IMO 2030/2050: International Maritime Organization Decarbonization Rules

Executive Summary

The International Maritime Organization (IMO) adopted a revised GHG Strategy at MEPC 80 (July 2023) with net-zero GHG emissions from international shipping by or around, i.e. close to 2050. (Source) The 2030 checkpoint requires at least 20% reduction in GHG emissions (striving for 30%) compared to 2008, with a 2040 checkpoint of at least 70% reduction (striving for 80%) compared to 2008. (Source) (Source)

Short-term measures (EEXI and CII) entered into force on 1 January 2023, applying to ships ≥400 GT. (Source) Mid-term measures—comprising a technical fuel GHG intensity standard and economic pricing mechanism—were approved at MEPC 83 (April 2025) for adoption in Autumn 2025, with entry into force around 2027 and first compliance year 2028. (Source)

Download Full IMO 2030/2050 Compliance Guide (PDF)

What You'll Learn

IMO GHG Strategy Evolution: From 2018 Initial to 2023 Revised

Initial Strategy (2018): 50% Reduction by 2050, 40% Carbon Intensity by 2030

The IMO adopted its Initial GHG Strategy in April 2018 at the 72nd session of the Marine Environment Protection Committee (MEPC 72). The 2050 target set an ambition of at least 50% reduction in total annual GHG emissions by 2050 compared to 2008. (Source) The carbon intensity target required at least 40% reduction by 2030, pursuing efforts towards 70% by 2050, compared to 2008. (Source)

The 2018 strategy represented a significant political achievement—the first global sector agreement to commit to absolute emissions reductions—but fell short of the Paris Agreement's 1.5-2°C temperature target alignment. Shipping's 50% reduction by 2050 was inconsistent with the Intergovernmental Panel on Climate Change (IPCC) recommendation that global emissions reach net-zero by 2050 to limit warming to 1.5°C. Critics argued the 2018 targets would allow international shipping's share of global emissions to grow from ~3% (2018) to potentially 10-15% by 2050 as land-based sectors decarbonized faster.

Revised Strategy (MEPC 80, July 2023): Net-Zero by or Around 2050, With 2030/2040 Checkpoints

Following intensive negotiations over 18 months, MEPC 80 (3-7 July 2023) adopted the 2023 IMO Strategy on Reduction of GHG Emissions from Ships. The net-zero goal commits to net-zero GHG emissions from international shipping by or around, i.e. close to 2050. (Source) This represents a dramatic tightening from the 2018 ambition of 50% reduction.

The 2030 checkpoint requires at least 20% reduction in GHG emissions (striving for 30%) compared to 2008. (Source) The 2040 checkpoint requires at least 70% reduction (striving for 80%) compared to 2008. (Source) These interim milestones enable course correction if progress is insufficient—a critical accountability mechanism absent from the 2018 strategy.

Well-to-Wake Emissions Now in Scope (Lifecycle Approach)

A fundamental shift in the 2023 strategy is the adoption of well-to-wake lifecycle GHG accounting. The 2018 strategy focused on tank-to-wake emissions (combustion onboard ships). The revised strategy now includes upstream emissions from fuel production, processing, and transportation (well-to-tank), plus onboard combustion (tank-to-wake), creating comprehensive well-to-wake accountability.

Guidelines on Life Cycle GHG Intensity of Marine Fuels were adopted at MEPC 80; methods for calculating well-to-wake and tank-to-wake GHG emissions; preliminary default emissions factors provided. (Source) This ensures that alternative fuels are assessed on full lifecycle impact—e.g., liquefied natural gas (LNG) has low tank-to-wake CO₂ but high methane slip and upstream production emissions; green ammonia (produced via renewable-powered electrolysis) has zero well-to-wake emissions; gray ammonia (produced from fossil gas) has significant upstream emissions.

The lifecycle approach prevents "emissions offshoring"—where shipping shifts GHG burdens upstream without achieving real decarbonization. It aligns maritime accounting with aviation (CORSIA lifecycle fuels), EU regulations (FuelEU Maritime well-to-wake), and scientific consensus that full lifecycle emissions must be addressed to meet climate targets.

Element 2018 Initial GHG Strategy 2023 Revised GHG Strategy (MEPC 80) Source
2050 Target At least 50% reduction in total annual GHG emissions by 2050 vs 2008 Net-zero GHG emissions by or around, i.e. close to 2050 2018 | 2023
2030 Target Carbon intensity: at least 40% reduction by 2030 vs 2008 (no absolute emissions target) Absolute emissions: at least 20% reduction (striving for 30%) vs 2008. Carbon intensity: 40% reduction (unchanged) Both
2040 Checkpoint Not specified At least 70% reduction (striving for 80%) in GHG emissions vs 2008 2023
Zero-Carbon Fuel Uptake Not specified At least 5%, striving for 10%, of energy used by international shipping from zero or near-zero GHG fuels by 2030 2023
Emissions Scope Tank-to-wake (combustion onboard) Well-to-wake (full lifecycle: production + combustion) 2023
Carbon Intensity (2050) Pursuing efforts towards 70% reduction by 2050 vs 2008 Not separately specified (subsumed by net-zero absolute target) 2018
Review Timeline Review in 2023 Next review: MEPC 86 (Summer 2027) initiates; MEPC 88 (Autumn 2028) finalizes 2028 Strategy 2023
Economic Measures Listed as candidate mid-term measure, not committed Committed: maritime GHG emissions pricing mechanism to be adopted 2025, entry into force ~2027 2023
Paris Agreement Alignment Insufficient (50% by 2050 incompatible with 1.5°C pathway) Improved (net-zero by 2050 aligns with IPCC 1.5°C scenarios, though some argue "close to 2050" still lags) Analysis
Strategic implication: The 2023 revised strategy transforms maritime decarbonization from a 2050 aspiration into a near-term operational and capital allocation challenge. Ship operators face compliance requirements starting 2023 (EEXI/CII), escalating significantly from 2027-2028 (mid-term measures), and culminating in near-total decarbonization by 2050. Fleet planning cycles (15-25 years for newbuilds) must now account for vessels operating in a net-zero regulatory environment for the majority of their economic life.

