The path to maritime decarbonization continues to evolve — and so do the regulatory and operational questions surrounding implementation.

Background

The IMO’s Net Zero Framework (NZF) is a regulation developed over more than 5 years to reduce greenhouse gas (GHG) emissions from international maritime shipping to net zero by 2050, using a combination of technical and economic measures. The NZF aligns with the Paris Accord targets and the IMO’s revised GHG reduction goals and strategy, as agreed in 2023.

After initial acceptance at the 83rd session of the Marine Environmental Protection Committee (MEPC 83) in April 2025, the NZF was scheduled for formal adoption during the recent Second Extraordinary Session (MEPC ES2) back in October of 2025. With no clear consensus in site, the session and the roll call vote requiring a two-thirds favorable majority on NZF adoption were adjourned for one year.

What Happened at MEPC 84

The regularly scheduled MEPC 84 meeting was held recently in London from April 27th to May 1st. Since this was less than one year from the adjournment of Second Extraordinary Session (MEPC ES2) there were no expectations for any direct vote on the NZF. At this session of the Committee and the preceding sessions of the intersessional working group on reduction of GHG emissions (ISW-GHG 19 and 20), progress continued to be made on refining and elaborating the guidelines for the NZF. Significant progress was made on the greenhouse gas fuel intensity (GFI) calculation methodology, sustainable fuel certification, zero- and near-zero-fuel definitions and rewards, and lifecycle analysis (LCA) guidelines for well-to-wake GHG fuel factors.

Several national delegations introduced concepts to modify the NZF as a way forward to break the deadlock at MEPC ES2, primarily by eliminating or restructuring the NZF’s economic penalty component. The discussions seemed to indicate that most delegations in favor of the NZF remain strongly in favor of adopting the unchanged regulation, and most delegations opposed to the NZF remain strongly opposed to including any type of economic levy on GHG emissions paid into an IMO-directed fund, with few of the uncommitted indicating their position. The general atmosphere was decidedly more congenial than at ES2, but positions seemed as entrenched as ever. However, multiple delegations on all sides indicated a willingness to make some compromises.

What Happens Next

The schedule for the rest of the year has been set:

  • ISWG-GHG 22 will meet on September 1-4, 2026
  • ISWG-GHG 23 will meet on November 23-27, 2026
  • MEPC 85 will meet for 4 days, November 30 to December 3, 2026
  • Followed by the resumption of ES2 for one day following MEPC 85 on
    December 4th, 2026

Assuming that some modified NZF will emerge from the intersessional and MEPC 85 meetings, the procedure at the resumed one-day ES2 meeting at the end of MEPC 85 would likely be roll-call votes on the following issues:

  1. Resolve if any adopted NZF regulations will finally enter into force by the “tacit” procedure (as an amendment to the current MARPOL convention), or by the much more difficult to meet “explicit” acceptance procedure (as is required for a new convention). Agreement could be by unanimous acclaim, but would likely need a roll-call vote.
  2. If it were obvious to all that neither the existing NZF nor an alternative proposal had sufficient support, there could be a vote for an additional one-year adjournment
  3. More likely, a motion to accept the existing unchanged NZF by a roll-call vote would come next.
  4. If there was not a two-thirds majority in support of the unchanged NZF, there would likely be a follow-up discussion regarding a modified NZF, which could be agreed by unanimous acclamation but would also likely require a roll-call vote.

Currently, it seems unlikely that there will be a two-thirds majority support for the unchanged NZF. So, unless a politically palatable modified NZF is negotiated through the intersessional process, the NZF will effectively be shelved on December 4th, and the entire process of developing GHG mid-term measures to meet the agreed IMO GHG emission goals will need to be restarted.

See the MEPC 84 ECA Expansion post here >

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