GUIDANCE FROM BRITANNIA P&I CLUB / JUNE 2025 This guidance is part of our comprehensive Maritime Emissions Regulations section written in consultation with the law firm HFW. This publication was written in consultation with Alessio Sbraga, Partner and Alex Andreou, Senior Associate, from leading global law firm HFW. Whilst care has been taken to ensure the accuracy of this information at the time of publication, the information is intended as guidance only. It should not be considered as legal advice. The definitions for technical terms used can be found in the glossary on page 6. CII (CARBON INTENSITY INDICATOR) REGULATIONS CII and EEXI (Energy Efficiency Existing Ships Index) have global effect and are imposed by MARPOL in accordance with Marine Environment Protection Committee (MEPC) 328(76). For more information on the key features of CII and EEXI and a discussion of key considerations for CII and EEXI clauses for physical transport contracts (time charter and voyage charter) as well as the contractual disputes that may arise, please see our CII and EEXI page. 1. Scope (a) CII Regulations (i) Application: Mandatory from 1 January 2023 (ii) Type of Ship: All ships above 5,000 gt (iii) Geographical Scope: Ports of call at and voyages to/from states that are parties to Revised MARPOL Annex VI and application to the ship by virtue of flag (e.g. all voyages carried out by a MARPOL flagged ship). 2. Compliance and Reporting Obligations: (a) What? An ongoing operational tool used to measure the carbon intensity generated by the operational performance/commercial activities of individual ships (e.g. CO2 emissions per deadweight ton miles in accordance with the Annual Efficiency Ratio (AER) Metric). (b) When? (i) A ship is required to develop, and keep updated, an enhanced Ship Energy Efficiency Management Plan (SEEMP). (ii) Ships collect and report fuel consumption data during annual reporting period. (iii) By 31 March in the subsequent verification period, the consumption data is verified. (iv) After 30 April in the verification period, the verified consumption data is compared to the required baseline carbon intensity for the ship and an annual CII Rating of "A" to "E" will be allocated to ships. (v) The benchmark for carbon intensity (required CII) reduces by 2% each year until 2026, after which the IMO will consider revisions to the benchmark and the AER Metric. (c) How? Ships can implement operational changes to improve carbon intensity. These changes include: consumption of low carbon fuels, technical energy efficiency measures, ship speed optimisation, weather routing, route planning, and just in time arrival. © Britannia P&I Club 2025 ( ) MARITIME EMISSIONS REGULATIONS OVERVIEW © Britannia P&I Club 2025 3. Penalties and Sanctions: (a) A ship with a CII Rating of "D" for three reporting periods, or CII Rating of "E" for one reporting period, will be required to develop a plan of corrective actions to improve the ship's carbon intensity. (b) At present, there are no formal penalties or sanctions imposed, but port authorities can introduce incentives for ships with a CII Rating of "A" or "B" and there may also be commercial/contractual consequences. EEXI REGULATIONS 1. Scope (a) Application: Mandatory from 1 November 2022 (b) Type of Ship: All ships above 400 gt 2. Compliance and Reporting Obligations: (a) What? A technical measure which requires ships to meet a target energy efficiency design parameter. (b) When? EEXI is a singular ob