The 2030 and 2050 Targets (What Ships Must Achieve)

2030 Checkpoint: At Least 20% GHG Reduction (Striving for 30%) vs 2008

The 2030 checkpoint requires at least 20% reduction in GHG emissions (striving for 30%) compared to 2008. (Source) This is an absolute emissions target—total well-to-wake GHG emissions from international shipping must be 20-30% below 2008 levels by 2030, regardless of fleet growth or trade volumes.

International shipping emitted approximately 1,050 million tonnes CO₂-equivalent in 2008 (the baseline year). A 20% reduction requires total emissions ≤840 Mt CO₂e by 2030; a 30% reduction requires ≤735 Mt CO₂e. Given that shipping emissions grew from ~1,050 Mt (2008) to ~1,120 Mt (2018) before declining slightly during COVID-19 pandemic (2020-2021), achieving 20-30% reduction by 2030 requires reversing historical growth trends and implementing aggressive efficiency measures plus alternative fuel adoption across the global fleet.

2040 Checkpoint: At Least 70% Reduction (Striving for 80%) vs 2008

The 2040 checkpoint requires at least 70% reduction (striving for 80%) compared to 2008. (Source) This implies total emissions ≤315 Mt CO₂e (70% reduction) or ≤210 Mt CO₂e (80% reduction) by 2040—a near-complete transformation of the maritime fuel mix.

Achieving 70-80% reduction by 2040 is mathematically impossible with fossil fuels (even the most efficient LNG vessels emit ~30-40% less CO₂ than heavy fuel oil, insufficient for 70%+ reduction). This checkpoint effectively mandates large-scale deployment of zero or near-zero emission fuels (ammonia, hydrogen, advanced biofuels, synthetic e-fuels) and potentially carbon capture systems onboard ships or through offsets (though offsets are contentious and not explicitly endorsed in the strategy).

2050 Goal: Net-Zero GHG Emissions

Net-zero GHG emissions from international shipping by or around, i.e. close to 2050. (Source) "Net-zero" allows for residual emissions balanced by removals (e.g., bioenergy with carbon capture and storage, direct air capture, nature-based solutions), but the strategy emphasizes deep emissions reductions rather than reliance on offsets.

The qualifier "by or around, i.e. close to" provides some flexibility (potentially 2048-2052) but is intentionally narrow—this is not an open-ended "second half of century" goal. The 2050 net-zero target aligns with IPCC guidance for limiting global warming to 1.5°C, matching commitments from aviation (ICAO Long-Term Aspirational Goal of net-zero by 2050, adopted 2022) and major emitting countries (EU, US, Japan, Korea committed to economy-wide net-zero by 2050).

Carbon Intensity: 40% Reduction by 2030 vs 2008 (Unchanged from Initial Strategy)

Carbon intensity target: reduce CO2 emissions per transport work by at least 40% by 2030 compared to 2008. (Source) This target was retained from the 2018 strategy and is distinct from the absolute emissions targets.

Carbon intensity measures emissions per unit of transport work (tonne-nautical miles)—essentially, emissions per tonne of cargo moved one nautical mile. Improvements can be achieved through:

The 40% carbon intensity reduction by 2030 is more achievable than the 20-30% absolute reduction, because transport work can grow even as emissions per tonne-mile decline. However, if trade growth is strong (e.g., 3-4%/year), carbon intensity improvements alone will not achieve absolute emissions reduction—alternative fuels become necessary.

Zero/Near-Zero Fuel Uptake: 5% (Striving for 10%) of Energy by 2030

At least 5%, striving for 10%, of energy used by international shipping from zero or near-zero GHG emission technologies/fuels by 2030. (Source) This is a transformative target—as of 2023, zero-emission fuels account for <0.1% of maritime energy use (almost entirely pilot projects and first-mover vessels).

5-10% uptake by 2030 implies ~15-30 million tonnes of ammonia, methanol, or hydrogen consumed annually by shipping (assuming total maritime energy demand ~300 million tonnes oil-equivalent). This requires:

The "zero or near-zero" qualifier acknowledges that some alternative fuels may have small residual emissions (e.g., blue ammonia with carbon capture achieving 90-95% GHG reduction vs gray ammonia; biofuels with <10 gCO₂e/MJ well-to-wake). The IMO will define thresholds via the mid-term measures lifecycle GHG intensity framework.

