December 2022

International Group P&I Clubs 2023/24 Excess loss of reinsurance program

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:

Dear Sir / Madam,

Below you may find the 2023 excess loss of reinsurance rates of the International Group Clubs, a programme jointly purchased by all the International Group Clubs.

Individual Club Retention (ICR) remains unchanged for the 2023/24 policy year at US$10 million, as does the structure of the Pool above that and the attachment point for the GXL programme at US$100m.

War cover

The excess War P&I cover will be renewed for 2023 for a period of 12 months. Again, this will be included in the total rates charged to shipowners. However, due to the ongoing active war between Russia and Ukraine, the IG’s Excess War reinsurers require Territorial Exclusion language (consistent with exclusion already applied by reinsurers for Primary War P&I coverage) for vessels trading in these waters. The IG are negotiating availability of sub-limited cover for affected vessels, which remains an ongoing process. However, it appears available cover is likely to be on the basis of a significantly lower per vessel limit than for the main Excess War placement limit of USD 500m. The Club will provide details of this cover in due course.

The following link provides detailed information for the new reinsurance agreement.

All Group Clubs have issued or will issue similar circular.

2023 / 24 rates summary

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