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MEPC 84: A Reset, Not a Reversal

The IMO's 84th Marine Environment Protection Committee could not finalise the Net-Zero Framework, but the substance of the week was the opposite of the headline. A clear majority of member states returned to the NZF as the basis for further negotiation, reversing the adjournment that derailed MEPC.ES2 in October 2025.
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MEPC 84: A Reset, Not a Reversal

The IMO's 84th Marine Environment Protection Committee could not finalise the Net-Zero Framework, but the substance of the week was the opposite of the headline. A clear majority of member states returned to the NZF as the basis for further negotiation, reversing the adjournment that derailed MEPC.ES2 in October 2025.

Alternative proposals from Japan, Liberia, Panama and Argentina did not displace it, but made an impression that there is room for adjustment within the current framework. Alongside the NZF debate, MEPC 84 delivered the world's largest Emission Control Area, a foundational methane and nitrous oxide measurement package, and meaningful progress on the technical infrastructure the future compliance system will sit on.

1. Introduction

The IMO Net-Zero Framework remains politically difficult. That was visible all week. But the more important shift is that most member states still see the need for a global framework, and the debate is no longer about whether shipping should decarbonise. It has moved to how the burden, the timing and the flexibility should be structured.

Without a global measure, the alternative is regional fragmentation. Different schemes, different compliance costs, different reporting systems and a less predictable investment environment. That is why the message from Cyprus, holding the EU presidency, on the need for a level playing field carried weight.

2. The numbers behind the reset

The most important data point of the week was the swing in member state positions on the NZF.

MEPC 84 member state position on the NZF

5 countries that backed adjournment at MEPC.ES2 flipped back to supporting the NZF. 10 countries that abstained or did not take a position at MEPC.ES2 now clearly support it. Only 2 countries flipped the other way, from opposing adjournment to opposing the NZF. A similar number of countries that had a clear position at MEPC.ES2 (14 supporting adjournment, 11 opposing) chose not to register a position at this meeting.

That fluidity is real, and it is a reason not to treat MEPC 85 as a foregone conclusion. But the direction of travel is clear. Alternative proposals tested the room and did not displace the NZF as the central negotiating platform.

MEPC Member State positions on Net Zero Framework

3. How the week unfolded

Monday and Tuesday: context, then technical groundwork

The week opened with delegations raising seafarer safety and the operational impact of geopolitical disruptions on shipping. That was important context. The Red Sea situation and the rerouting via the Cape of Good Hope have measurably increased fuel consumption and emissions for many ships. Same cargo, same vessels, longer voyages. Industry reporting points to a 5.7% rise in global fleet fuel consumption in 2024, much of it driven by these added 7,000 to 8,000 nautical miles per voyage on affected routes.

This exposed a real weakness in the current CII framework. A ship can look less efficient on paper while the underlying operation has simply been forced onto a longer route for safety reasons. MEPC 84 therefore took up data granularity, "underway" versus "not underway" reporting, and whether future CII adjustments should better reflect weather, routing and operational realities.

Two interventions were notable.

  • Cook Islands raised concerns around correction factors for weather-related fuel consumption.
  • Saudi Arabia raised concerns about default emission factors, the scientific basis behind them, and the case for allowing custom well-to-wake factors for all fuel pathways.

These are not minor technical points. They go directly to the credibility of any future GHG Fuel Intensity (GFI) system.

In parallel, the GHG reduction working group, chaired by Norway, focused on the 5th IMO GHG Study: its scope, its timeline, the question of international versus domestic shipping coverage, and whether regional analysis should be included. This study will be the next major evidence base for international shipping emissions and projections, and future policy debates will increasingly depend on it.

Industry contributions added useful detail. A Brazilian company, "Marsalgado Brasil", demonstrated a fuel data tracing system, a relevant proof point as fuel certification and chain-of-custody rules become central to compliance. KCC Norway presented on why blanket measures like CII do not always fit specific operational profiles such as combination carriers, a useful reminder that decarbonisation regulation must be both ambitious and operationally workable.

Wednesday: NZF in the Main Hall

By Wednesday, the NZF discussion moved into the Main Hall. The atmosphere was more diplomatic than confrontational, but the division was clear. Broadly, four groupings emerged.

  1. Delegations supporting the NZF as agreed in principle, open to limited refinements.
  2. Delegations supporting alternative proposals, particularly those linking ambition to fuel market readiness.
  3. Delegations not rejecting the objective but calling for further impact assessment before adoption.

Delegations not taking a clear position.