2030 Absolute Reduction
20-30%
vs 2008 baseline. Source
2040 Checkpoint
70-80%
Reduction vs 2008. Source
2050 Goal
Net-Zero
By or around 2050. Source
Zero-Fuel Uptake (2030)
5-10%
Of energy from zero/near-zero fuels. Source

IMO GHG Reduction Pathway: 2008-2050 (% vs 2008 Baseline)

Based on 2023 Revised IMO GHG Strategy targets. Source

Short-term Measures (In Force Since 1 January 2023): EEXI and CII

EEXI (Energy Efficiency Existing Ship Index): One-Time Certification

EEXI (Energy Efficiency Existing Ship Index): One-time certification; compares ship's attained energy efficiency to required EEXI baseline (reduction factor relative to EEDI baseline); applies to ships ≥400 GT. (Source)

EEXI is a design-based metric that entered into force on 1 January 2023 under amendments to MARPOL Annex VI. It applies to existing ships (built before 1 January 2013, when the Energy Efficiency Design Index—EEDI—became mandatory for newbuilds). EEXI establishes minimum energy efficiency standards for the global fleet, effectively extending EEDI-equivalent requirements to older vessels.

How EEXI Works

EEXI compares a ship's attained EEXI (calculated based on the ship's current technical specifications: installed power, fuel consumption, cargo capacity, design speed) against a required EEXI value. The required EEXI is derived from the EEDI baseline for the ship's type and size, with reduction factors applied:

  • Reference line: Each ship type (container, bulk carrier, tanker, gas carrier, etc.) has a baseline EEDI reference line established by statistical analysis of ships built 1999-2009.
  • Reduction factor: The required EEXI applies a reduction factor to the reference line—typically 20-30% below baseline, depending on ship type and size. For example, large container ships (≥15,000 TEU) must achieve 50% reduction vs reference line; smaller vessels have less stringent factors (e.g., 20% for general cargo ships 3,000-15,000 DWT).
  • Attained EEXI calculation: Ship's attained EEXI = (Main engine power × Fuel consumption factor) / (Capacity × Speed factor). Lower EEXI values indicate higher efficiency (less fuel per tonne-mile).

If a ship's attained EEXI exceeds the required EEXI (i.e., the ship is less efficient than required), the ship must implement technical or operational improvements to comply. Common compliance measures:

  • Engine power limitation (EPL): Reduce maximum continuous rating (MCR) of main engine via engine modifications or electronic governors, limiting top speed. This is the most common EEXI compliance method—over 60% of ships requiring action used EPL (2023 data from classification societies).
  • Energy efficiency technologies: Install waste heat recovery systems, air lubrication, wind-assisted propulsion (rotor sails, wing sails), or shaft generators to reduce fuel consumption.
  • Alternative fuels: Conversion to LNG, methanol, or dual-fuel capability (though capital-intensive for EEXI compliance alone).

EEXI Certification and Enforcement

EEXI is a one-time certification. Ships must obtain EEXI certification at the first annual, intermediate, or renewal survey on or after 1 January 2023. Once certified, EEXI does not change unless major modifications are made to the ship (engine replacement, hull modifications). The International Energy Efficiency Certificate (IEEC) documents EEXI compliance and must be carried onboard; port state control inspections can verify compliance.

CII (Carbon Intensity Indicator): Annual Operational Rating

CII (Carbon Intensity Indicator): Annual operational rating (A/B/C/D/E based on carbon intensity); links GHG emissions to cargo carried over distance; applies to ships ≥400 GT. (Source)

Unlike EEXI (design-based, one-time), CII is an operational metric calculated annually based on actual fuel consumption and transport work. CII entered into force 1 January 2023 and assigns each ship a rating (A, B, C, D, or E) based on its carbon intensity performance relative to a declining reference line.

How CII Works

CII measures annual carbon emissions per unit of transport work:

  • CII formula: CII = (Annual CO₂ emissions in tonnes) / (Transport work in tonne-nautical miles). For cargo ships, transport work = deadweight × distance sailed. For passenger ships, gross tonnage is used instead of deadweight.
  • Required CII: Each ship type has a required CII reference line (gCO₂/tonne-nm), calibrated to 2019 average performance for that ship type and size. The required CII becomes more stringent each year (2%-3% reduction per year through 2026; reduction factors for 2027-2030 to be finalized at MEPC 83 in 2025).
  • Rating bands: Ships are rated A (best 20%, significantly better than required CII), B (next 20%, better than required), C (middle 40%, meeting required CII), D (next 10%, below required), or E (worst 10%, significantly below required).

CII Enforcement: Corrective Action Plans

Ships rated D for three consecutive years or E for one year must submit a corrective action plan. (Source) The corrective action plan must be developed as part of the Ship Energy Efficiency Management Plan (SEEMP Part III) and approved by the ship's flag state administration. The plan must identify:

  • Root causes of poor CII performance (inefficient operations, aging machinery, suboptimal routing, cargo imbalance, excessive auxiliary power consumption)
  • Specific measures to improve CII (slow steaming, hull cleaning, propeller polishing, engine tuning, voyage optimization, wind-assisted propulsion, fuel switching)
  • Timeline for implementation and expected CII improvement

While corrective action plans are mandatory for D/E-rated ships, there is currently no direct IMO penalty for failing to improve CII. However, market-based enforcement is emerging: charterers (especially oil majors, grain traders, container lines) are increasingly including CII performance in vessel selection criteria, with some refusing to charter D/E-rated vessels. Banks and insurers are also beginning to link financing terms and insurance premiums to CII ratings.

