MEPC 81, movement on the GHG reduction plan and new ECAs approved

New Emission Control Areas and Advancements in Marine Environmental Protection.


by Paul Hopkins

As expected much of the time at MEPC 81 was devoted to GHG emissions, air pollution and energy efficiency but there were also developments in other matters such as ballast water management and most notably two new designated emission control areas (ECAs).

Taking the latter first as these are the least controversial, the meeting approved Canada’s proposal for the establishment of a Canadian Arctic Emission Control Area for NOx, SOx and particulate matter (PM). This new ECA would have the added benefit of partially addressing concerns around black carbon emission in the Arctic region.

For SOx the ECA limit of 0.1% sulphur content would apply to fuel used on board and for NOx, Tier III levels would apply to new ships with a keel laying date after 1 January 2025 (assuming MEPC 82 adopts the proposal).

Also approved was Norway’s proposal for a Norwegian Sea ECA which, if adopted by MEPC 82 would become effective on 1 March 2026. For NOx Tier III to apply to a ship the building contract would need to be placed after 1 March 2026, or if no building contract a keel laying date on or after 1 September 2026. For other new buildings already ordered the ECA would apply if delivery occurs after 1 March 2030.

Ballast developments

Discussion on ballast water treatment (BWT) saw four systems given new type approval and one using an active substance granted Basic Approval. The BWT convention is now being monitored in what is called the ‘experience building phase’ where identified weaknesses and contradictions are addressed. MEPC 81 accepted the recommendations of the Correspondence Group and recognised these included: survey aspects such as sampling and analysis of ballast water to confirm the treatment capacity and discharge concentration of active substances during intermediate and renewal surveys, in addition to commissioning tests, to ensure appropriate installation and effective operation. It was agreed to re-establish the Correspondence Group for pursuing the topics that require further discussions.

Interim guidance on ballast management for ships operating in challenging water quality was adopted and work continues on developing a comprehensive set of guidelines to apply to ships, administration and ports. Guidance for temporary storage of treated sewage and grey water in ballast tanks, necessary when reception facilities at ports is inadequate, was approved. The guidance sets out the standards such as for flushing tanks after temporary storage and for implementing the relevant procedures in Ballast Water Management Plans.

GHG levy gathers more support but no consensus

Turning to the more difficult subject of GHG emissions, this was the first opportunity to work on the IMO Strategy on Reduction of GHG Emissions from Ships (2023 IMO GHG Strategy) adopted at MEPC 80.

Measures already in force such as the Data Collection System (DCS) for fuel oil consumption of ships, EEXI and CII regulations were reviewed along with discussions on mid-term measures and lifecycle assessments of marine fuels. For DCS the MEPC 80 approvals were adopted requiring data on total fuel oil consumption per combustion systems and total fuel oil consumption while the ship is not under way. Also adopted were amendments to the relevant IMO SEEMP Guidelines on “total transport work” calculations.

Moving to the mid-term measures for GHG reduction

The strategy is now at the point where the comprehensive impact assessment (CIA) is to be performed to assess what impacts there might be on the shipping industry and individual countries by adopting identified measures or combinations of measures. This is expected to be completed in July this year. Any measures would need to be adopted in 2025 in order to come into force in 2027.

The discussions at MEPC 81, centred mostly around the work of the working group ISWG-GHG 16 which met the week before. The Working Group had set out eight candidate mid-term measures and five elements for the development of the basket of measures.

GHG emissions levy

At MEPC there was a growing but not unanimous growing support for a GHG emissions levy. MEPC agreed that the possible way forward would be to identify a common structure of the legal framework for the basket of candidate measures. During discussions, several delegations supported that it would be premature to rule out any of the candidate proposals without having the outcome of the CIA and that the common structure should not prejudge any future changes or possible outcomes of further negotiations.

IMO Net-Zero Framework

The meeting approved the possible outline of the “IMO Net-Zero Framework” with several required amendments to MARPOL Annex VI, which can be used as a starting point for consolidating the different proposals into a possible common structure. It also agreed to establishing the Fifth GHG Expert Workshop on the further development of the basket of mid-term measures.

During discussions, several delegates felt that the GHG-EW 5 should primarily focus on increasing understanding of the preliminary findings of the CIA for a broader group of delegates than those engaged in the Steering Committee, whereas others expressed that the GHG-EW 5 should not engage in any policy negotiations but provide relevant information to the Committee and/or Steering Committee. It was agreed to organise an expert workshop to give an understanding of the preliminary findings of the CIA.

MEPC 81 established and instructed ISWG-GHG 17, to take into account the final report of the CIA of the basket of mid-term measures, the report of the GHGEW 5 on the further development of the basket of mid-term measures and relevant documents submitted to MEPC 82 as also to previous sessions to progress the matter.  Outcomes should include draft Terms of Reference for the Fifth IMO GHG Study, and a written report to MEPC 82.

Carbon Capture and LCA need more work

Two other agenda items, carbon capture onboard and fuel life cycle analysis, will play into the mid-term measures and decarbonisation goals. It was agreed to establish a Correspondence Group that will further consider issues related to onboard carbon capture and develop a work plan on the development of a regulatory framework for the use of onboard carbon capture systems with the exception of matters related to accounting of CO2 captured onboard ships and submit a written report to MEPC 83.

There has been much discussion on the GHG intensity of different fuels in recent years focussing on the fact that while some fuels produce higher amounts of GHG than others when used on a ship, the production, storage and delivery processes of other fuels means the overall GHG emissions of those fuels could actually be higher.

Initial guidelines on lifecycle analysis (LCA) of GHG intensity of fuels LCA were adopted at MEPC 80. At this session, MEPC adopted Resolution MEPC.391(81), 2024 Guidelines on life cycle GHG intensity of marine fuels (2024 LCA Guidelines), which incorporates draft amendments proposed by an LCA Correspondence Group. Furthermore, as the issues investigated at the Correspondence Group were diverse and required expertise, it was agreed to newly establish a Working Group on the Life Cycle GHG Intensity of Marine Fuels under GESAMP to pursue discussions along with its Terms of Reference.

There were adoptions of resolutions relating to reporting of containers lost at sea, recommendations on the carriage of plastic pellets as cargo in containers, and endorsement of a Draft Action Plan for reduction of underwater noise from commercial shipping and an agreement to include an agenda item on the topic for MEPC 82.

A small number of matters including proposed amendments to the 2021 Guidelines for Exhaust Gas Cleaning Systems with regards to nitrates, were held over due to lack of time or for requiring further input.

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