Thursday and Friday: political sharpness, procedural conclusion

The week sharpened politically on Thursday with the Strait of Hormuz item, where a chair-approved resolution was carried in a vote of 59 in favour to 3 against. The NZF discussion itself was confirmed to push to the next session, with the question of an extraordinary session and the negotiating basis for it deferred to subsequent decisions.

4. The Japan and Panama proposals, and why neither displaced the NZF

Two main alternative pathways were tabled. Both helped frame the debate. Neither carried the room.

Japan's proposal

Japan moved away from the perceived "global carbon tax" character of the existing framework. It proposed:

  • Removing remedial units and the IMO Fund.
  • Requiring non-compliant ships to acquire surplus units (SU) from over-achievers, with alternative measures (such as donations to maritime industry projects) where SUs are insufficient in the market.
  • Revising the base and direct compliance targets.
  • Scientifically reassessing fuels, including LNG, so that actual emission factors can be established for fossil fuels rather than relying solely on default values.
Panama's proposal

Panama linked the GFI trajectory to the demonstrated market uptake of alternative fuels. A fuel would qualify as "commercially viable" only if it met defined thresholds.

Panama's proposal

In other words, ambition would adjust to what the fuel market actually delivers. That addresses a real industry concern. But it does so at the cost of softening the regulatory pull-through that drives that very market.

Why neither displaced the NZF

Both proposals reframe the level of ambition. Both would have softened or restructured the economic backbone of the framework. The room considered them and moved on. The signal is that alternatives may influence refinements, but the original NZF architecture remains the main negotiating platform.

5. The five pressures that slowed the NZF

The delay was not the result of one issue. Five pressures came together.

  • Disagreement on the economic element. The IMO Net-Zero Fund and the pricing or remedial unit structure remain politically sensitive. Some member states see the fund as essential to make the transition investable and equitable. Others read it as a carbon tax or an additional cost on trade.
  • Concern over fuel availability and affordability. The Panama-style market readiness logic addresses a genuine concern. Regulation should not assume that fuels are available everywhere, at scale, and at manageable cost before the market has built them. The counter argument, that regulatory pull is what builds the market in the first place, is also genuine.
  • Lifecycle emissions and default factors. Questions on LNG, methane slip, fossil fuel pathways, biofuels, upstream emissions and actual versus default values were running in the background all week. This is why the LCA work, the methane measurement guidelines and the fuel certification discussions are so consequential.
  • Geopolitical pressure. The events of MEPC.ES2 in October 2025 were still fresh. Several delegations came into MEPC 84 wanting either a more flexible framework or a different architecture altogether.
  • Industry pressure. Some shipowners and flag states remain concerned about cost, competitiveness, fuel uncertainty and stranded asset risk. These concerns are legitimate. They are an argument for a better, more practical transition. They are not an argument for inaction.

6. The other MEPC 84 outcomes, easy to miss, hard to overstate

The NZF took most of the attention, but the rest of the agenda was substantive.

North-East Atlantic Emission Control Area, adopted

The NE Atlantic ECA covers the EEZs of France, Ireland, Portugal, Spain, the UK, Iceland, Greenland and the Faroe Islands. A region home to over 190 million people. It links the existing Baltic, North Sea and Mediterranean ECAs with the recently approved Norwegian Sea and Canadian Arctic ECAs, creating an almost continuous pollution control zone across the Atlantic and the Arctic.

Projected impact under a likely compliance scenario:

Projected impact under a likely compliance scenario


Implementation begins in September 2028, with stricter NOx engine limits applying to ships built from 1 January 2027. The submission was led by 27 EU member states, Iceland, the United Kingdom and the European Commission, with technical support from ICCT and Porto University.

Methane and N₂O measurement guidelines, adopted (MEPC.414, .415 and .416)

This may be the most operationally important technical outcome of the week. For LNG and dual-fuel ships, methane slip stops being a theoretical discussion. These resolutions create the official measurement architecture on which the future GFI / NZF compliance system will sit. The numbers will feed directly into future GFI intensity calculations.

Lifecycle assessment (LCA) framework, continued progress

Default emission factors, chain-of-custody models, sustainable fuel certification, and the treatment of technologies such as onboard carbon capture all advanced. Future compliance will depend on the industry's ability to prove fuel origin, production pathway and well-to-wake emissions.

5th IMO GHG Study, terms of reference agreed

The next major evidence base for international shipping emissions, projections and future policy review.

CII and SEEMP, phase 2 of the short-term measure review

MEPC 84 began the second phase of the review of short-term GHG measures, with a strong focus on strengthening SEEMP, improving operational energy efficiency, and considering whether the CII framework needs better alignment with real operational conditions, including weather and forced rerouting. It was noted, however, that at least one of the short-term measures needs to be anchored before the others can move forward efficiently.

