MARPOL

Topic 8 of 8

Back to MARPOL
Tools

MARPOL Annex VI — Emission Reduction, EEDI, EEXI & CII

Master MARPOL Annex VI decarbonization: Exhaust Gas Recirculation (EGR), slide-valve injectors, EEDI formula, EEXI Engine Power Limitation, and CII ratings.

Published by ChartandKeel Updated

EEDI, EEXI and CII — design efficiency versus annual operation

MARPOL Annex VI Chapter 4 uses three related measures that answer different questions. Keep their scope separate: EEDI and EEXI are technical/design efficiency indices; CII is an annual operational carbon-intensity rating.

MeasureApplies toWhat is assessedTypical compliance response
EEDIApplicable new shipsAttained design CO2 per capacity-mile against a required valueDesign efficiency and approved technical calculation
EEXIApplicable existing shipsTechnical/design efficiency against a required valueTechnical measures such as engine or shaft-power limitation where needed
CIIApplicable ships in annual operationAchieved annual operational carbon intensity and rating A–EAnnual rating, corrective/improvement measures and SEEMP follow-up where required

Exam distinction: EEDI/EEXI compare technical efficiency with required values; CII reflects achieved annual operation. An EEXI-compliant ship may still receive a poor CII rating because its actual annual fuel use, distance travelled and transport work determine operational intensity.

Continue to the detailed EEDI, EEXI and power-limitation engineering and the separate CII rating bands and SEEMP process. Use the latest Administration guidance and ship-specific certification for attained/required calculations and reduction factors.

1. Primary NOx Reduction: Exhaust Gas Recirculation (EGR) & Slide Valves

While secondary post-treatment systems like Selective Catalytic Reduction (SCR) clean exhaust gases downstream, primary emission controls prevent thermal NOx from forming inside the combustion chamber. Thermal NOx generation spikes exponentially above 1100°C when nitrogen and excess oxygen are subjected to intense flame temperatures.

Marine engine designers employ two principal primary technologies: Exhaust Gas Recirculation (EGR) and slide-valve fuel injectors:

  • Exhaust Gas Recirculation (EGR): Diverts up to 40% of exhaust gas back into the engine scavenge air manifold. Carbon dioxide and water vapor in the exhaust gas possess higher specific heat capacities than pure air, dampening peak combustion flame temperatures. Furthermore, lowering scavenge oxygen concentration directly deprives the thermal NOx reaction of reactants.
  • Slide-Valve Fuel Injectors: Conventional hole-type injectors feature a small residual fuel cavity (sac volume, ~20–40 mm³) beneath the needle seat. When the needle snaps shut, trapped sac fuel boils and dribbles into the hot cylinder during expansion, generating intense local flame hot spots and soot. Slide-valve injectors feature a sliding cut-off spindle flush with the nozzle tip surface, achieving zero sac volume.
  • NOx Cut via Marine EGR: 50–60%
  • Slide-Valve Nozzle Volume: 0 mm³ Sac
  • Thermal NOx Threshold: >1100°C
  • EGR Scrubber Gas Outlet: ≤60°C

The mechanical P&ID of an advanced marine 2-stroke diesel engine Exhaust Gas Recirculation system demonstrates the cleaning, cooling, and blower circuits required:

Exhaust gas recirculation (EGR)A branch from the exhaust receiver passes through a scrubber cooler, water-mist catcher and EGR blower into the scavenge receiver. The main exhaust drives a turbocharger turbine; the shaft-coupled compressor supplies fresh air to the scavenge receiver. A separate water treatment loop serves the scrubber. EXHAUST RECEIVERSCAVENGE AIR RECEIVERTurbineTo exhaustFresh airCompressorSCRUBBER / COOLERQuench and cleanMIST CATCHERRemove dropletsEGR blowerWATER TREATMENTRecirculate / remove sludgeConditioned exhaust mixes with fresh charge air to reduce oxygen concentration.
Figure 1: Exhaust gas recirculation (EGR) — The EGR branch cleans and cools a portion of the exhaust, removes droplets, and uses a blower to return it to the scavenge receiver. The turbocharger supplies fresh air through a separate path.

