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Next week, our Head of Legal Affaires, Sinem Ogis, is heading to International Maritime Organization, making sure our customers get the latest updates as the IMO is set to adopt its Net-Zero-Framework. Here are her key points prior to the meeting.
At the upcoming extraordinary MEPC session, the IMO is set to adopt the first global regime regulating GHG intensity in shipping. The message to the industry is clear: emissions performance is no longer optional. It will define compliance costs, competitiveness, and market access.
Next week´s adoption is only the start. The amendments would enter into force in early 2027, with the first reporting period starting in 2028. But the real impact will be decided by the detailed implementing guidelines due between 2025 and 2027 - from the IMO LCA Guidelines to the rules on how ships can prove the use of low- or zero-carbon fuels. Key among these is the debate on “chain of custody” models, such as mass balance and book-and-claim.
Beyond the MARPOL amendments, MSs are developing a package of around ten implementing guidelines in ISWG-GHG/MEPC (Intersessional Working Group on Greenhouse Gases) to be finalised between 2025-2027. These guidelines covering topics such as, among others:
For example, the 2024 IMO LCA Guidelines, adopted at MEPC 81, set the baseline methodology for life-cycle (well-to-wake) GHG emission factors. They remain under development: only three of 128 fuel pathways currently have full values, and further revisions at MEPC 84 (2026) and MEPC 87 (2028) are expected to expand coverage of alternative fuels and refine rules on default values, sustainability and certification.
.....One particular issue relates to LNG and its life-cycle emissions.
For LNG-fuelled ships, the key metric is the well-to-tank (WTT) default emission factor. In the recent submissions, Norway has proposed (MEPC 84/7/1) 17.4 g CO2-eq/MJ, but other submissions (MEPC 83/7/28) argue for higher defaults such as 27.95 g CO2-eq/MJ. The final figure will strongly influence how “green” LNG looks on paper.
These guidelines will determine the real cost and feasibility of compliance.
How can ships credibly prove the use of low- or zero-GHG fuels? Two main models are under discussion:
Mass balance: Alternative and fossil fuels can be blended in the same pipeline, but the “green” share is tracked administratively so that only the certified amount is claimed downstream.
Book-and-claim: The physical fuel and the environmental certificate are separated. A ship can buy a certificate from a producer of alternative fuel and claim the GHG reduction even if the green fuel is consumed elsewhere.
Submissions highlight that these models could speed up the uptake of alternative fuels, because they allow ships in ports without alternative fuel to still claim verified reductions.
At the same time, several points call for particular caution:
How IMO resolves this question will shape both the credibility of the NZF and the cost and pace of scaling up alternative fuels.
At entry into force the framework will apply only to ships ≥5,000 GT on international voyages. Ships between 400–5,000 GT remain outside the mandatory regime at least until the first scheduled review, expected around 2032.
However, MSs could allow voluntary opt-in. For example, proposals from ZESTAs suggest that smaller ships opting in could:
This opens access to IMO funds for zero- and near-zero-carbon fuels and infrastructure, while avoiding the need for separate national credit systems.
Adoption in October signals certainty but does not settle the real costs. Between 2025–2027, IMO’s detailed LCA, default factors, and chain of custody rules will define compliance costs and competitiveness. Companies that prepare now, by understanding their fuel pathways and emissions, will be best positioned to reduce both emissions and regulatory exposure.
Politics around the IMO Net-Zero Framework vote
Next week, our Head of Legal Affaires, Sinem Ogis, is heading to International Maritime Organization, making sure our customers get the latest updates as the IMO is set to adopt its Net-Zero-Framework. Here are her key points prior to the meeting.
At the upcoming extraordinary MEPC session, the IMO is set to adopt the first global regime regulating GHG intensity in shipping. The message to the industry is clear: emissions performance is no longer optional. It will define compliance costs, competitiveness, and market access.
Next week´s adoption is only the start. The amendments would enter into force in early 2027, with the first reporting period starting in 2028. But the real impact will be decided by the detailed implementing guidelines due between 2025 and 2027 - from the IMO LCA Guidelines to the rules on how ships can prove the use of low- or zero-carbon fuels. Key among these is the debate on “chain of custody” models, such as mass balance and book-and-claim.
Beyond the MARPOL amendments, MSs are developing a package of around ten implementing guidelines in ISWG-GHG/MEPC (Intersessional Working Group on Greenhouse Gases) to be finalised between 2025-2027. These guidelines covering topics such as, among others:
For example, the 2024 IMO LCA Guidelines, adopted at MEPC 81, set the baseline methodology for life-cycle (well-to-wake) GHG emission factors. They remain under development: only three of 128 fuel pathways currently have full values, and further revisions at MEPC 84 (2026) and MEPC 87 (2028) are expected to expand coverage of alternative fuels and refine rules on default values, sustainability and certification.
.....One particular issue relates to LNG and its life-cycle emissions.
For LNG-fuelled ships, the key metric is the well-to-tank (WTT) default emission factor. In the recent submissions, Norway has proposed (MEPC 84/7/1) 17.4 g CO2-eq/MJ, but other submissions (MEPC 83/7/28) argue for higher defaults such as 27.95 g CO2-eq/MJ. The final figure will strongly influence how “green” LNG looks on paper.
These guidelines will determine the real cost and feasibility of compliance.
How can ships credibly prove the use of low- or zero-GHG fuels? Two main models are under discussion:
Mass balance: Alternative and fossil fuels can be blended in the same pipeline, but the “green” share is tracked administratively so that only the certified amount is claimed downstream.
Book-and-claim: The physical fuel and the environmental certificate are separated. A ship can buy a certificate from a producer of alternative fuel and claim the GHG reduction even if the green fuel is consumed elsewhere.
Submissions highlight that these models could speed up the uptake of alternative fuels, because they allow ships in ports without alternative fuel to still claim verified reductions.
At the same time, several points call for particular caution:
How IMO resolves this question will shape both the credibility of the NZF and the cost and pace of scaling up alternative fuels.
At entry into force the framework will apply only to ships ≥5,000 GT on international voyages. Ships between 400–5,000 GT remain outside the mandatory regime at least until the first scheduled review, expected around 2032.
However, MSs could allow voluntary opt-in. For example, proposals from ZESTAs suggest that smaller ships opting in could:
This opens access to IMO funds for zero- and near-zero-carbon fuels and infrastructure, while avoiding the need for separate national credit systems.
Adoption in October signals certainty but does not settle the real costs. Between 2025–2027, IMO’s detailed LCA, default factors, and chain of custody rules will define compliance costs and competitiveness. Companies that prepare now, by understanding their fuel pathways and emissions, will be best positioned to reduce both emissions and regulatory exposure.
