Liberia Marine Notice POL-009 – Revised MARPOL Annex VI
Marine Notice POL-009 Rev. 10/26 | Liberia Maritime Authority – Implementation of the 2021 Revised MARPOL Annex VI, Regulations for the Prevention of Air Pollution from Ships
Revision: October 2026.
Supersedes: Marine Notice POL-009 dated September 2025.
The Liberia Maritime Authority has issued Revision 10/26 of Marine Notice POL-009, providing updated guidance on the implementation of the 2021 Revised MARPOL Annex VI and its requirements for the prevention of air pollution from ships. The revision incorporates amendments to NOx technical requirements, EEDI survey and certification guidelines, Emission Control Areas (ECAs), engine emission record-keeping, Selective Catalytic Reduction (SCR) systems, energy efficiency and operational carbon intensity reporting.
Purpose and Applicability of the Revised MARPOL Annex VI Requirements
The purpose of this Marine Notice is to provide guidance on the implementation of the 2021 Revised MARPOL Annex VI, Regulations for the Prevention of Air Pollution from Ships, as amended by Resolution MEPC.385(81).
The revised Annex VI establishes requirements addressing air emissions from ships, including nitrogen oxides (NOx), sulphur oxides (SOx), ozone-depleting substances, volatile organic compounds, shipboard incineration and energy efficiency.
The Notice applies to Liberian-flagged vessels and provides guidance for shipowners, operators, Masters and Recognized Organizations responsible for the implementation, survey, certification and verification of applicable requirements.
Regulatory References
- Liberian Maritime Regulation 2.37.
- MARPOL Convention, Annex VI.
- Resolution MEPC.385(81).
- Resolution MEPC.397(83).
- Resolution MEPC.408(84).
- Resolution MEPC.410(84).
- Resolution MEPC.411(84).
- Resolution MEPC.412(84).
- Resolution MEPC.413(84).
- Applicable NOx Technical Code 2008 amendments.
Key Regulatory Changes Introduced by POL-009 Revision 10/26
Revision 10/26 introduces amendments across several sections and attachments of POL-009 to incorporate recent IMO resolutions, updated technical guidance and additional provisions for air pollution prevention and energy efficiency.
Section 1.15 – Distance Travelled
The definition of distance travelled has been amended to clarify that distance travelled is measured over ground using satellite data. The associated clarification addresses periods when a ship is underway and not underway for data collection purposes.
Section 1.29.3 – NOx Technical Code
The provisions concerning major conversion and substantial modification of marine diesel engines have been amended to incorporate amendments to the NOx Technical Code 2008 by Resolution MEPC.397(83).
Sections 4.2.1 and 4.3 – EEDI Surveys and Certification
The requirements have been updated to include the 2026 Guidelines on Survey and Certification of the Energy Efficiency Design Index (EEDI), adopted by Resolution MEPC.411(84).
Sections 8.3.1 and 15.13 – Operational Carbon Intensity
References to the applicable guidelines have been updated to include Resolution MEPC.412(84), amending Resolution MEPC.352(78).
Section 11.2 – Emission Control Areas
Sections 11.2.4, 11.2.5, 11.2.9, 11.2.10 and 11.2.11 have been amended to incorporate the new Emission Control Areas (ECAs) and their respective effective dates.
Sections 12.2.5 and 12.3.8 – ECA Record Books
The amendments clarify that a combined ECA record book covering NOx and SOx is acceptable.
New Section 12.2.10 – Selective Catalytic Reduction
A new section has been introduced addressing Selective Catalytic Reduction (SCR) systems used for compliance with applicable NOx emission requirements and identifying the associated SCR guidelines.
Energy Efficiency Guidelines and References
Sections 15.7.2, 15.7.4, 15.11.4 and 16.8.6 have been updated to incorporate Resolution MEPC.410(84) in the relevant EEDI and related guideline references.
SEEMP and Operational Carbon Intensity
Sections 15.11.1 and 15.11.2 have been amended to incorporate Resolution MEPC.413(84), together with the applicable updated references to the SEEMP and operational carbon intensity requirements.
