Background
The IMO again held ‘back-to-back’ meetings in London for the 17th session of the Intersessional Working Group on GHG emissions (ISWG-GHG) on the 23rd to 27th of September 2024 and the subsequent 82nd session of the Marine Environmental Protection Committee (MEPC) on the following week of 30 September to 4 October.
The topics addressed at the meeting were:
· Modifications and improvements to the short-term GHG measures (CII & EEDI)
· Mid-term measures for Greenhouse Gas (GHG) Emissions
· Washwater effluent from exhaust scrubbers
· Guidelines to reduce Arctic black carbon emission
· Amendments to the Ballast Water Convention
· Guidelines for managing plastic pollution at sea
· Proposed new ECA’s in the Canadian Arctic and Norwegian Sea
· Approving plans to reduce underwater radiated noise
This brief focuses on the first two main issues.
Short-term GHG Measures (Modifications to the CII and EEDI
Short-term measures (EEDI for new ships, and CII plus SEEMP for all ships operating) are intended to support the IMO’s ambition of net-zero by 2050, and in particular, the ambition of short-term reduction of CO2 emissions per transport work target of 40%, and the overall decrease in GHG emissions by 20%-30%, by 2030.
Three main issues remain to be addressed for these short-term regulations:
· The reduction factors for the years 2027-2030 and beyond, which were left unspecified in the initial CII regulations
· Consideration of a large number of specific improvements and ship type adjustments in the CII
· Methodology of transitioning from tank-to-wake (TtW) to well-to-wake (WtW) fuel factors for the CII regulations
While the working group at MEPC 82 discussed many items, decisions on them were deferred. The 2027-2030 reduction factors and a few adjustments (handling port and idle time, short voyages, cruise ships' time in port) will be resolved before January 2026. The remaining issues (adjustments for bulk carriers, adverse weather considerations, ballast voyages, refer cargo, ro-ro passenger ships, and WtW factors) were further deferred beyond January 2026.
Mid-term Measures for GHG Emissions
Possible mid-term measures, scheduled to come into force in January 2027 (some delegations favor January 2028), are intended to support and incentivize the transitions to meet the IMO’s ambitions for net-zero GHG emissions in 2050, including the intermediate targets in 2030 and 2040.
The desired January 2027 enforcement date requires that the mid-term measures be completed for approval at the next MEPC 83 meeting in April 2025.
As anticipated, no decisions were made at this session, and ongoing discussions on the possible mid-term measure options and the framework for the MARPOL text progressed at both ISWG-GHG 17 and MEPC 82.
The discussions indicated that many member countries support combining technical and economic measures to incentivize the transition to net zero. There is broad support for applying the measures initially to all ships over 5000 GT on international voyages (and later to ships down to 400GT).
The technical measure is converging on a GHG fuel intensity requirement called GFI. GFI is the amount of GHG emissions per unit of energy used, and it is to be adjusted annually to mirror the IMO GHG emission targets of a 30% reduction in 2030, an 80% reduction in 2040, and net zero in 2050 (compared to the 2008 baseline). GHG accounting is to be based on well-to-wake (WtW) emissions.
Multiple economic measures are under consideration, but they seem to converge some form of GLG levy or pricing per ton of CO2 equivalent, with payments collected over the annual target intensity and credits dispersed under the annual target intensity. Some proposals permit fleet pooling, trading, and banking of credits to reward early adopters of zero and near-zero carbon technologies.
There is also broad support that the funds generated from the economic measures are to be deposited into an IMO-controlled fund to be directed to support transition initiatives.
The working group and MEPC have produced a broadly supported draft of MARPOL Annex VI Chapter 5, including all the proposed options. This draft will now become the basis for the upcoming discussions and negotiations.
Summary and possible outcomes
As generally anticipated, MEPC 82 was a relatively relaxed and congenial session with no final decisions about the short- and mid-term GHG measures. MEPC 83 in April 2025, supported by two interim ISWG-GHG meetings, 18 & 19, is likely to be very different, potentially contentious, and challenging. While there appears to be growing consensus around some fee-based GHG incentive measures supporting the agreed GHG reduction ambitions, some nations remain opposed, and many member states have not yet expressed their views. However, the IMO usually has a way of meeting its self-imposed deadlines. MEPC 83 will likely approve some of these mid-term measures and implement a new GHG chapter of MARPOL Annex VI for adoption. Still, the negotiated specifics will make all the difference.
