EU MRV for General Cargo Ships 400–4,999 GT
Since 1 January 2025, smaller general cargo and offshore ships calling EU ports are inside EU MRV. Here is what that actually means for an owner — in plain language, with the deadlines that matter.
Is my ship in scope? (30-second check)
In scope — via the 2025 extension.
General cargo and offshore ships of 400–4,999 GT calling EU/EEA ports are covered by EU MRV since 1 January 2025. You need a monitoring plan, per-voyage monitoring and a verified annual emissions report. CII, IMO DCS and EU ETS do not (yet) apply at this size.
The deadlines that matter
Monitoring started
Per-voyage monitoring became mandatory: fuel consumed, distance sailed, time at sea and cargo carried, for every voyage touching an EU/EEA port. A monitoring plan had to be submitted to an accredited verifier.
First verified emissions report
Your 2025 emissions report — checked by an accredited verifier — must be submitted via THETIS-MRV. This is the first hard filing for the 400–4,999 GT cohort.
Document of Compliance on board
After a satisfactory report, a Document of Compliance is issued and must be carried on board — port state control can ask for it.
What you must do
- 1.Appoint an accredited MRV verifier and get your monitoring plan assessed.
- 2.Record, for every EU-touching voyage: fuel consumption by fuel type, distance, time at sea and cargo carried.
- 3.Aggregate the year into an annual emissions report.
- 4.Have the report verified and submit it via THETIS-MRV by 31 March each year.
- 5.Carry the Document of Compliance on board by 30 June.
What you do NOT need at this size
- ✓No CII rating — IMO CII applies from 5,000 GT.
- ✓No IMO DCS annual fuel report — also a 5,000 GT threshold.
- ✓No EU ETS allowances — the ETS currently starts at 5,000 GT.
- ✓No FuelEU Maritime balance — applies above 5,000 GT.
One caveat: the European Commission is required to review extending EU ETS to ships of 400–5,000 GT (review due end-2026). Nothing is decided — but it is exactly why building clean MRV data now is a cheap insurance policy.
Your crew already writes down everything MRV needs.
BunkerIstanbul turns the operational data your crew already logs — noon reports, bunkers, port calls — into per-voyage MRV monitoring and a verifier-ready annual report. Free for shipowners, any fleet size.
Frequently asked questions
My ship is 2,500 GT and trades Turkey–Greece. Am I covered?
If it is a general cargo ship and it calls Greek (EU) ports — yes, since 1 January 2025. Voyages between an EU and a non-EU port count at 50% of emissions; voyages between two EU ports and emissions at berth in EU ports count in full.
What happens if I simply don’t report?
Penalties are set by member states and escalate: fines per non-compliant period, flag-state notification, and after two consecutive reporting periods without a valid DoC, ships can face expulsion orders / entry refusals in EU ports. Port state control checks the DoC.
Do I need special sensors or equipment?
No. The default monitoring methods accept BDNs plus bunker tank readings — data your crew already produces. The work is in organising it per voyage and keeping the evidence chain consistent; that is exactly what software should do for you.
Can BunkerIstanbul submit to THETIS-MRV for me?
You (or your verifier) submit in THETIS-MRV; we prepare everything underneath it: per-voyage monitoring, the annual aggregation, Excel exports your verifier can audit, and the evidence chain (logbooks, BDN reconciliation, data-gap alerts). Verification itself must legally be done by an accredited verifier — anyone claiming to replace them is misleading you.
Over 5,000 GT, CII applies too — check any ship’s A–E rating in seconds, no sign-up.
This guide summarises Regulation (EU) 2015/757 as amended by Regulation (EU) 2023/957 for information purposes. It is not legal advice; consult your verifier or flag administration for binding interpretations.