CII Review and Future Adjustments

CII review timeline: Data gathering until MEPC 82 (Autumn 2024); analysis and amendments finalized by MEPC 83 (Summer 2025); CII reduction requirements 2026–2030 aligned with revised strategy. (Source)

The IMO is reviewing CII based on 2023-2024 performance data to assess whether the current reference lines and reduction factors are delivering the required fleet-wide improvements. Industry concerns being evaluated include:

  • Ship type disparities: Some ship types (e.g., pure car carriers, ro-ro vessels) have struggled to achieve good CII ratings due to low cargo utilization on return voyages (ballast legs).
  • Voyage profile variations: Ships on short-sea routes (frequent port calls, low average speed) have worse CII than similar ships on long-haul routes, even with identical fuel efficiency.
  • Alternative fuel adjustment factors: Ships using LNG receive a correction factor (LNG has lower CO₂ per MJ than fuel oil), but correction factors for methanol, ammonia, and biofuels are still being refined.

Expected outcomes from MEPC 83 (2025): (1) Adjusted CII reference lines for specific ship types with structural disadvantages, (2) Steeper reduction trajectory for 2027-2030 to align with 2030 checkpoint (20-30% reduction vs 2008), (3) Finalized well-to-wake CII calculation methodology incorporating lifecycle GHG factors for alternative fuels.

Element EEXI (Energy Efficiency Existing Ship Index) CII (Carbon Intensity Indicator) Source
What It Measures Design efficiency (technical capability): energy efficiency at design speed and load Operational efficiency: actual carbon emissions per tonne-nautical mile traveled annually Both
Frequency One-time certification (at first survey on/after 1 Jan 2023); does not change unless ship modified Annual calculation and rating based on actual operational data from previous calendar year Both
Applicability Ships ≥400 GT built before 1 January 2013 (existing ships not covered by EEDI) Ships ≥5,000 GT engaged in international voyages (broader scope than EEXI) Both
Compliance Method Must meet required EEXI value via technical measures (engine power limitation, efficiency technologies, fuel switching) Achieve rating of C or better; if D (3 consecutive years) or E (1 year), must submit corrective action plan CII
Rating/Certification Pass/fail (attained EEXI must be ≤ required EEXI); documented in International Energy Efficiency Certificate (IEEC) Letter rating A/B/C/D/E; documented in Statement of Compliance issued annually by flag state or recognized organization Both
Data Source Ship's technical specifications (engine power, design speed, deadweight, fuel type) Actual fuel consumption data from IMO Data Collection System (DCS) + distance traveled + cargo carried Regulatory
Penalty for Non-Compliance Cannot operate without valid IEEC; port state control can detain non-compliant ships Must submit corrective action plan (D/E ratings); no direct IMO penalty yet, but market penalties emerging (charter refusals, higher insurance) CII
Influence on Operations Limited operational impact after compliance (if EPL used, reduces max speed but does not affect normal operations) Significant operational impact: incentivizes slow steaming, optimized routing, reduced port time, higher cargo utilization Operational
Review/Adjustment Timeline Static (no planned adjustments; locked to ship's design unless modified) Dynamic: required CII becomes more stringent annually; MEPC 83 (2025) finalizing 2027-2030 reduction trajectory CII
Strategic Purpose Establish minimum efficiency floor for existing fleet (eliminate worst-performing ships/configurations) Drive continuous operational improvement and create transparency for charterers/investors on ship performance Strategic
Practical takeaway: EEXI is a one-time hurdle (most ships complied via engine power limitation in 2023). CII is the ongoing operational challenge—ship operators must continuously optimize operations to maintain C or better rating as required CII tightens annually. CII is driving behavioral change: widespread adoption of slow steaming (10-12 knots vs historical 14-16 knots for container ships), weather routing optimization, hull cleaning frequency increases, and just-in-time arrival coordination with ports to reduce idle time.

Mid-term Measures (IMO Net-Zero Framework): Adoption 2025, Entry Into Force 2027

Two-Part Framework: Technical Element + Economic Element

Two-part framework: (a) Technical element: goal-based marine fuel GHG intensity standard; (b) Economic element: maritime GHG emissions pricing mechanism. (Source)

The IMO's mid-term measures are designed to bridge the gap between short-term regulations (EEXI/CII, which focus on efficiency) and the 2050 net-zero goal (which requires wholesale fuel transformation). The framework has two complementary elements working in tandem:

Technical Element: Goal-Based Marine Fuel GHG Intensity Standard

The technical element establishes a declining well-to-wake GHG intensity limit for marine fuels, measured in gCO₂e per megajoule (gCO₂e/MJ). This is a fuel standard, not a ship standard—it regulates the lifecycle emissions intensity of fuels used by ships, not the ships themselves.