Other technical items

Ballast Water Management amendments, NOx Technical Code amendments for non-carbon fuels, onboard carbon capture work, VOC measures, and marine plastic litter all progressed. Polar fuels, the global 0.5% sulphur limit and discharge from EGCS were moved into further evaluation, with potential conclusions in this session.

7. The road to adoption: timeline and political windows

The path from MEPC 84 to a likely adoption decision is now visible.

The sequencing of MEPC 85 and the ES.2 resumption after the US midterms is deliberate, and it gives the framework a politically meaningful runway. If the NZF is adopted at MEPC 85 or the ES.2 resumption, operators will have roughly 15 months before mandatory compliance begins. Newbuilds ordered today will trade under this framework for 25 years.

8. The strategic case for acting now

The biggest mistake now would be to wait for perfect certainty.

The exact regulatory text may change. The economic element may be adjusted. The GFI trajectory may be refined. But the direction is settled. Shipping compliance is moving toward lifecycle GHG intensity, fuel traceability, operational data quality and carbon cost exposure. Companies that begin work now can still shape their options. Specifically, they can:

  • Run GFI gap analyses across the fleet under plausible NZF and adjusted NZF scenarios.
  • Identify the vessels most exposed to remedial unit or surplus unit costs, and model the cost ranges.
  • Review LNG and dual-fuel assets for methane slip exposure under the new measurement guidelines.
  • Improve CII and SEEMP performance before enforcement tightens, including using the new underway and non-underway reporting to recover misread efficiency profiles distorted by 2024 rerouting.
  • Build fuel procurement, certification and chain-of-custody readiness so that future GFI claims hold up under scrutiny.
  • Embed decarbonisation clauses in chartering, newbuilding and retrofit decisions.
  • Prepare customers and financiers for the cost and the opportunity of the transition.

This is not abstract preparation. Operators that use this 18-month pre-adoption window will not just comply earlier. They will make better investment decisions, manage risk more effectively, and build credibility with cargo owners, financiers and regulators.

9. The bottom line

MEPC 84 was not the end of the Net-Zero Framework. It was the start of a more serious negotiation.

The NZF was not adopted. The conversation moved forward. Alternative proposals were tested. Technical infrastructure advanced. The majority of the debate still pointed toward convergence, not collapse.

IMO negotiations can be slow. The energy transition in shipping is not.

The window is open. It will not stay open forever.

MEPC 84: A Reset, Not a Reversal

The IMO's 84th Marine Environment Protection Committee could not finalise the Net-Zero Framework, but the substance of the week was the opposite of the headline. A clear majority of member states returned to the NZF as the basis for further negotiation, reversing the adjournment that derailed MEPC.ES2 in October 2025.

Alternative proposals from Japan, Liberia, Panama and Argentina did not displace it, but made an impression that there is room for adjustment within the current framework. Alongside the NZF debate, MEPC 84 delivered the world's largest Emission Control Area, a foundational methane and nitrous oxide measurement package, and meaningful progress on the technical infrastructure the future compliance system will sit on.

1. Introduction

The IMO Net-Zero Framework remains politically difficult. That was visible all week. But the more important shift is that most member states still see the need for a global framework, and the debate is no longer about whether shipping should decarbonise. It has moved to how the burden, the timing and the flexibility should be structured.

Without a global measure, the alternative is regional fragmentation. Different schemes, different compliance costs, different reporting systems and a less predictable investment environment. That is why the message from Cyprus, holding the EU presidency, on the need for a level playing field carried weight.

2. The numbers behind the reset

The most important data point of the week was the swing in member state positions on the NZF.

MEPC 84 member state position on the NZF

5 countries that backed adjournment at MEPC.ES2 flipped back to supporting the NZF. 10 countries that abstained or did not take a position at MEPC.ES2 now clearly support it. Only 2 countries flipped the other way, from opposing adjournment to opposing the NZF. A similar number of countries that had a clear position at MEPC.ES2 (14 supporting adjournment, 11 opposing) chose not to register a position at this meeting.

That fluidity is real, and it is a reason not to treat MEPC 85 as a foregone conclusion. But the direction of travel is clear. Alternative proposals tested the room and did not displace the NZF as the central negotiating platform.

MEPC Member State positions on Net Zero Framework

3. How the week unfolded

Monday and Tuesday: context, then technical groundwork

The week opened with delegations raising seafarer safety and the operational impact of geopolitical disruptions on shipping. That was important context. The Red Sea situation and the rerouting via the Cape of Good Hope have measurably increased fuel consumption and emissions for many ships. Same cargo, same vessels, longer voyages. Industry reporting points to a 5.7% rise in global fleet fuel consumption in 2024, much of it driven by these added 7,000 to 8,000 nautical miles per voyage on affected routes.

