Ahead of next week’s International Maritime Organization’s Marine Environment Protection Committee meeting (IMO, MEPC 82, September 30-October 4), the Clean Shipping Coalition urged national delegations that support ambitious climate action to also insist that the IMO revise its ship efficiency standards to ensure the organization’s climate targets are met.

Along with this week’s Intersessional Working Group on Reduction of GHG Emissions from Ships (IMO, ISWG-GHG-17), this the first occasion with all three critical elements of the IMO's implementation of its GHG Strategy - the Carbon Intensity Indicator (CII) revision, Global Fuel Standard (GFS) and a greenhouse gas (GHG) levy on the table at the same moment.

“At last week’s intersessional ship climate negotiations we saw growing support for a ship GHG levy and fuel standard. These need to be urgently agreed, but they are not enough on their own”, said Clean Shipping Coalition President Delaine McCullough. “At MEPC 82, unless IMO member states show an equal commitment to revision of the organization’s energy efficiency rules - the CII, international shipping will be unable to meet the crucial emission-reduction targets that it agreed only last year.”

“Having the GHG levy and fuel standard, along with the CII revision, will ensure the shipping sector maximises energy efficiency to immediately cut emissions, drive the uptake of onboard wind and solar propulsion and investment in scalable zero-emission fuels, and guarantee an equitable and just transition to zero-emission shipping”, said McCullough. “There’s no time to waste on false solutions—the IMO member states must adopt a comprehensive and fully integrated set of efficiency, fuel and energy emission standards, and carbon pricing policies.”

Carbon Intensity Indicator
“The revision of the Carbon Intensity Indicator (CII) should take place without delay, that is, by 2026, to ensure the CII can make the necessary contribution to reaching the 2030 IMO GHG Strategy targets”, said McCullough. “This revision should maximize the operational efficiency of ships now, and in the future, to drive down fuel-burn for the long-term, and actively favor the primary use of wind and solar for ship propulsion. Even with a successful outcome on the GFS/levy, which is far from certain, we will still need an effective revised CII to deal with the other 50% of emissions.”

NGOs are also calling for the IMO to recognize the need to elevate other crucial issues, such as risks to biodiversity and pollution from shipping:

“The IMO must put biodiversity and pollution threats on the same footing as its response to the climate crisis”, said Andrew Dumbrille, Director of Equal Routes. “A healthy, diverse ocean plays a vital role in tackling climate change. The ocean has the ability to soak up 31% of global CO2 emissions and produces half of the planet’s oxygen. A high level and well-coordinated task force, similar to IMO's Maritime Just Transition Task Force, should be agreed at MEPC 82 to prioritize solutions with co-benefits which address the triple planetary crisis of climate change, biodiversity loss and increased pollution.”

Global Fuel Standard
“The IMO agreed to targets last year but, as we enter the crucial phase of hashing out concrete measures to deliver them on the Global Fuel Standard progress is shaky”, said Constance Dijkstra, IMO Policy Manager at Transport & Environment. “ As discussions move forward, this can be the beginning of the end for fossil fuels in shipping. But there is a high risk that IMO rules might end up doing more damage than good by promoting biodiversity-destroying biofuels. Countries must be razor-focused on promoting wind and future-proof fuels such as sustainable e-fuels, and promote these as they iron out the details of the rules.”

Greenhouse Gas Levy
“It is positive to see that a universal levy on all shipping’s life-cycle GHG emissions gathered significant support in this first week of IMO meetings”, said Bastien Bonnet-Catalloube, Expert on decarbonization of aviation and shipping, Carbon Market Watch. “In the second week, we must reach a consensus around a levy of $150/tonne of life-cycle GHG emissions, as proposed by a group of Pacific Island and Caribbean states, thereby meeting the requirements of the GHG Strategy for mid-term measures with both a technical and economic element and that address the just and equitable transition. Only a strong levy accompanying a GFS can do that. The time is now”.

“In the lead up to this week’s negotiations, the Pacific and Caribbean delegations put forth this week a clear and comprehensive proposal for how a $150 GHG levy can support the most vulnerable. While the primary purpose of the levy is to drive emission reductions, it will generate resources that can support a just and equitable transition. Their vision includes how the resources can be used both in sector and out of sector to ensure that no country is left behind as shipping transitions to a cleaner future. It's encouraging to see so many countries from across the world showing continuous support for a GHG levy approach, but now is the time to make decisions, so that we can create a fair and equitable transition that addresses the needs of those most at risk”, said Sandra Chiri International Outreach Manager - Shipping Emissions at Ocean Conservancy.

