If your vessel has been rated D under the IMO CII framework, you have a regulatory obligation that is not optional. You must develop and submit a SEEMP Part III — a Corrective Action Plan — to your flag state administration.
Most technical managers I speak with have three questions:
- What exactly is SEEMP Part III?
- What must it contain?
- What happens if you don’t submit one?
This post answers all three in plain English. No regulatory jargon. No vague references to “IMO guidelines.” Specific requirements, specific content, specific consequences.
What Is SEEMP Part III?
SEEMP stands for Ship Energy Efficiency Management Plan. It has been mandatory under MARPOL Annex VI since 2018. Every covered vessel must have a SEEMP on board.
SEEMP Part III is a specific section added to the SEEMP for vessels rated D or E. It requires the vessel to have a documented plan for improving its CII rating. This is not a suggestion. It is a regulatory requirement under IMO MEPC.338(76).
The key point: a D-rated vessel without a SEEMP Part III is in non-compliance with MARPOL Annex VI. This is a deficiency that PSC inspectors can and will cite.
What SEEMP Part III Must Contain
The IMO MEPC.338(76) resolution specifies the minimum content of a SEEMP Part III. Here is what it requires, in plain terms:
1. Current Performance Assessment
The plan must document the vessel’s current CII performance:
- The vessel’s CII rating for the most recent reporting period
- The vessel’s CII trend over the last 3 years (if available)
- The gap between the current CII and the benchmark for the upcoming year
- A root cause analysis explaining why the vessel is underperforming
The root cause analysis is the most critical section. It must identify specific factors contributing to the underperformance: hull fouling, engine degradation, operational practices, trading pattern, or a combination.
2. Corrective Actions
The plan must list specific corrective actions the vessel will implement. These fall into three categories:
Operational measures (no capital expenditure):
- Speed reduction (how much, at what cost)
- Trim optimization (current trim vs. optimal trim)
- Route optimization (weather routing, direct vs. great circle)
- Port idle reduction (minimizing engine runtime in port)
- Ballast water management optimization
Technical measures (requiring capital expenditure):
- Hull cleaning and repainting (timeline and cost)
- Propeller polishing or replacement
- Air lubrication system installation
- Waste heat recovery system
- Wind assistance (rotors, kites, sails)
The plan must prioritize operational measures first (they are free) and list technical measures as secondary actions with a timeline for implementation.
3. Implementation Timeline
The plan must include a timeline for implementing each corrective action:
| Measure | Implementation Timeline | Expected CII Improvement |
|---|---|---|
| Speed reduction (5%) | Immediate | +1 rating band |
| Trim optimization | Within 30 days | +0.5 rating band |
| Hull cleaning | Before next dry-dock | +0.5 to +1 rating band |
| Propeller polishing | Within 90 days | +0.25 to +0.5 rating band |
| Weather routing | Within 30 days | +0.25 rating band |
The timeline must be realistic. A plan that lists “propeller replacement within 30 days” when the vessel is on a continuous trade route is not credible and will be rejected by the flag state.
4. Monitoring and Reporting
The plan must describe how the vessel’s progress will be monitored:
- Who is responsible for tracking CII performance?
- How often will performance data be reviewed?
- What happens if the corrective actions are not effective?
- How will the plan be updated?
The monitoring section must name specific individuals — the master, the chief engineer, the designated person ashore. It cannot say “the company will monitor.” It must specify who, how, and when.
What Happens If You Don’t Submit a SEEMP Part III
The consequences of non-compliance are not theoretical:
PSC deficiency: A D-rated vessel without a SEEMP Part III is a guaranteed citation during any PSC inspection. Paris MoU, Tokyo MoU, and USCG inspectors all check for this.
Detention risk: A missing SEEMP Part III can lead to detention, especially if combined with other deficiencies. The cost of a single detention (€10,000–50,000/day in laytime losses) dwarfs the cost of developing the plan.
Flag state action: The flag state administration may require the vessel to take corrective action before it is allowed to sail. This can result in a forced port stay.
Charterer rejection: Major charterers now screen for SEEMP Part III compliance. A vessel without one may be excluded from charter opportunities.
The SEEMP Part III Development Process
The process to develop a SEEMP Part III for a D-rated vessel is structured:
Step 1: Data Collection (1–2 days)
Gather the following data:
- Last 3 years of CII ratings
- Annual fuel consumption records
- Voyage data (distance, speed, route)
- Hull condition records (last dry-dock date, antifouling type)
- Engine performance records (main engine hours, efficiency data)
Step 2: Root Cause Analysis (1–2 days)
Analyze the data to identify the primary factors contributing to the D rating. Common root causes for Handymax bulk carriers:
- Hull fouling (most common for vessels with 12+ month intervals between dry-docks)
- Engine degradation (most common for vessels built before 2015)
- Suboptimal speed/trading patterns (most common for vessels on long-haul trades)
Step 3: Corrective Action Plan Development (2–3 days)
Develop the plan with specific, measurable corrective actions. Each action must include:
- A description of the measure
- The expected CII improvement
- The implementation timeline
- The responsible party
- The cost (if applicable)
Step 4: Flag State Submission (1–2 days)
Submit the plan to the flag state administration for approval. Most administrations process the submission within 2–4 weeks.
Step 5: Implementation and Monitoring (ongoing)
Implement the corrective actions according to the timeline. Monitor progress and update the plan quarterly.
Common Mistakes in SEEMP Part III Plans
1. Generic Corrective Actions
“Optimize speed” is not a corrective action. “Reduce service speed from 12.5 knots to 11.5 knots on all voyages exceeding 2,000 nm” is a corrective action. Specificity matters.
2. Unrealistic Timelines
Listing technical measures (propeller replacement, air lubrication) with implementation timelines that are impossible to meet (30 days for a vessel on continuous trade) signals to the flag state that the plan was not carefully considered.
3. No Root Cause Analysis
A plan that lists corrective actions without explaining why those actions are needed is incomplete. The root cause analysis is the foundation of the plan. Without it, the flag state will reject the submission.
4. No Monitoring Plan
A plan without a monitoring and reporting section is non-compliant. The plan must describe how progress will be tracked and who is responsible.
The Bottom Line
A SEEMP Part III is a regulatory requirement for every D-rated vessel. It is not optional. It is not a suggestion. The cost of developing the plan is negligible compared to the cost of non-compliance (detention, charterer rejection, flag state action).
The plan must contain four elements: current performance assessment, corrective actions with specific measures, implementation timeline, and monitoring procedure. Generic plans are rejected. Specific, credible plans are approved.
*Need a SEEMP Part III development for your D-rated vessel? Request a SEEMP Part III assessment from Ingeniat — fixed scope, fixed deliverable, fixed price. Turnaround: 5 working days. Or check our marine compliance platform for other tools of interest.