London, 27 August 2026:- Ahead of next week’s key
meeting of the International Maritime Organization (IMO),
the Clean Shipping Coalition is calling on member states to
hold firm in their support for the Net-Zero Framework (NZF)
– the UN shipping body’s long negotiated compromise
climate agreement – in the face of “alternative
proposals” that seek to undermine climate action by the
shipping sector.
“While less ambitious than we had
hoped for, the NZF’s broad political support from member
states means it remains the best tool available to meet the
IMO’s Greenhouse Gas Strategy goals on climate,
decarbonisation and a just and equitable energy transition
for the shipping industry, and must be adopted by the IMO
this December”, said Clean Shipping Coalition President
Lukas Leppert. “The result of multiple rounds of
negotiations, the NZF is already by any measure, an
acceptable compromise. Any further weakening would lead to a
less effective, slower, and costlier
transition”.
The shipping sector makes up 2-3% of
global greenhouse gas emissions – comparable to the
world’s fifth biggest emitting country, Japan. The IMO has
committed to achieving its GHG Strategy goal, including its
long-term goal of decarbonisation by 2050, its interim
targets of a 30% reduction in absolute emissions by 2030 and
80% by 2040, and its commitment to a just and equitable
transition.
Discussions during ISWG-GHG 22
(Intersessional Working Group on Reduction of GHG Emissions
from Ships in London, 1-4 September) are expected to include
IMO’s long negotiated compromise agreement, the Net-Zero
Framework (NZF), and its proposed adoption at December’s
Marine Environment Protection Committee (MEPC 85/ES.2).
Approved during MEPC 83 in 2025, the NZF includes a
“global fuel standard” (GFS), which requires ship
operators to gradually decrease the amount of greenhouse gas
emitted by shipping fuels – or pay penalties. The framework
also introduces a mechanism that puts a price on a portion
of greenhouse gases ships emit, giving the industry a clear
financial incentive to reduce emissions in line with the
global fuel standard. See also: IMO paper on the NZF – MEPC
85/3/8: Consideration And Adoption of Amendments to
Mandatory Instruments: Amendments to MARPOL Annex
VI.
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“Shipping is the backbone of the global economy,
with estimates of shipping trade’s market value topping
$14 trillion, but as it’s also a major source of climate
pollution, heating up our ocean and our planet, it must be
part of the solution”, said Delaine McCullough, Shipping
Program Director at Ocean Conservancy. “As ocean
temperatures hit record highs again this summer, increasing
storm intensity and threatening marine life, food supplies,
and coastal communities, there’s no time for further delay
in addressing the roughly one billion tons of carbon dioxide
shipping spews into our atmosphere every
year.”
“It’s taken years of negotiating and
compromise by IMO member states to get to the Net-Zero
Framework (NZF)”, added McCullough. “It may not be
perfect, but it has the elements needed to eliminate the
global shipping industry’s emissions by 2050 and help ensure
that the countries facing the greatest climate risks with
the least capacity to respond are not further harmed in the
maritime energy transition. Adoption of the NZF ‘as is’
would be a huge step forward for our climate, communities,
and ocean.”
“The Clean Shipping Coalition cannot
support any option that does not include a financial GHG
emission penalty and fund”, said Sönke Diesener, Senior
Policy Officer Maritime Transport at NABU. “These economic
measures are essential for incentivizing emission
reductions, supporting the uptake of zero-emission fuels and
technologies as well as for ensuring a just and equitable
transition. The sector requires clear regulatory directions
for the transition and the IMO now has the opportunity to
deliver global planning security for the ramp-up of
sustainable solutions.”
Further consideration of the
development of the IMO Life Cycle GHG Assessment (LCA)
framework which will determine well-to-wake emissions and
sustainability criteria for global marine fuels is also
included on the ISWG-GHG 22 agenda.
“If the IMO
gives an advantage to methane-based fuels such as LNG and
biomethane, as current submissions to ISWG are calling for,
this would lock in shipping emissions of methane, a super
pollutant, for decades to come”, said Andrew Dumbrille,
Co-Director, Equal Routes. “The LCA guidelines must
include sustainability criteria that account for
biodiversity and human rights impacts, real world emissions
factors for methane-based fuels, and reflect GHG emissions
of indirect land use change caused by production of biogenic
fuels.”
“With accelerated climate warming already
driving devastating impacts around the world, such as record
heatwaves, flooding, wildfires and droughts, there is no
doubt that the industry must rapidly lower its greenhouse
gas emissions”, said Anaïs Rios, Senior Shipping Policy
Officer at Seas At Risk. “For the shipping sector, the
question is no longer whether it needs to decarbonise, but
how best to meet the goals of the International Maritime
Organization’s (IMO) GHG (greenhouse gas) Strategy and to
reach net zero by 2050. The industry must quickly evolve so
that it acts as a shared good for people, rather than a key
contributor to the climate crisis and the loss of health and
livelihoods around the world. The best way to achieve this
is for IMO member states to adopt the Net-Zero Framework in
December.”
Following widespread support for the NZF
at MEPC 84 in May 20226, the Clean Shipping Coalition stated
that “IMO’s Net-Zero Framework is back on track”, but
that supporters must remain “vigilant and strong in order
to parry inevitable future attacks and attempts to further
delay the process of adoption, which is scheduled for early
December”.