Updated Attachments and IAPP Certificate Supplement
Attachment 3 now includes Resolution MEPC.410(84). Attachment 4 incorporates references to Resolutions MEPC.412(84) and MEPC.413(84). Annex I, Supplement to the IAPP Certificate, has also been updated to include NTC 8 (Multiple Engine Operational Profile) in accordance with Resolution MEPC.408(84).
Updated SEEMP Confirmation Templates
Annex 4, Sample Confirmation of Compliance – SEEMP Part II, and Annex 5, Sample Confirmation of Compliance – SEEMP Part III, have been amended to reflect the latest SEEMP Guidelines.
Distance Travelled and Ship Operational Data Collection
The revised Section 1.15 clarifies the definition of distance travelled for the purposes of ship fuel oil consumption data collection and reporting.
Distance Over Ground
Distance travelled is defined as distance travelled over ground, measured using satellite data.
Underway Period
The underway period is identified as the period between Full Ahead on Passage (FAOP) and End of Sea Passage (EOSP).
Not Underway Period
The not underway period is identified as the period between End of Sea Passage (EOSP) and Full Ahead on Passage (FAOP).
Data Collection
The clarification supports consistent recording of distance travelled and operational periods for the applicable IMO fuel oil consumption data collection requirements.
Operational Consideration
Shipowners and operators should review their onboard data collection procedures to ensure that distance travelled, underway periods and periods not underway are recorded consistently with the revised definitions.
NOx Emission Requirements and Engine Certification
Section 1.29.3 has been amended to incorporate the relevant changes to the NOx Technical Code 2008. The revised Notice also addresses the technical requirements applicable to marine diesel engines subject to substantial modification and certification to a different NOx Tier.
Marine Diesel Engine Requirements
MARPOL Annex VI Regulation 13 applies to marine diesel engines with a power output of more than 130 kW, subject to the applicable provisions and exemptions.
Major Conversion and Substantial Modification
Engine replacement, additional engine installation and substantial modifications must be assessed against the applicable NOx emission requirements and the relevant provisions of the NOx Technical Code 2008.
Certification from 1 September 2026
The Notice addresses certification of marine diesel engines subject to substantial modification or certification to a NOx Tier different from that assigned at installation, in accordance with the applicable amended NOx Technical Code provisions.
Engine Technical Documentation
The applicable NOx Technical File and supporting certification documentation should reflect the engine's approved configuration, emission certification and applicable technical requirements.
NOx Technical Code Reference
The revised Notice incorporates Resolution MEPC.397(83) in the relevant definition and technical provisions. It also addresses the applicable amended NOx Technical Code requirements for engine modifications and certification.
EEDI Survey and Certification Requirements
Sections 4.2.1 and 4.3 have been updated to include the 2026 Guidelines on Survey and Certification of the Energy Efficiency Design Index (EEDI), adopted by Resolution MEPC.411(84).
Initial Surveys
The applicable initial survey requirements must take account of the revised EEDI survey and certification guidelines.
EEDI Technical File
The attained EEDI must be supported by the applicable EEDI Technical File containing the information and calculation methodology required for verification.
Recognized Organization Authorization
The Notice addresses the authorization of Recognized Organizations to perform applicable surveys, technical file verification and related certification functions on behalf of the Administration.
Survey and Certification References
The revised guidelines must be considered when performing applicable EEDI surveys, certification and verification activities.
Emission Control Areas and Applicable Effective Dates
Sections 11.2.4, 11.2.5, 11.2.9, 11.2.10 and 11.2.11 have been amended to incorporate the new Emission Control Areas (ECAs) and their respective effective dates.
These amendments are relevant to the application of MARPOL Annex VI requirements concerning the control of emissions from ships operating within designated emission control areas.
Updated ECA Designations
The revised sections identify the additional or newly designated ECAs addressed in the updated Notice.
Effective Dates
The respective effective dates have been incorporated into the relevant provisions to clarify when the applicable ECA requirements take effect.
Operational Compliance
Shipowners and operators should review their trading routes and applicable emission control arrangements against the revised ECA provisions.
