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Dec 27, 2022
Lockton P.L. Ferrari

Renewal Bulletin No. 15/22 - The Summary

The European Union’s Emissions Trading System (EU ETS) was extended to cover emissions from shipping as of 1st January 2024.

The EU ETS is limited by a 'cap' on the number of emission allowances. Within the cap, companies receive or buy emission allowances, which they can trade as needed. The cap decreases every year, ensuring that total emissions fall.

Each allowance gives the holder the right to emit:

  • One tonne of carbon dioxide (CO2), or;
  • The equivalent amount of other powerful greenhouse gases, nitrous oxide (N2O) and perfluorocarbons (PFCs).
  • The price of one ton of CO2 allowance under the EU ETS has fluctuated between EUR 60 and almost EUR 100 in the past two years. The total cost of emissions will vary based on the cost of the allowance at the time of purchase, the vessel’s emissions profile and the total volume of voyages performed within the EU ETS area. The below is for illustration purposes:
  • ~A 30.000 GT passenger ship has total emissions of 20.000 tonnes in a reporting year, of which 9.000 are within the EU, 7.000 at berth within the EU and 4.000 are between the EU and an outside port. The average price of the allowance is EUR 75 per tonne. The total cost would be as follows:
  • ~~9.000 * EUR 75 = EUR 675.000
  • ~~7.000 * EUR 75 = EUR 525.000
  • ~~4.000 * EUR 75 * 50% = EUR 150.000
  • ~~Total = EUR 1.350.000 (of which 40% is payable in 2024)
  • For 2024, a 60% rebate is admitted to the vessels involved. However, this is reduced to 30% in 2025, before payment is due for 100% with effect from 2026.
  • Emissions reporting is done for each individual ship, where the ship submits their data to a verifier (such as a class society) which in turns allows the shipowner to issue a verified company emissions report. This report is then submitted to the administering authority, and it is this data that informs what emission allowances need to be surrendered to the authority.
  • The sanctions for non- compliance are severe, and in the case of a ship that has failed to comply with the monitoring and reporting obligations for two or more consecutive reporting periods, and where other enforcement measures have failed to ensure compliance, the competent authority of an EEA port of entry may issue an expulsion order. Where such a ship flies the flag of an EEA country and enters or is found in one of its ports, the country concerned will, after giving the opportunity to the company concerned to submit its observations, detain the ship until the company fulfils its monitoring and reporting obligations.
  • Per the EU’s Implementing Regulation, it is the Shipowner who remains ultimately responsible for complying with the EU ETS system.

There are a number of great resources on the regulatory and practical aspects of the system – none better than the EU’s own:

Upon the conclusion of the announcements for general renewals requirements released by the Clubs of the International Group for the renewals of 20th February 2023, please find the summary headlines for each of the Clubs.

We will follow up with our next and last renewal bulletin reporting any change in the cost or structure of the International Group reinsurance programme.

POLICY YEAR 2023-2024

P&I / FDD: All expiring estimated total premium to have no standardized general increase for both Class I (P&I) and Class II (FD&D) insurance*
DEDUCTIBLES: All deductibles from $10,000 to $50,000 per claim will be increased by 10%, and any below the $10,000 threshold will be increased in all cases by $1,000.
NOTES: * A supplementary call of 30% of currently estimated total premium for the 2021 policy year be applied to both Class I (P&I) and Class II (FD&D)for all open entries at 30th September 2022. Given the inflation and hostile trends in the claim environment, the implementation for 2023 of a year-on-year increase in the pricing risk of at least +10% on expiring rates overall has been decided.

P&I / FDD: An overall Estimated Total Call (ETC) adjustment of + 10 % for the mutual product before any adjustments to the Group Excess of Loss contract be achieved.

P&I / FDD: No General increase ordered but a 5-7 % Premium increase adjusted with risk profile and claims record of each Member.
NOTES: General discount of 5% on the agreed Estimated Total Call (ETC).

P&I: 10%*
FDD: Member's rates will be adjusted to reflect their individual claims records and risk profiles to achieve a 15% increase on Britannia's ETC but there will be no declared general increase.
DEDUCTIBLES: minimum deductible increase: Crew: USD 7,000 - Cargo: USD19,500 - All others: USD13,500
NOTES: *Estimated Total Call (“ETC”) Britannia is no longer adopting the General Increase system, however, the Club is targeting an overall increase of 10% in the for the 2023/24 policy year before any Group Excess of Loss (“GXL”) rate adjustment.

P&I: No GI
DEDUCTIBLES: Based on individual Member LR and Risk Profiles
NOTES: Renewal terms for both Classes will be based on individual Member loss records and risk profiles incorporating the anticipated impact of inflation on future claims costs.

P&I: No GI*
DEDUCTIBLES: All deductibles under US$ 50,000 would be increased by 10% but subject to a minimum monetary increase of US$ 500
NOTES: *+10% increase in premiums for Yacht Sector. Increases would be applied as required to Members operating Dry Cargo vessels.

P&I: 10%
FDD: 10%
DEDUCTIBLES: An increase of all deductibles by 10% for P&I mutual entries, subject to a 'minimum increase of USD 2,000 for crew and cargo claims.* No changes to FD&D deductibles.
NOTES: *There will be additional premium adjustments for any P&I mutual owners/members preferring to maintain their existing deductibles.

P&I: 10%
FDD: 15%
DEDUCTIBLES: All crew and other people related claims deductibles below US$50,000 will be increased by a minimum of US$2,500. All cargo and other claims deductibles will be increased by a minimum of US$1,000. FD&D Rules deductible is to remain at 25%, with the minimum of US$10,000 per claim, but to remove the maximum deductible limit of US$150,000 per claim.

P&I: 7,50%
FDD: 7,50%
DEDUCTIBLES: +10% increase in Class 1 P&I deductibles to apply to all deductibles which are US$ 50,000 or less.

P&I: 10% on all mutual premiums
FDD: 15% on all mutual premiums
DEDUCTIBLES: No changes will be made to deductibles for Class 1 (P&I) owned entries however there will be 10% increase and a minimum increase of USD2,500 will be applied. No change will be made to the deductible for Class 2 (FD&D) owned mutual.
NOTES: Non-Mutual P&I and FDD Covers: No Surcharge, rates and terms will be increased and adjusted as appropriate to reflect the increased reinsurance cost, Member’s record and/or risk exposure. For charterers and fixed premium rates, no change will be made to current practice.

P&I: 10%
DEDUCTIBLES: The standard deductible will remain unchanged at US$15,000 per event, including fees and expenses.

FDD: 5%

P&I: 10%
FDD: 15%*
DEDUCTIBLES: Cargo Recommended minimum USD 15,000 / +10% if above minimum. Crew Recommended minimum USD 10,000 / +10% if above minimum. Third Party Recommended minimum USD 25,000 / +10% if above minimum. Other liabilities Recommended minimum USD 10,000 / +10% if above minimum. FDD: USD 12,000 and 25% in respect of costs in excess of USD 250,000.
NOTES: *the Management to contact each Member individually to discuss renewals.

P&I: 10%
FDD: 10%

Renewal Bulletin No. 15/22 - The Summary
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