“Many countries have raised concerns about the potential impact of shipping decarbonization on their supply chains, especially regarding food security. Climate change already poses serious risks to global trade, disrupting shipping routes, ports, and food distribution systems. To address shipping's role in the climate crisis, we need urgent action. By enhancing vessel energy efficiency, adopting a global fuel standard, and implementing an ambitious levy to rebalance economic impacts, we can ensure that shipping's transition to a cleaner, more resilient future is both just and fair - leaving no country behind”, said Anaïs Rios, Shipping Policy Officer, Seas At Risk.

Black Carbon
”During MEPC 82, the IMO must commit to developing new regulations which identify fuels suitable for use by international shipping in the polar regions because they would deliver an immediate fuel-based reduction in black carbon emissions which impact the Arctic”, said Dr Sian Prior, Lead Advisor to the Clean Arctic Alliance. “With a changing Arctic having detrimental impacts on weather systems around the world], governments must start to regulate emissions of short-lived climate forcers such as black carbon.”

Emission Control Areas
“Emission Control Areas have played a central role in air pollutant reduction and likewise fostered the development of cleaner burning fuels, exhaust after-treatment technologies as well as efficiency technologies. As a next step almost all Norwegian and Canadian waters will become ECAs. Moreover, in May 2025 the Emission Control area in the Mediterranean will come into force to the benefit of 240 million people's health. Unfortunately, it just covers sulphur while a decision on nitrogen is still pending. We very much welcome the recent developments but call on the IMO and governments to strive for stricter regulation to cover more areas. Therefore, we very much welcome North Atlantic states’ intention to move ahead with the probable world's biggest emission control area for sulphur and nitrogen oxide. ECAs are very cost-effective measures, because the harm that the pollutants put to health, environment and climate are much bigger that the cost of compliance for shipping”, said Sönke Diesener, shipping expert at NABU.

Scrubbers
“In order to prevent a further continuous pollution and acidification of the seas and oceans, the IMO is urged to prohibit the use of scrubbers as a means of compliance with the global sulphur cap”, said Maarten Verdaasdonk, Project Manager Clean Shipping at the North Sea Foundation. “Until a global ban is introduced, other measures should be taken. National maritime administrations could be encouraged to ban the discharge of scrubber waste within their jurisdictional waters and to stop approving scrubbers as an alternative compliance method for ships registered under their flags. At the same time, the IMO could develop and adopt a resolution calling on shipping operators to immediately stop the release of scrubber discharge wastes in ecologically sensitive areas such as coastal and marine protected areas, critical habitats for endangered species, IMO-designated Special Areas and PSSAs.”

Underwater Noise
“In order to effectively reduce underwater radiated noise from ships, the IMO must continue to encourage member states and industry to share lessons learned and best practices as part of the three year experience-building phase of the implementation of the Revised noise Guidelines, and to focus on the important tasks laid out in the noise reduction Action Plan. The time is now to determine and implement the most effective measures and policies to successfully reduce the impacts of underwater noise on marine life”, said Sarah Bobbe, Senior Manager, Arctic Program, Ocean Conservancy.

Plastics
​​”Since the adoption of the Action Plan in 2018, progress on plastics at the IMO has stagnated, while sea-based plastic pollution continues to surge alongside rising plastic production. These plastics are devastating ecosystems, coastal environments and food security. Yet, despite this urgency, we've seen repeated delays, deferrals, and a glaring lack of ambition from the IMO to tackle this crisis with decisive action. The IMO must go beyond just ticking boxes and take meaningful and effective actions. Adopting policies without ensuring real-world impact gives only the illusion of progress. It is time for the IMO to deliver tangible outcomes by enforcing regulations, promoting innovation and prioritizing solutions that truly reduce marine litter,” said Amy Youngman, Legal and Policy Specialist, Environmental Investigation Agency.

Shipbreaking
“To stop pollution caused by ships at end-of-life, the IMO will have to seriously improve the standards set by its Hong Kong Convention, which enters into force in June 2025 and currently allows the scrapping of ships on unprotected and sensitive tidal mudflats,” said Ingvild Jenssen, Director of the NGO Shipbreaking Platform. “At its upcoming meeting, the IMO must also acknowledge that there can be no exception for the shipping sector to abide by well established international environmental laws, including UNEP’s Basel Convention on the Transboundary Movements of Hazardous Wastes and their Disposal.”