Recent MEPC meetings have promised a lot but have frequently delivered very little – at least that would be the view of those organizations that want to see shipping moving further and faster on reducing emissions. On the other hand, there are those that consider shipping’s contribution to the global economy to be more important and who think the regulators at the IMO have already moved too far without due consideration of both the operational impact of existing measures of the availability of technologies to meet ambitious – or over ambitious targets.
MEPC 82 fell into this familiar pattern although there was some progress on other matters. It also took place against the backdrop of geopolitical events that has caused emissions from shipping to increase significantly as ships take the route around Southern Africa to avoid terrorist attacks in the Red Sea.
Guidelines and new ECAs adopted
Looking back to the PPR 11 meeting in February, the various Guidelines around the cleanup of plastic pellets carried as cargo, mitigation of risk for vessels carrying HFO in the Arctic, revision to the guidelines for Reduction of Underwater Noise from Commercial Shipping, revisions to the Best Management Practices for Removal of Anti-Fouling Coatings from Ships and Revised Tank Cleaning Additives Guidance were all adopted.
The latter will mean that the list of additives approved by the IMO will now fall into two categories; Branded products will be added to the list for a period of seven years while pure products will not be subject to this limitation. After a product listing has expired, the manufacturer will need to go through the approval process again. The original guidance contained in MEPC.1/Circ.590 will be altered and reissued as MEPC.1/Circ.590/Rev.1 in October this year.
Of the least contentious, the meeting adopted resolution MEPC.392(82) bringing into effect the Canadian arctic and Norwegian Sea ECAs. The two ECAs will come into effect on 1 March 2026 and will mean sulphur in fuel limits of 0.10% and Tier III NOx limits applying. The two ECAs also aim to address long-standing concerns of Black carbon emissions in the arctic region. The new NOx limits begin for newbuilds from 1 January 2025 for the Canadian Arctic and from 1 March 2026 for the Norwegian Sea.
Staying with the subject of NOx, MEPC 82 approved draft amendments to MARPOL Annex Vi and the NOx Technical Code 2008 on the use of multiple engine operational profiles for a marine diesel engine. The amendments should be adopted at MEPC 83. This will allow electronically controlled engines to finally get the best out of their potential in terms of performance under differing operating conditions. Also adopted was resolution MEPC.396(82) – Designating the Nusa Penida islands and Gili Matra islands in Lombok strait as a Particularly Sensitive Sea Area.
CII review to go beyond 2026
On the most contentious issues of emission reduction and efficiency measures progress was claimed to have been made but until everything is agreed nothing is agreed and that is very much the position negotiations were in before and after MEPC 82.
Both the EEXI and CII came into effect on 1 January 2023 as Short-term GHG reduction measures. As a technical measure for existing ships, the necessary changes to ships’ machinery under EEXI have all been made and ships in service should now be compliant. The operational measure known as CII (Carbon Intensity Indicator) is supposed to indicate a ship’s energy efficiency and is given in grams of CO2 emitted per cargo-carrying capacity and nautical mile.
Even before it was introduced, those involved in operating ships were pointing out the CII’s failings. Port delays, trade patterns, route changes necessitated by weather or geopolitical events and a whole host of other reasons beyond an operator’s control could give the impression that a ship was inefficient when in fact it was producing less emissions than an inferior ship not needing to make long ballast runs was doing.
Criticism of the measure by environmental groups was focussed on the fact that beyond having to make changes to improve the CII if it scored lowly for two years in succession, there was no teeth behind it. Rather they would prefer that operators would be financially penalised which solution was never included when the CII rules were drafted. The CII was in fact supposed to be a factor that would influence charterers to avoid ‘inefficient’ ships making them commercially unviable although very few analysts expected this would be the case.
A review of CII was set in place earlier than expected at MEPC 80 and at MEPC 82 the work of the Intersessionary working group (ISWG) was discussed with a number of new proposals being considered. As a way forward the meeting decided to conduct the review based on a gap analysis and a two-phase approach addressing some issues prior to 1 January 2026 (phase 1), and some after that date (phase 2). A list of the issues was drawn up and the ISWG instructed to submit a written review to MEPC 83 for further consideration.
Convergence but slow progress on Mid-term measures
Arguments are most ferocious when it comes to the mid-term measures and the idea of levies and charges are put on the table. There was some progress on convergence but no unanimous acceptance on any single proposal. A draft legal text for use as a basis for ongoing talks around the proposed “mid-term measures” for GHG reduction, which are expected to be adopted in 2025 was developed. These measures include a goal-based marine fuel standard that will phase in the mandatory use of fuels with less GHG intensity and a global maritime GHG emissions pricing mechanism. They are aimed at driving the international shipping industry’s transition to achieve net-zero GHG emissions by or around 2050.
There was too no agreement on the purpose of any levies or financial measures. Some believe that the money should be retained within the industry to develop new technologies and to incentivise their adoption. Others believe that the money should be used to mitigate the impact of climate change where it is needed most by developing states and small islands.
As things stand, the schedule for the mid-term measures remains; Approval of the draft legal text at MEPC 83 in spring 2025, adoption at an extraordinary session of MEPC in Autumn 2025 and entry into force by 2027. There are still major concerns, one of which was the lack of a detailed assessment of the impact of any reduction measures on food security. It was agreed to initiate supplemental studies into this critical aspect before the next session.
Still on the table are measures such as a pooling agreement whereby emissions from the least efficient ships in a fleet could be offset by more modern vessels and also the question of whether carbon capture will be accepted and under what rules. Time ran out for any lengthy discussions on the question of exhaust gas cleaning systems despite several issues being raised. Consequently, the draft terms of reference for the re-establishment of the GESAMP Task Team on EGCS to was deferred to PPR 12 for further consideration with a view to finalization.
Cautious welcomes and criticisms
Reaction to MEPC has fallen into predictable patterns with many shipping organisations pointing out the progress made while environmental groups appear frustrated at the lack of progress. “Countries at the IMO are moving way too slowly to make decisions on the crucial details of the policy measures needed to meet the emission cuts committed to in the 2023 greenhouse gas strategy”, said Sandra Chiri, International Outreach Manager, Shipping Emissions, Ocean Conservancy.
From the industry side, an ICS statement said it welcomed further progress achieved on developing a base text for amendments to the MARPOL Convention, to help ensure delivery of the IMO goal for international shipping to deliver net-zero greenhouse gas (GHG) emissions by or close to 2050 while warning more work still needs to be undertaken by governments before this ‘Net-Zero Framework’ is ready to be approved at next year’s critical MEPC 83 meeting in April. The ICS statement also said it was pleased that MEPC has committed to consider and address all identified system anomalies within the review of the Carbon Intensity Indicator but warned the workload was considerable and would extend beyond 2026.
Further information on MEPC can be found on the IMO website here.
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