Shipboard Compliance Documentation
Masters and Chief Engineers should ensure that the applicable shipboard procedures and records reflect the relevant ECA requirements, including the recording of engine operating status and other required information.
Combined NOx and SOx ECA Record Book
Sections 12.2.5 and 12.3.8 have been amended to clarify that a combined ECA record book covering both NOx and SOx is acceptable.
NOx Records
Applicable records should address the NOx emission control requirements and the relevant engine operating status when entering, operating within and leaving designated NOx ECAs.
SOx Records
Applicable records should address the relevant sulphur oxide emission control arrangements and associated operational information.
Combined Record Book
A single combined record book may be used for the applicable NOx and SOx ECA entries, in accordance with the revised Notice.
Shipboard Procedures
Operators should review the onboard recording procedures to ensure that the relevant information is properly documented and readily available.
New Section 12.2.10 – Selective Catalytic Reduction (SCR) Systems
A new Section 12.2.10 has been introduced to address Selective Catalytic Reduction (SCR) systems as a method of achieving compliance with the applicable Tier III NOx emission requirements.
SCR technology reduces nitrogen oxide emissions by injecting a liquid reductant, typically a urea-water solution, into the exhaust gas stream. In the presence of a catalyst, the reaction converts NOx into nitrogen and water vapour.
Applicable SCR Guidelines
The revised Notice identifies the following SCR guideline provisions:
- 2011 SCR Guidelines adopted by Resolution MEPC.198(62), as amended by Resolution MEPC.260(68).
- 2017 SCR Guidelines adopted by Resolution MEPC.291(71), as amended by Resolution MEPC.313(74).
- 2025 SCR Guidelines for the applicable SCR installations identified in the revised Notice.
Applicability of the 2025 SCR Guidelines
Ships Constructed from 1 November 2025
The 2025 SCR Guidelines apply to SCR systems installed on ships for which the keel is laid, or which are at a similar stage of construction, on or after 1 November 2025.
Contractual Delivery from 1 May 2026
The guidelines also apply to SCR systems installed on ships whose keels were laid, or which were at a similar stage of construction, before 1 November 2025, where the contractual delivery date of the SCR system to the ship is on or after 1 May 2026.
Actual Delivery from 1 May 2026
Where no contractual delivery date exists, the actual delivery of the SCR system to the ship on or after 1 May 2026 is the relevant criterion.
Technical and Documentation Considerations
Shipowners and operators should verify the applicability of the relevant SCR guidelines to the installation, construction and delivery circumstances of the system. Applicable technical documentation, approval arrangements and operating procedures should be maintained in accordance with the relevant requirements.
Energy Efficiency – EEDI and EEXI Requirements
Revision 10/26 incorporates updated references to IMO guidelines concerning energy efficiency calculations, surveys, verification and certification.
Energy Efficiency Design Index (EEDI)
The attained EEDI must be calculated and verified in accordance with the applicable requirements and supporting technical documentation.
Energy Efficiency Existing Ship Index (EEXI)
The Notice continues to address the calculation, verification and applicable technical documentation for the attained and required EEXI.
Updated EEDI Guidelines
The relevant EEDI references have been updated to incorporate Resolution MEPC.410(84) and the 2026 survey and certification guidelines under Resolution MEPC.411(84).
Technical Documentation
EEDI and EEXI Technical Files, applicable calculations and verification records should remain consistent with the relevant requirements.
SEEMP and Carbon Intensity Requirements
Revision 10/26 updates references concerning the Ship Energy Efficiency Management Plan (SEEMP) and operational carbon intensity requirements.
SEEMP Part I – Ship Energy Efficiency Management
The SEEMP provides the ship-specific management framework for improving energy efficiency and implementing the applicable operational measures.
SEEMP Part II – Ship Fuel Oil Consumption Data Collection
The applicable data collection plan and associated confirmation documentation must reflect the relevant IMO requirements and updated guidance.
SEEMP Part III – Operational Carbon Intensity
The Notice updates the relevant references for operational carbon intensity planning, calculation and verification.
Attained Annual Operational CII
Section 15.13 incorporates the updated reference to Resolution MEPC.412(84) in connection with the applicable operational carbon intensity guidelines.