Alongside EGR, modern electronically controlled engines feature Slide-Valve Injectors that eradicate fuel sac dribble:

Fuel injector tips: sac vs slide valveTwo enlarged closed injector nozzle tips compare a conventional needle seat with trapped fuel in the sac and possible after-dribble, against an extended slide spindle closing directly at the spray ports. CONVENTIONAL NOZZLESLIDE-VALVE NOZZLENeedleTrapped fuelAfter-dribbleSliding spindlePorts sealedResidual fuel remains below the seatExtended spindle closes at the portsCut-off comparison: the slide tip reduces the fuel volume left below the closing element.
Figure 2: Fuel injector tips: sac vs slide valve — Enlarged cutaways compare the closing geometry. The conventional needle leaves fuel in a sac beneath its seat; the extended slide spindle closes near the outlet ports and reduces that residual volume.

2. EEDI, EEXI & Engine Power Limitation (EPL / ShaPoLi)

MARPOL Annex VI Chapter 4 establishes a mandatory technical energy efficiency framework aimed at reducing maritime greenhouse gas emissions:

EEDI (Energy Efficiency Design Index)

Mandatory for new ships constructed on or after 1 January 2013. Sets a regulatory ceiling on grams of CO2 emitted per cargo capacity deadweight-tonne per nautical mile (g CO2 / (t · nm)). Phased reductions force naval architects to optimize hull lines, bulbous bows, and propulsion machinery.

EEXI (Energy Efficiency Existing Ship Index)

Entered into force on 1 January 2023, applying EEDI-equivalent design efficiency retroactively to all existing ships ≥400 GT. Existing ships that cannot meet their Required EEXI must undergo technical modifications, predominantly through engine power de-rating.

EPL (Engine Power Limitation) & ShaPoLi

The primary compliance mechanism for EEXI. Involves installing a physical wire-sealed mechanical stop on the fuel injection rack, or a software-locked governor limiter (Shaft Power Limitation - ShaPoLi) that legally restricts maximum continuous rating (MCR) to a compliant power level.

The Master EEDI / EEXI Mathematical Equation:

The index represents the fundamental ratio of environmental harm (total carbon mass produced) to commercial utility (transport work accomplished):

Component Mathematical Representation Engineering Significance
Impact (Numerator) Σ (P_ME × SFC_ME × C_F) + (P_AE × SFC_AE × C_F) - Energy Saving Total grams of CO2 generated per hour by main propulsion and auxiliary diesel generators at 75% MCR.
Utility (Denominator) Capacity (DWT) × V_ref (knots) × f_w Commercial transport work delivered: cargo mass moved over distance in one hour at reference service speed.
Compliance Criterion Attained EEDI / EEXI ≤ Required EEDI / EEXI The ship's physical index must be lower than the regulatory threshold set by its ship-type baseline curve.

The mechanical architecture of an Engine Power Limitation (EPL) and Shaft Power Limitation (ShaPoLi) system demonstrates the tamper-evident locking mechanisms required by surveyors:

Engine and shaft power limitation cutawaysMechanical fuel rack with contact shoulder, sealed adjusting screw and reserve travel. Intermediate shaft with torque and speed pickups feeds calculated power to an integrated limiter and bridge recorder. Deliberate safety override, recording, notification and restoration are retained.138 • Overridable engine / shaft power limitationEEXI arrangements • schematic cutaways, not interchangeable measurementsA Mechanical EPL • fuel-index travel stopGovernorFuel rack + shoulderWire sealStop screw + locknutRetract to releaseMore fuel →Reserve travel after authorized releaseSealed setting limits fuel index; it does not directly measure shaft power.B SHaPoLi • measured shaft power + approved controlEngineTorque T: calibrated twistGauge length LSpeed n: pickupPshaft = T × 2πn / 60Compare with approved PlimLimit command to engine controlBridge / recorderT • n • Pshaft • overrideIntegrated example; independent systems may alarm for manual power reduction.Master / OICNW deliberate overrideSafety / save life reserve use onlyRecord + notify without delayReset when safe verify restoration
Figure 3: EEXI Engine Power Limitation (EPL) Mechanical Stop and Electronic ShaPoLi System Cutaway. To comply with retroactively enforced EEXI baselines without expensive machinery overhauls, vessels install physical wire-sealed fuel index stops or electronic torque-meter monitoring (ShaPoLi) that legally restricts engine output to an approved power limit. Unsealing the stop for navigation emergencies triggers mandatory Flag Administration reporting within 48 hours.

3. Carbon Intensity Indicator (CII) & SEEMP Part III Trajectory

While EEDI and EEXI certify the theoretical design efficiency of a vessel's hardware, the Operational Carbon Intensity Indicator (CII) measures actual real-world operational carbon emissions per transport work over an entire calendar year.

Mandatory for all ships ≥5,000 GT (the same threshold as the IMO Fuel Oil Data Collection System - DCS), the attained annual operational CII is calculated as:

Attained CII = Σ (Fuel Mass × C_F) / Σ (DWT × Distance Travelled)   [g CO_2 / (t · nm)]

The Five Operational Performance Rating Bands (A to E):

Every year, each ship's attained CII is compared against the regulatory required CII baseline for its ship type and size, assigning a statutory operational rating:

Rating Band Performance Level Statutory Consequence & Fleet Standing
Rating A Major Superior Performance Well above regulatory target; vessel rewarded in green chartering markets and port fee discounts.
Rating B Minor Superior Performance Comfortably complies with statutory decarbonization trajectory.
Rating C Moderate / Target Level Meets the minimum baseline compliance standard for the trading year.
Rating D Minor Inferior Performance Below standard. Three consecutive years of 'D' triggers mandatory Corrective Action Plan.
Rating E Inferior Performance Grossly below standard. A single year of 'E' triggers mandatory Corrective Action Plan.

Warning: The SEEMP Part III Corrective Action Plan

If a ship receives an 'E' rating in a single calendar year or a 'D' rating for three consecutive years, its Ship Energy Efficiency Management Plan (SEEMP Part III) must be revised with an approved Plan of Corrective Actions (PoCA). The plan must detail exact technical steps (hull antifouling, micro-bubble air lubrication, propeller boss cap fins, voyage routing, or operational slow steaming) to regain a 'C' rating within 24 months. Failure to execute invalidates the Statement of Compliance.

OPERATIONAL CARBON INTENSITY INDICATOR (CII) RATING SPECTRUM & ANNUAL TIGHTENING A MAJOR SUPERIOR B MINOR SUPERIOR C TARGET BASELINE D MINOR INFERIOR E INFERIOR ANNUAL CII REDUCTION TRAJECTORY (Z% FACTOR BELOW 2019 BASELINE) 2023 -5.0% 2024 -7.0% 2025 -9.0% 2026 -11.0% IMO 2030 & 2050 REVISED STRATEGY • 2030 Target: -40% Carbon Intensity • 2040 Checkpoint: -70% GHG reduction • 2050 Net-Zero GHG Emissions Target SEEMP AUDIT: The Statement of Compliance is issued annually; ships with unrectified D/E ratings cannot legally trade.
Figure 4: Operational Carbon Intensity Indicator (CII) Rating Spectrum and Annual Decarbonization Trajectory. Ships ≥5,000 GT receive an annual letter grade from A (major superior) to E (inferior) based on verified fuel consumption per deadweight-nautical mile. Earning an E in a single year or D for three consecutive years mandates a revised SEEMP Part III Corrective Action Plan. Targets tighten by 2% annually toward the IMO 2030 and 2050 net-zero greenhouse gas goals.

Standards & sources referenced