How it works:

  • Well-to-wake accounting: Each fuel is assigned a GHG intensity value covering production (well-to-tank) + combustion (tank-to-wake). For example:
    • Heavy fuel oil (HFO): ~95 gCO₂e/MJ well-to-wake
    • Marine gas oil (MGO): ~93 gCO₂e/MJ
    • Liquefied natural gas (LNG): ~75-80 gCO₂e/MJ (lower than oil, but methane slip adds to total)
    • Gray ammonia (fossil-based): ~85 gCO₂e/MJ well-to-wake
    • Blue ammonia (with carbon capture): ~20-30 gCO₂e/MJ
    • Green ammonia (renewable-powered electrolysis): ~2-5 gCO₂e/MJ
    • E-methanol (from renewable electricity + captured CO₂): ~10-20 gCO₂e/MJ
  • Declining intensity limits: The standard sets maximum average GHG intensity for a ship's fuel mix, declining over time. For example (illustrative pathway, exact values to be finalized at MEPC 83):
    • 2028-2030: Maximum 90 gCO₂e/MJ (baseline, allows continued use of fossil fuels with small alternative fuel blending)
    • 2031-2035: Maximum 80 gCO₂e/MJ (requires ~15-20% alternative fuel blending or shift to LNG)
    • 2036-2040: Maximum 60 gCO₂e/MJ (requires ~40-50% near-zero fuel blending)
    • 2041-2045: Maximum 30 gCO₂e/MJ (requires majority zero-emission fuels)
    • 2046-2050: Maximum 5-10 gCO₂e/MJ (near-complete zero-emission fuel use)
  • Compliance flexibility: Ship operators can comply by: (1) using 100% zero-emission fuels (green ammonia, e-methanol, green hydrogen), (2) blending lower-carbon fuels with conventional fuels (e.g., 30% biodiesel + 70% MGO), (3) purchasing GHG intensity credits from ships using fuels below the required intensity (tradable compliance mechanism, similar to EU ETS or CORSIA).

Strategic impact: The fuel GHG intensity standard creates a predictable regulatory glide path, enabling fuel suppliers and shipowners to plan investments. It avoids technology mandates (doesn't prescribe ammonia vs methanol vs hydrogen) but sets performance outcomes (you must achieve X gCO₂e/MJ, choose your pathway). This is analogous to vehicle fuel economy standards or renewable fuel standards in road transport.

Economic Element: Maritime GHG Emissions Pricing Mechanism

The economic element introduces a price on maritime GHG emissions, creating financial incentives to reduce emissions beyond compliance minimums. The pricing mechanism has two components:

1. GHG Fuel Intensity (GFI) levy: A fee charged on the GHG intensity of marine fuels used. Ships using high-GHG-intensity fuels (conventional oil, gray ammonia) pay higher fees per tonne of fuel; ships using low-GHG-intensity fuels (green ammonia, e-methanol) pay lower fees or zero fees.

  • Fee structure (indicative, subject to MEPC 83 finalization): Fee = (Fuel GHG intensity in gCO₂e/MJ - Target intensity) × Fuel consumed in MJ × Price per tonne CO₂e. For example, if target intensity is 60 gCO₂e/MJ and price is $100/tonne CO₂e:
    • Ship using HFO (95 gCO₂e/MJ): pays fee on excess 35 gCO₂e/MJ
    • Ship using green ammonia (3 gCO₂e/MJ): pays zero (below target)
  • Revenue use: Revenues collected from GFI levy will be channeled to: (1) support developing countries' maritime decarbonization (technical assistance, port infrastructure for alternative fuels), (2) fund R&D for zero-emission fuels and propulsion technologies, (3) potentially reward ships exceeding compliance (feebate structure: polluters pay, leaders receive rebates).

2. GHG Emissions levy (optional, under negotiation): An additional fee on absolute emissions ($/tonne CO₂e emitted), independent of fuel type. This would function like a carbon tax, increasing the cost of all fossil fuel use regardless of intensity. This element is more controversial—some countries (especially island states and EU members) support it as necessary to drive deep decarbonization; others (including major shipping nations like China, India, Brazil) oppose it as disproportionately impacting developing countries' trade.

Adoption and Entry Into Force Timeline

Adoption and entry into force timeline: Draft approved by MEPC 83 (April 2025); adoption at extraordinary MEPC session (Autumn 2025); entry into force 16 months after adoption (~2027); first compliance year 2028. (Source)

  • MEPC 83 (April 2025): Draft regulations for technical and economic elements approved by Marine Environment Protection Committee. Key parameters finalized: fuel GHG intensity reduction trajectory, GFI levy fee structure, revenue allocation mechanisms, compliance and enforcement provisions.
  • Extraordinary MEPC session (Autumn 2025): Formal adoption of mid-term measures as amendments to MARPOL Annex VI. This special session allows rapid adoption following MEPC 83 approval, accelerating timeline vs waiting for MEPC 84 (2026).
  • Entry into force (~2027): MARPOL amendments enter into force 16 months after adoption (tacit acceptance procedure: unless objected to by one-third of IMO member states representing 50% of gross tonnage, amendments automatically enter into force after 16 months). Estimated entry: Q1 2027.
  • First compliance year (2028): Ships must comply with fuel GHG intensity limits and pay GFI levy based on 2028 fuel consumption. Reporting via IMO Data Collection System (DCS), with additional data elements approved at MEPC 80. (Source)

Data Collection System (DCS) Enhancements

Additional data elements: MEPC 80 approved amendments to MARPOL Annex VI Appendix IX requiring fuel consumption per fuel type and energy consumer, transport work, and energy consumer data; data accessibility expanded. (Source)

The IMO Data Collection System (DCS), operational since 2019, requires ships ≥5,000 GT to report annual fuel consumption. MEPC 80 expanded DCS to support mid-term measures compliance:

  • Fuel-specific consumption data: Ships must report consumption by fuel type (HFO, MGO, LNG, methanol, ammonia, etc.) and by energy consumer (main engine, auxiliary engines, boilers). This enables precise calculation of well-to-wake emissions using fuel-specific GHG intensity factors.
  • Transport work: Enhanced reporting of cargo carried (tonnes) and distance traveled (nautical miles) to improve CII accuracy and enable transport-work-based compliance mechanisms.
  • Onboard fuel consumption monitoring (OBFCM): Ships must have certified OBFCM systems (flow meters on fuel lines) to ensure data accuracy. This data feeds into DCS and is verified by flag state or recognized organizations.