Updated SEEMP Confirmation Templates
The revised Notice includes updated sample Confirmation of Compliance documents:
- Annex 4 – Sample Confirmation of Compliance, SEEMP Part II.
- Annex 5 – Sample Confirmation of Compliance, SEEMP Part III.
These templates have been amended to reflect the latest SEEMP Guidelines.
IMO Fuel Oil Consumption Data Collection and Reporting
The revised Notice maintains the applicable IMO Data Collection System (DCS) and operational carbon intensity reporting framework for ships subject to the relevant requirements of MARPOL Annex VI.
Annual Data Collection
Applicable ships of 5,000 gross tonnage and above engaged in international voyages must collect the prescribed fuel oil consumption and operational data in accordance with their SEEMP methodology.
Annual Data Reporting
Aggregated data must be submitted to the authorized Verifier within the applicable reporting period, in accordance with the Notice.
Supporting Documentation
Relevant supporting documents may include the verified SEEMP Data Collection Plan, bunker delivery note summaries, fuel oil consumption records, distance travelled, hours underway and supporting shipboard records.
Company and Administration Changes
The Notice addresses the transfer and availability of relevant fuel consumption and operational data when a vessel changes Company or Administration.
IAPP Certificate and Updated Annexes
The revised Notice incorporates changes to the IAPP Certificate supplement and associated supporting documentation.
Annex I – IAPP Certificate Supplement
The supplement has been updated to include NTC 8 (Multiple Engine Operational Profile) in accordance with Resolution MEPC.408(84).
Attachment 3
The attachment has been updated to include the reference to Resolution MEPC.410(84).
Attachment 4
References to Resolutions MEPC.412(84) and MEPC.413(84) have been incorporated.
SEEMP Compliance Samples
Annexes 4 and 5 have been updated to reflect the latest SEEMP Guidelines and associated confirmation requirements.
Implications for Shipowners, Operators, Masters and Recognized Organizations
Shipowners and operators of Liberian-flagged vessels should review the revised POL-009 and assess the impact of the updated requirements on their technical documentation, engine certification, operational procedures, emission control arrangements and energy efficiency management systems.
Regulatory Review
Review Marine Notice POL-009 Rev. 10/26 and identify the amended sections applicable to the vessel's equipment, operational profile and statutory certification.
Engine Emission Compliance
Verify applicable NOx certification, engine technical files and the implications of any engine replacement, major conversion or substantial modification.
SCR System Compliance
Establish which SCR guidelines apply to the installation, taking into account the construction stage, contractual delivery date and actual delivery date where relevant.
ECA Operational Arrangements
Review trading routes, ECA operating procedures and applicable NOx and SOx recording arrangements, including the acceptability of a combined ECA record book.
EEDI and EEXI Documentation
Verify that the relevant technical files, calculations, surveys and certification arrangements reflect the updated IMO guidelines.
SEEMP and CII Documentation
Review SEEMP Parts II and III, fuel consumption data collection procedures, operational data records and the applicable CII reporting arrangements.
Shipboard Records
Ensure that relevant records, including fuel consumption, distance travelled, hours underway, engine operating status and supporting documentation, are maintained in accordance with the applicable requirements.
Recognized Organization Coordination
Confirm that applicable statutory surveys, certification and verification activities are undertaken in accordance with the revised Notice and the Administration's authorization arrangements.
Official Liberia Marine Notice POL-009 Rev. 10/26
Implementation of the 2021 Revised MARPOL Annex VI – Regulations for the Prevention of Air Pollution from Ships
Issuing Authority: Liberia Maritime Authority – Office of the Deputy Commissioner of Maritime Affairs.
Notice Number: POL-009.
Revision: October 2026.
Supersedes: Marine Notice POL-009 dated September 2025.
Subject: Implementation of the 2021 Revised MARPOL Annex VI, Regulations for the Prevention of Air Pollution from Ships.
Reference: Liberian Maritime Regulation 2.37 and MARPOL Convention.
Access the complete revised Marine Notice directly from the official Liberia International Ship & Corporate Registry website.