, London, 2023.
INTERTANKO. Tanker SEEMP Guidance. INTERTANKO, London, 2023.
ABS. Guide for Energy Efficiency Management Plan. ABS, Houston, 2023.
DNV. SEEMP III Best Practices Guide. DNV, Oslo, 2023.
Lloyd’s Register. SEEMP Guidance for Owners and Operators. Lloyd’s Register Marine, London, 2023.

External links

IMO Energy Efficiency Page - official IMO energy-efficiency landing page
IMO Resolution MEPC.346(78) PDF - 2022 SEEMP Guidelines
BIMCO CII Clause - standard charter-party clause
ICS Library - ICS SEEMP Guide
IACS Common Procedural Requirements - PR 39 Annex VI procedures