DCS data will be the enforcement backbone for mid-term measures: ships report fuel consumption → fuel type matched to GHG intensity database → total well-to-wake emissions calculated → compliance assessed against fuel GHG intensity limits → GFI levy calculated and invoiced.

Investment signal: The mid-term measures, particularly the fuel GHG intensity standard with a published reduction trajectory through 2050, provide the long-term price signal that fuel suppliers and shipyards have been demanding. With regulatory certainty that conventional oil will be phased out, investment in green ammonia production, methanol production, bunkering infrastructure, and dual-fuel/ammonia-ready newbuilds becomes financially justifiable. Analysts estimate the mid-term measures will unlock $50-100 billion in alternative fuel infrastructure investment globally by 2030.

Alternative Fuels Landscape: What Qualifies as "Zero or Near-Zero"

LNG (Not Zero, Bridge Fuel)

Liquefied natural gas (LNG) has been the dominant alternative fuel in shipping since 2010, driven by sulfur emission regulations (IMO 2020 0.5% sulfur cap made LNG attractive vs scrubber-equipped HFO). However, LNG is not a zero or near-zero GHG fuel under the 2023 revised strategy's lifecycle approach.

LNG GHG profile:

  • Tank-to-wake: LNG combustion emits ~25% less CO₂ than HFO per unit energy (LNG is primarily methane, CH₄, with higher hydrogen-to-carbon ratio than oil-based fuels).
  • Methane slip: Incomplete combustion in engines releases unburned methane—a potent greenhouse gas with ~28-36 times the global warming potential of CO₂ over 100 years. Methane slip varies by engine type: high-pressure dual-fuel engines (0.5-2% slip), low-pressure dual-fuel engines (3-6% slip), older two-stroke engines (up to 8% slip).
  • Well-to-tank: Upstream emissions from natural gas extraction, liquefaction, and transportation add ~15-25% to total lifecycle GHG footprint (methane leakage during extraction and transport is a major contributor).
  • Total well-to-wake: LNG ranges from 75-80 gCO₂e/MJ (modern engines, low methane slip) to 90+ gCO₂e/MJ (older engines, high slip)—only 5-20% better than MGO (~93 gCO₂e/MJ), far from "zero or near-zero."

Strategic role: LNG is a bridge fuel—ships built 2020-2025 with LNG propulsion have better GHG performance than oil-fired equivalents and can comply with CII ratings and early years of the fuel GHG intensity standard (2028-2032). However, LNG ships will struggle to comply post-2035 as intensity limits tighten, unless they switch to bio-LNG or synthetic methane (both scarce and expensive). LNG infrastructure investment should be viewed as a 10-15 year horizon, not a 2050 solution.

Methanol, Ammonia, Hydrogen: The Zero-Emission Trio

Methanol (CH₃OH)

Methanol is the first scalable alternative fuel seeing commercial adoption for deep-sea shipping. Maersk has ordered 25+ large container ships (13,000-16,000 TEU) with dual-fuel methanol engines for delivery 2024-2027, the largest alternative fuel newbuild program to date.

Methanol GHG profile:

  • Gray methanol (fossil-based, from natural gas or coal): 90-100 gCO₂e/MJ well-to-wake—no better than conventional fuels.
  • Bio-methanol (from biomass, waste, or forestry residues): 20-40 gCO₂e/MJ well-to-wake, depending on feedstock and production pathway. Certified sustainable bio-methanol with ≥65% GHG reduction vs MGO qualifies as "near-zero."
  • E-methanol (synthesized from green hydrogen + captured CO₂): 10-20 gCO₂e/MJ well-to-wake (emissions from energy inputs in H₂ production and CO₂ capture, but near-zero if using renewable electricity). This is the long-term methanol pathway aligned with net-zero.

Advantages: Methanol is liquid at ambient temperature and pressure (easy handling vs cryogenic fuels), compatible with existing bunkering infrastructure (with minor modifications), and engines are commercially proven (MAN and WinGD offer dual-fuel methanol engines). Toxicity is moderate (safer than ammonia, more toxic than diesel).

Challenges: Lower energy density than oil (~50% volumetric energy density of MGO, requiring ~2× larger fuel tanks), limited green/bio-methanol production (global production ~100 Mt/year, mostly gray methanol for chemicals; green e-methanol production ~0.5 Mt/year as of 2024), high cost ($800-1,200/tonne for e-methanol vs $600-700/tonne for MGO).

Ammonia (NH₃)

Ammonia is the leading candidate for deep-sea zero-emission shipping, particularly for large vessels (VLCCs, Capesize bulk carriers, large container ships) on long-haul routes where methanol's lower energy density is prohibitive.

