Charting a Sustainable Course Part II: IMO compliance - EEXI, SEEMP, CII, EEOI Pain Points and Edge AI Solutions
- Paul Nijhof

- 6 days ago
- 4 min read
Updated: 10 hours ago
In Part I, we decoded each instrument and the interrelated logic between them. It is clear that they were designed to drive safer, cleaner, more efficient shipping; But for most ship owners, these four instruments now define the daily reality of speed, cost and negotiating power.
In Part II, we unpack how EEXI, CII, SEEMP and EEOI show up as pain points in daily operations and outline practical, on-board ways to turn them from compliance burden into performance tools.
Here is where they are biting you - and what you can do on board:
Pain Points
1. EEXI — Design limits made operational
The Energy Efficiency Existing Ship Index (EEXI) fixes a legal power envelope via Engine Power Limitation (EPL)/ Shaft Power Limitation (ShaPoLi) and Onboard Management Manual (OMM) procedures.
The costs show up as:
Lost commercial headroom – older hulls accept deeper power caps, tightening schedules and options.
Retrofit CAPEX and planning friction – propeller work, ducts, fins, bow/bulb, dry-dock and class coordination.
Assurance risk – if override practice and evidence don’t match the OMM, findings appear in surveys and re-surface in charter talks.
2. SEEMP — Governance, data, people
The Ship Energy Efficiency Management Plan (Parts I, II, III) (SEEMP) is the operating system: plan, do, record, improve.
Its costs are mainly organisational:
Governance – version control, approvals, roles and change logs.
Data engineering – noon, sensors, Bunker Delivery Notes (BDNs), Monitoring, Reporting and Verification (EU) (MRV), Data Collection System (IMO) (DCS), Voyage Data Recorder (VDR), Computerised Maintenance Management System (CMMS), class, all standardised and reconciled.
Crew workload – prompts by rank, minimal double entry, clean close-outs.
Weakness here means non-conformities, slower Port State Control (PSC) inspections, and longer charterparty negotiations because your claims are harder to defend.
3. CII — A live operating carbon budget
The Carbon Intensity Indicator (CII) turns daily decisions into an A–E rating that financiers and charterers treat as a quality signal. Costs include:
Rating slippage – tighter reference lines drive mid-year drift without active management.
Commercial drag – shortlisting pressure, tougher clauses, rate impact, earlier redelivery.
Financial spillover – higher margins, refinancing friction, softer resale.
Regional exposure – European Union Emissions Trading System (EU ETS), FuelEU Maritime Regulation – the EU regulation promoting low-GHG maritime fuels - (FuelEU Maritime) and United Kingdom Emissions Trading Scheme (UK ETS) translating directly into allowance/penalty costs.
Managing CII as an in-year budget needs forecasting, triggers and evidence - time and skill you must either build or buy.
4. EEOI — The voyage truth meter
The Energy Efficiency Operational Indicator (EEOI) is voluntary, but it’s the backbone that proves what really saved fuel. Costs sit in quality:
Method discipline – MEPC.1/Circ.684 choices on emission factors, transport work and distance. (The MEPC.1/Circ.684 is the IMO Marine Environment Protection Committee Circular 684, which provides guidelines for measurement of ship energy efficiency, distance definition, emission factors, and EEOI methodology.)
Instrument health – meter calibration, current/leeway handling.
Analytics time and disputes – Comparative controlled tests of two scenarios (A vs. B) (A/B tests), before-and-after performance comparisons and arguments when records are not trusted.
When EEOI is done well, it shortens disputes and supports benefit-sharing and emissions cost pass-through. When it isn’t, it adds operating cost and weakens your negotiating position.
A Practical and Realistic Way Forward:
The NIJHOF Central Intelligence Library (Maritime) | NCIL(M) - Your vessel’s offline AI for compliance, evidence and daily decision-making
NCIL(M) is a high-performance, fully offline, generative AI system installed on board.
We load what matters to your crew - OEM manuals, class approvals, IMO/flag rules, SEEMP Parts I–III, SOPs, training material, MRV/DCS exports, CMMS records, BDNs, routing/trim outputs and selected enterprise data - clean it, structure it, and bind it to a large language model running inside the hardware. The box joins your internal LAN/Wi-Fi. Crew use their existing devices to get instant, accurate, procedure-true answers and step-by-step guidance—no internet required.

What It Does On-board
Operational guidance – rank-specific checklists and answers for maintenance, operations and compliance, aligned with OEM limits, class and your SOPs.
EEXI discipline – guided EPL/ShaPoLi workflows, OMM-faithful override prompts and tamper-evident logs, with evidence pre-packaged for surveys and audits.
CII as a live budget – in-year forecasts, “what-if” scenarios (speed, weather, loading, cleaning), and triggered corrective actions; inputs ready for SEEMP Part III updates.
Defensible EEOI – MEPC.1/Circ.684-true voyage sheets, noon-vs-sensor reconciliation, clear exceptions and root-cause notes to separate condition losses from operations.
Evidence automation – one-click audit packs spanning noon/sensor/BDN/MRV-DCS/VDR/CMMS/class with ship–shore version control.
Training that sticks – built-in AI tutorials and micro-modules mapped to your procedures; command can see completion and performance trends to close skills gaps.
How We Deliver
Lead time is about one month from order. During that period we work with your technical; health, safety, environment and quality (HSEQ) and crewing teams to:
Select and prepare sources
Clean and structure the data
Tailor the system to the vessel’s class, trade and equipment
The hardware arrives pre-loaded and ready to join your internal network, with role-based access and full audit trails. Each unit is configured specifically for its vessel.
Why it Matters for Your P&L
First order effect – fewer non-conformities and observations in surveys, audits and Port State Control, faster close-out of checks and reduced off-hire risk because evidence and procedures match.
Second order effect– more stable in-year CII performance, better defended speed/consumption and emissions claims, and a stronger negotiating position with charterers and cargo interests.
Third order effect – a lower perceived risk premium for financiers, visible readiness for tighter regional or global measures, and fuel savings that compound across the fleet.
If you want to turn compliance into competence – and competence into competitive advantage – send us a message at crew@nijhofcs.com. We will show you how the NCIL(M) can lift decision-making on your vessels and tailor a unit to each ship.


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