Those threats have now materialized in
the form of ‘alternative’ proposals from a number of IMO
member states. Having analysed the available proposals, the
Clean Shipping Coalition has found two of them particularly
unfit for decarbonization: those submitted by Liberia and
Japan. (The other proposals are covered in the notes
below.)
Liberia
Instead of setting reduction
targets on a path to net zero, the submission from Liberia –
the world’s largest flag state – would allow ships to
stick to conventional fuels if they think cleaner
alternatives are too costly or
unavailable.
Additionally, Liberia’s proposal puts
greater emphasis on trading of surplus units, while removing
the idea of mandatory payments into a Net-Zero Fund. Without
reduction targets or financial incentives, this would not
cause a shift in the shipping sector beyond
business-as-usual, while the lack of available funds would
make it impossible to address disproportionately negative
impacts on states.
“By failing to ensure a just and
equitable transition on top of its poor climate performance,
the Clean Shipping Coalition finds that Liberia’s proposal
constitutes a fundamental redesign which will fail to
deliver on the goals set out in the 2023 IMO Greenhouse Gas
Strategy”, said Leppert.
Japan
Japan’s
proposal would fundamentally fail to deliver on the goals
set out in the GHG Strategy 2023. Japan has put forward a
questionable alternative to compliance payments flowing into
a centralized fund, which would allow shipowners to direct
payments to projects of their own choice.
“Without
proper oversight from a governing board, and a clearer
focus, the system proposed by Japan risks creating a scheme
where money is invested into projects that do little to
reduce emissions”, said Alex Springer, Interim Shipping
Director at T&E. “Left to its own devices, the
industry will continue its reliance on dead-end
‘solutions’ like fossil LNG or crop biofuels, for an
expensive, long-term fossil lock-in. Real solutions such as
e-fuels and electrification require investment certainty,
long-term targets, and robust governance – all of which the
proposal is lacking.”
The Clean Shipping Coalition
is calling for a central fund administered by the IMO or
another independent body and sufficient contributions to
ensure a just and equitable transition. In order to leave no
one behind, states facing disproportionately negative
impacts like small island developing states and least
developed countries need financial support – which they made
abundantly clear at previous negotiations. Japan’s proposal
would clearly fail to deliver, haemorrhaging support from
one group of states in an attempt to appease
another.
Japan’s proposal also carries serious
procedural risks. As it was not circulated six months ahead
of the meeting (as is the normal requirement), it cannot be
adopted under normal rules at MEPC 85.
The IMO already
delayed its planned timetable of establishing a climate
framework for global shipping in 2025, by adjourning MEPC
ES.2 for a year. This delay has wasted time as the planet
warms, emissions of greenhouse gases from global shipping
continue unhindered, and delayed investments will lead to a
hastier and in turn costlier transition. By diverting
attention from circulated proposals the submission from
Japan risks throwing the IMO further off-course, and would
provoke a loss of trust in the organisation’s capacity to
police international shipping and deliver on its own
goals.
“Both the Liberia and Japan proposals are
wrecking balls – aimed at the heart of shipping climate
action, and will prevent necessary action, cause higher
total costs, will not support a just and equitable
transition, and ultimately will fail to meet the obligations
the shipping sector faces”, said Leppert. “Both
proposals are designed to placate those that do not think
shipping climate action is needed, and serve only to
undermine what has been achieved so far. Getting to the
Net-Zero Framework is the result of multiple years of
negotiations. The result is supported by a comprehensive
impact assessment, and has the ability to deliver on the
goals of the IMO GHG Strategy”.
“Forget the
distractions. Now is the moment for the IMO and all its
member states to have the courage to protect and adopt the
Net-Zero Framework ‘as is’”, concluded
Leppert.
Notes: Other alternative
proposals
Brazil Proposal
Brazil’s proposal
at best can be seen as a weakened version of the NZF: it
delivers fewer GHG reductions in the short term, is
associated with higher total costs of the transition due to
a later kickoff and steeper targets from 2040, and will not
gather sufficient financial contributions at the outset.
Furthermore, success of delivering a just and equitable
transition hinges on the concrete configuration of the
proposed “facility” and whether it will be able to
support countries facing disproportionately negative impacts
or just become an empty shell. Overall, as Brazil’s
proposal presents a weaker and overall costlier version of
the NZF, which itself is a compromise that doesn’t achieve
the IMO’s own GHG strategy, the NZF should be favoured
over the Brazil proposal.
Pacific Proposal
The
proposal submitted by Pacific IMO members, which concerns
introducing a carbon levy for all GHG emissions of shipping,
provides a strong economic incentive for ships to reduce
their emissions, while generating sufficient financial
resources to support the maritime energy transition, and at
the same time ensure that no countries are
disproportionately harmed by negative impacts of the
transition with everyone benefiting from the economic
opportunities the energy transition provides.
The
Clean Shipping Coalition supports the Pacific proposal, as
it showcases which approach has the best outcome and to
highlight that the NZF ‘as is’ is already a compromise
after years of negotiation that shouldn’t be watered down
further. It can also be used to show that the limits of
possible policy frameworks are not the NZF and Liberia, but
that the NZF is indeed the middle ground, supported by a
wide range of member states.
About the Clean Shipping
Coalition:
The Clean Shipping Coalition is an
international association of civil society environmental
protection organisations, and the only one with a purely
shipping focus.
We help develop and drive global
environment and climate laws on shipping, principally at the
United Nation’s shipping regulator, the International
Maritime
Organization.