Ammonia GHG profile:

  • Gray ammonia (Haber-Bosch process from natural gas, no carbon capture): 80-90 gCO₂e/MJ well-to-wake—not zero-emission.
  • Blue ammonia (Haber-Bosch with carbon capture and storage): 15-30 gCO₂e/MJ well-to-wake (depends on CCS capture rate: 90% capture → ~15 gCO₂e/MJ).
  • Green ammonia (electrolysis hydrogen + nitrogen from air separation, powered by renewables): 2-5 gCO₂e/MJ well-to-wake (only emissions from minor energy inputs and upstream equipment manufacturing). This is the gold standard for zero-emission marine fuel.

Advantages: Zero CO₂ emissions when combusted (nitrogen and water as exhaust), high volumetric energy density (~50% of MGO, better than hydrogen and comparable to methanol), established global production and distribution (140 Mt/year produced globally for fertilizer), existing ammonia tanker fleet provides operational knowledge.

Challenges: Toxic and corrosive (requires specialized handling, crew training, stringent safety protocols), low flame speed and combustion stability (requires pilot fuel or advanced engine designs), N₂O (nitrous oxide) formation during combustion (potent GHG, ~265× CO₂ on 100-year basis; requires exhaust aftertreatment). Engine technology is still maturing—first commercial ammonia-fueled ships (2-stroke engines from MAN and WinGD) expected 2025-2026 deliveries.

Hydrogen (H₂)

Hydrogen is the ultimate zero-emission fuel (only water vapor from combustion or fuel cells), but faces severe practical challenges for deep-sea shipping.

Hydrogen GHG profile:

  • Gray hydrogen (steam methane reforming, no carbon capture): 90-95 gCO₂e/MJ well-to-wake—not zero-emission.
  • Blue hydrogen (SMR with CCS): 20-35 gCO₂e/MJ.
  • Green hydrogen (electrolysis from renewable electricity): 0-3 gCO₂e/MJ—true zero-emission.

Advantages: Zero emissions, high gravimetric energy density (120 MJ/kg vs 43 MJ/kg for MGO), rapid refueling for fuel cell applications.

Challenges: Extremely low volumetric energy density (compressed at 700 bar: ~5% of MGO; liquefied at -253°C: ~25% of MGO), requiring massive tank volumes or cryogenic systems unsuitable for most ships. Hydrogen is viable for short-sea shipping (ferries, coastal vessels) where frequent refueling is possible, but impractical for transoceanic routes. Most analysts view hydrogen as an intermediate step—ships are more likely to use hydrogen derivatives (ammonia, methanol, synthetic fuels) than pure hydrogen.

Biofuels and Synthetic E-Fuels

Biofuels (Drop-In Compatibility)

Biofuels certified by international schemes (meeting aviation sustainability standards) with ≥65% well-to-wake GHG reduction vs fossil MGO can use well-to-wake CO2 conversion factor under DCS and CII. (Source)

Biofuels (biodiesel, hydrotreated vegetable oil-HVO, bio-LNG) are attractive for existing fleets because they are "drop-in" fuels—compatible with existing engines and infrastructure without modification. MEPC 80 adopted a temporary circular allowing certified sustainable biofuels (ISCC, RSB schemes) with ≥65% lifecycle GHG reduction to use preferential emission factors for CII reporting, making them CII-favorable.

Challenges: Feedstock limitations (competing with food, land use change risks), high cost ($1,000-2,000/tonne for advanced biofuels vs $600-700/tonne MGO), limited scalability (global sustainable biofuel potential estimated at 50-100 Mt/year for all transport sectors, shipping may access only 10-20 Mt/year).

Synthetic E-Fuels (E-Diesel, E-LNG, E-Methanol)

Synthetic fuels produced via Power-to-X pathways (renewable electricity → hydrogen → synthesis to liquid/gaseous fuels) can achieve near-zero well-to-wake emissions if using captured CO₂ and renewable energy. E-diesel and e-LNG can be used in existing fleets (drop-in compatibility), while e-methanol and e-ammonia are already covered above.

Challenges: Very high production cost ($1,500-3,000/tonne MGO-equivalent for e-diesel, due to energy losses in multi-step conversion), limited production capacity (mostly pilot projects as of 2024), and efficiency concerns (only ~30-40% of input renewable electricity ends up as useful fuel energy, vs ~70-80% for direct electrification in road transport—but electrification not viable for shipping).

Safety Frameworks Under Development (MSC 108+)

The IMO's Maritime Safety Committee (MSC) is developing safety codes and guidelines for alternative fuels:

  • IGF Code (International Code of Safety for Ships using Gases or other Low-flashpoint Fuels): Originally developed for LNG, being expanded to cover methanol, ammonia, hydrogen. MSC 107 (2023) approved interim guidelines for methanol; MSC 108 (2024) approved interim guidelines for ammonia. Final amendments expected 2025-2026.
  • Key safety provisions: Fuel containment systems (double-wall tanks, leak detection), ventilation (prevent explosive atmospheres), fire suppression (inert gas systems), emergency shutdown, crew training and certification.
  • Port and bunkering safety: International Safety Management (ISM) Code and ISPS (port security) being updated to address alternative fuel bunkering operations—ammonia bunkering requires specialized equipment, shoreside emergency response, and potentially exclusion zones during bunkering.

Alternative Marine Fuels: Well-to-Wake GHG Intensity Comparison

Based on lifecycle GHG assessment guidelines (MEPC 80). Source

Economics and Fleet Investment Implications

Retrofit vs Newbuild Decision Drivers

EEXI Compliance: Retrofit or Replace?