This exposed a real weakness in the current CII framework. A ship can look less efficient on paper while the underlying operation has simply been forced onto a longer route for safety reasons. MEPC 84 therefore took up data granularity, "underway" versus "not underway" reporting, and whether future CII adjustments should better reflect weather, routing and operational realities.

Two interventions were notable.

  • Cook Islands raised concerns around correction factors for weather-related fuel consumption.
  • Saudi Arabia raised concerns about default emission factors, the scientific basis behind them, and the case for allowing custom well-to-wake factors for all fuel pathways.

These are not minor technical points. They go directly to the credibility of any future GHG Fuel Intensity (GFI) system.

In parallel, the GHG reduction working group, chaired by Norway, focused on the 5th IMO GHG Study: its scope, its timeline, the question of international versus domestic shipping coverage, and whether regional analysis should be included. This study will be the next major evidence base for international shipping emissions and projections, and future policy debates will increasingly depend on it.

Industry contributions added useful detail. A Brazilian company, "Marsalgado Brasil", demonstrated a fuel data tracing system, a relevant proof point as fuel certification and chain-of-custody rules become central to compliance. KCC Norway presented on why blanket measures like CII do not always fit specific operational profiles such as combination carriers, a useful reminder that decarbonisation regulation must be both ambitious and operationally workable.

Wednesday: NZF in the Main Hall

By Wednesday, the NZF discussion moved into the Main Hall. The atmosphere was more diplomatic than confrontational, but the division was clear. Broadly, four groupings emerged.

  1. Delegations supporting the NZF as agreed in principle, open to limited refinements.
  2. Delegations supporting alternative proposals, particularly those linking ambition to fuel market readiness.
  3. Delegations not rejecting the objective but calling for further impact assessment before adoption.

Delegations not taking a clear position.

Thursday and Friday: political sharpness, procedural conclusion

The week sharpened politically on Thursday with the Strait of Hormuz item, where a chair-approved resolution was carried in a vote of 59 in favour to 3 against. The NZF discussion itself was confirmed to push to the next session, with the question of an extraordinary session and the negotiating basis for it deferred to subsequent decisions.

4. The Japan and Panama proposals, and why neither displaced the NZF

Two main alternative pathways were tabled. Both helped frame the debate. Neither carried the room.

Japan's proposal

Japan moved away from the perceived "global carbon tax" character of the existing framework. It proposed:

  • Removing remedial units and the IMO Fund.
  • Requiring non-compliant ships to acquire surplus units (SU) from over-achievers, with alternative measures (such as donations to maritime industry projects) where SUs are insufficient in the market.
  • Revising the base and direct compliance targets.
  • Scientifically reassessing fuels, including LNG, so that actual emission factors can be established for fossil fuels rather than relying solely on default values.
Panama's proposal

Panama linked the GFI trajectory to the demonstrated market uptake of alternative fuels. A fuel would qualify as "commercially viable" only if it met defined thresholds.

Panama's proposal

In other words, ambition would adjust to what the fuel market actually delivers. That addresses a real industry concern. But it does so at the cost of softening the regulatory pull-through that drives that very market.

Why neither displaced the NZF

Both proposals reframe the level of ambition. Both would have softened or restructured the economic backbone of the framework. The room considered them and moved on. The signal is that alternatives may influence refinements, but the original NZF architecture remains the main negotiating platform.

5. The five pressures that slowed the NZF

The delay was not the result of one issue. Five pressures came together.

  • Disagreement on the economic element. The IMO Net-Zero Fund and the pricing or remedial unit structure remain politically sensitive. Some member states see the fund as essential to make the transition investable and equitable. Others read it as a carbon tax or an additional cost on trade.
  • Concern over fuel availability and affordability. The Panama-style market readiness logic addresses a genuine concern. Regulation should not assume that fuels are available everywhere, at scale, and at manageable cost before the market has built them. The counter argument, that regulatory pull is what builds the market in the first place, is also genuine.
  • Lifecycle emissions and default factors. Questions on LNG, methane slip, fossil fuel pathways, biofuels, upstream emissions and actual versus default values were running in the background all week. This is why the LCA work, the methane measurement guidelines and the fuel certification discussions are so consequential.
  • Geopolitical pressure. The events of MEPC.ES2 in October 2025 were still fresh. Several delegations came into MEPC 84 wanting either a more flexible framework or a different architecture altogether.
  • Industry pressure. Some shipowners and flag states remain concerned about cost, competitiveness, fuel uncertainty and stranded asset risk. These concerns are legitimate. They are an argument for a better, more practical transition. They are not an argument for inaction.

