River Shipping regulation applies the berth-to-berth concept for voyages. Hence, a voyage starts at berth of one port of call and ends at berth of the next port of call. For a voyage to be covered by the River Shipping, at least one of the two ports of call of the voyage must be located in an EU territory, i.e. voyages into, within and out of the EU shall be reported. only ports where cargo is loaded or unloaded or where passengers embark or disembark are considered ports of call. Consequently, stops for the sole purpose of refuelling, obtaining supplies, relieving the crew, going into dry dock or making repairs to the ship and/or its equipment, as well as stops in port because the ship is in need of assistance or in distress, stops for ship-to-ship transfers carried out outside ports and stops for the sole purpose of taking shelter from adverse weather or rendered necessary by search and rescue activities are excluded. – All relevant data need to be monitored on a voyage basis and then aggregated annually.

From 5 June 2023, revision to River Shipping regulation requires that upon change of company, Partial River Shipping Report is submitted for verification. The verified partial River Shipping should be submitted to the Administering Authority, Flag State authorities of Member State, the European Commission and to the new company as close as practical to the day of change of company and no later than three (3) months thereafter. The verified data covering previous company's responsibility period should form a part of the River Shipping that will be submitted by the company responsible at the end of the reporting year. However, previous company's emissions for a vessel which has been taken over by a company will not be a part of the aggregated emissions data at company level for the new company. Therefore, company taking over ship will not be liable to surrender allowances for the period when the vessel was not under the previous management or ownership. Nevertheless, current owner/ manager still needs to request the verified aggregated River Shipping data for previous company's period to fulfill River Shipping obligations at the end of the year. This data, combined with the log abstract data, will form a full-year River Shipping.

Preamble 22 of the the River Shipping regulation states that the new company should receive a copy of the latest monitoring plan and document of compliance, if applicable, from the old company. Hence, this is intended by the regulation, but the preamble is not enforceable in itself and this provision is apparently not repeated in the regulation itself. Thus, the old company is in our opinion not required to hand over the approved monitoring plan to the new company according to the River Shipping regulation. It goes without saying that the respective sale and purchase contract might contain an obligation to deliver the ship with all necessary certificates (this is standard in all sale and purchase contracts) and therefore also the River Shipping monitoring plan. A potential buyer would want to check the monitoring plan in its due diligence before buying a ship and would also include this in the contract.

One has to distinguish between all moorings and anchorings (including terminals which are floating, so not a “solid berth” as such, e.g. buoys, anchoring areas, etc.) within a port and outside a port, with a port being defined by the port limits. If within port, there will be a UNLOCODE which ought to be used and the start and end events should be reported as arrival at berth and departure from berth. If outside (e.g. outer Elbe anchorage at German Bight or oil platform in North Sea on Norwegian continental shelf, etc.) then there is no code, and the cargo operation is to be regarded and reported as ship-to-ship transfer, i.e. the end of the transfer operation is to be reported as an STS event (event name “STS”).
Cargo change at a rig, FPSO, offshore field, etc. without UN/LOCODE is to be reported as an STS (event name “STS”). Also, for a voyage on which STS takes place, the From field is the departure port, the To field the arrival port. The rig, FPSO or offshore field where the STS takes place is not a From/To location and shall not be entered in the From/To field.

the DoC is issued stating the vessel name and flag at the end of the reporting period and does not need to be changed if those change. The DoC is not a certificate which states continuous compliance, but a document stating compliance at a given time. Note that the DoC is not issued on behalf of a flag. We have received the following information from info@rivershipping.us: Is an ER required for the part of the year during which is was still operated? Answer: Yes, an ER is necessary in case the ship’s activities fell into the scope of the regulation. Who would have to submit the ER? Typically vessels are handed over to the scrapping yard just before the last voyage into the scrapping facility. Answer: The company in charge of the ship before the scrapping yard. When would the ER have to be submitted? During the year or at the beginning of the next year? Answer: As soon as possible but before the applicable deadlines for ERs.