6. The other MEPC 84 outcomes, easy to miss, hard to overstate

The NZF took most of the attention, but the rest of the agenda was substantive.

North-East Atlantic Emission Control Area, adopted

The NE Atlantic ECA covers the EEZs of France, Ireland, Portugal, Spain, the UK, Iceland, Greenland and the Faroe Islands. A region home to over 190 million people. It links the existing Baltic, North Sea and Mediterranean ECAs with the recently approved Norwegian Sea and Canadian Arctic ECAs, creating an almost continuous pollution control zone across the Atlantic and the Arctic.

Projected impact under a likely compliance scenario:

Projected impact under a likely compliance scenario


Implementation begins in September 2028, with stricter NOx engine limits applying to ships built from 1 January 2027. The submission was led by 27 EU member states, Iceland, the United Kingdom and the European Commission, with technical support from ICCT and Porto University.

Methane and N₂O measurement guidelines, adopted (MEPC.414, .415 and .416)

This may be the most operationally important technical outcome of the week. For LNG and dual-fuel ships, methane slip stops being a theoretical discussion. These resolutions create the official measurement architecture on which the future GFI / NZF compliance system will sit. The numbers will feed directly into future GFI intensity calculations.

Lifecycle assessment (LCA) framework, continued progress

Default emission factors, chain-of-custody models, sustainable fuel certification, and the treatment of technologies such as onboard carbon capture all advanced. Future compliance will depend on the industry's ability to prove fuel origin, production pathway and well-to-wake emissions.

5th IMO GHG Study, terms of reference agreed

The next major evidence base for international shipping emissions, projections and future policy review.

CII and SEEMP, phase 2 of the short-term measure review

MEPC 84 began the second phase of the review of short-term GHG measures, with a strong focus on strengthening SEEMP, improving operational energy efficiency, and considering whether the CII framework needs better alignment with real operational conditions, including weather and forced rerouting. It was noted, however, that at least one of the short-term measures needs to be anchored before the others can move forward efficiently.

Other technical items

Ballast Water Management amendments, NOx Technical Code amendments for non-carbon fuels, onboard carbon capture work, VOC measures, and marine plastic litter all progressed. Polar fuels, the global 0.5% sulphur limit and discharge from EGCS were moved into further evaluation, with potential conclusions in this session.

7. The road to adoption: timeline and political windows

The path from MEPC 84 to a likely adoption decision is now visible.

The sequencing of MEPC 85 and the ES.2 resumption after the US midterms is deliberate, and it gives the framework a politically meaningful runway. If the NZF is adopted at MEPC 85 or the ES.2 resumption, operators will have roughly 15 months before mandatory compliance begins. Newbuilds ordered today will trade under this framework for 25 years.

8. The strategic case for acting now

The biggest mistake now would be to wait for perfect certainty.

The exact regulatory text may change. The economic element may be adjusted. The GFI trajectory may be refined. But the direction is settled. Shipping compliance is moving toward lifecycle GHG intensity, fuel traceability, operational data quality and carbon cost exposure. Companies that begin work now can still shape their options. Specifically, they can:

  • Run GFI gap analyses across the fleet under plausible NZF and adjusted NZF scenarios.
  • Identify the vessels most exposed to remedial unit or surplus unit costs, and model the cost ranges.
  • Review LNG and dual-fuel assets for methane slip exposure under the new measurement guidelines.
  • Improve CII and SEEMP performance before enforcement tightens, including using the new underway and non-underway reporting to recover misread efficiency profiles distorted by 2024 rerouting.
  • Build fuel procurement, certification and chain-of-custody readiness so that future GFI claims hold up under scrutiny.
  • Embed decarbonisation clauses in chartering, newbuilding and retrofit decisions.
  • Prepare customers and financiers for the cost and the opportunity of the transition.

This is not abstract preparation. Operators that use this 18-month pre-adoption window will not just comply earlier. They will make better investment decisions, manage risk more effectively, and build credibility with cargo owners, financiers and regulators.

9. The bottom line

MEPC 84 was not the end of the Net-Zero Framework. It was the start of a more serious negotiation.

The NZF was not adopted. The conversation moved forward. Alternative proposals were tested. Technical infrastructure advanced. The majority of the debate still pointed toward convergence, not collapse.

IMO negotiations can be slow. The energy transition in shipping is not.

The window is open. It will not stay open forever.