For ships built before 2013 failing EEXI, operators faced a choice in 2023:

  • Low-cost retrofit (engine power limitation - EPL): Cost: $50,000-200,000 per ship (electronic governor installation, documentation, certification). Reduces max speed by 10-20% but allows continued fossil fuel operation. Suitable for ships with 5-10 years remaining economic life.
  • Mid-cost retrofit (efficiency technologies): Cost: $500,000-2,000,000 (hull air lubrication, waste heat recovery, propeller upgrades). Improves EEXI and CII performance without speed penalty. Payback period 3-7 years depending on fuel prices. Suitable for ships with 10-15 years remaining life.
  • High-cost retrofit (fuel conversion): Cost: $5-15 million (convert to LNG or methanol dual-fuel). Only economical for high-value ships with 15+ years remaining life and clear fuel availability/cost projections.
  • Scrap and replace: For ships >20 years old with poor EEXI/CII performance, scrapping and ordering new EEDI Phase 3-compliant vessel (or alternative-fuel newbuild) may be more economical than retrofit. 2023-2024 saw elevated scrapping rates (300-400 ships/year vs historical 200-250) attributed partly to EEXI/CII driving retirement of marginal tonnage.

Newbuild Fuel Readiness: Hedge or Commit?

Ship operators ordering newbuilds (2024-2027 delivery) face fundamental fuel choice:

  • Conventional (MGO/HFO with scrubber): Lowest upfront cost, proven technology, but regulatory risk—ships delivered 2025 will operate until 2045-2050 in a net-zero regulatory environment. CII penalties, fuel GHG intensity non-compliance costs, and stranded asset risk make conventional newbuilds increasingly unattractive unless short economic life (e.g., specialized vessels, short-sea trades).
  • LNG dual-fuel: Moderate additional cost (+10-15% vs conventional), de-risks near-term CII and fuel GHG intensity compliance (2028-2035), but long-term viability uncertain post-2040. Suitable for ships with expected life through 2040-2045, assuming transition to bio-LNG or synthetic methane in later years.
  • Methanol-ready or ammonia-ready: Higher upfront cost (+15-25% vs conventional for "ready" designs with larger fuel tanks and compatible piping/materials, but not full dual-fuel capability), provides optionality. Ship can operate on conventional fuel initially, converting to methanol/ammonia when fuel availability and economics improve (conversion cost additional $2-5M).
  • Full dual-fuel (methanol or ammonia): Highest upfront cost (+20-30% vs conventional), but immediate compliance with zero-fuel uptake targets, favorable financing (green loans, sustainability-linked loans with lower interest rates), and charter premium (charterers willing to pay 5-15% higher rates for zero-emission vessels to meet their own Scope 3 targets). Suitable for operators with long-term charter commitments, access to alternative fuel supply agreements, and commitment to decarbonization leadership.

Bunkering Infrastructure Investment: Where Ammonia/Methanol Hubs Emerge

Alternative fuel bunkering infrastructure requires massive investment—estimated $50-100 billion globally by 2030 for ammonia and methanol bunkering capacity to serve 5-10% alternative fuel uptake target.

Leading bunker hubs making commitments (2024-2025):

  • Singapore: Government committed $300M for alternative fuel bunkering infrastructure; partnerships with renewable energy developers to supply green ammonia/methanol by 2027-2028; targeting 20% market share of global alternative fuel bunkering by 2030.
  • Rotterdam: EU's largest port investing €500M in green hydrogen, ammonia, and methanol import terminals and bunkering facilities; leveraging EU renewable energy imports from North Africa (solar) and North Sea (offshore wind).
  • Fujairah (UAE): Positioning as Middle East alternative fuel hub, with access to low-cost solar energy for green ammonia/methanol production; targeting Asia-Europe and Asia-Middle East trades.
  • Shanghai/Ningbo-Zhoushan (China): China investing $1B+ in alternative fuel bunkering infrastructure at major ports; domestic ammonia and methanol production capacity expansion (China already produces ~25% of global ammonia).
  • US Gulf Coast (Houston, New Orleans): Leveraging existing ammonia production (US produces ~10% of global ammonia) and LNG infrastructure; targeting trans-Atlantic and Latin America trades.

Infrastructure investment risks: Chicken-and-egg problem—ports hesitate to invest in bunkering infrastructure without committed ship demand; ship operators hesitate to order alternative-fuel vessels without guaranteed fuel availability. First-mover partnerships (e.g., Maersk's methanol supply agreements with producers before ordering methanol ships) are critical to break the deadlock. Government co-investment (subsidies, loan guarantees, carbon contracts for difference) is accelerating infrastructure rollout.

Carbon Pricing Impact on Freight Rates and Charter Contracts

The mid-term measures' GHG emissions pricing mechanism will directly increase shipping costs. Estimated impact on freight rates (assuming $100/tonne CO₂e GFI levy, illustrative):

  • Container shipping (Asia-Europe route): Fuel cost represents ~30-40% of slot cost at historical fuel prices ($600/tonne MGO). A $100/tonne CO₂ price adds ~$30-40/tonne fuel cost (assuming 3.2 tonnes CO₂/tonne MGO), or +5-7% total slot cost. This translates to +$50-100 per TEU (twenty-foot equivalent unit) on a $1,500 Asia-Europe TEU rate—manageable, but cumulative impact by 2040-2050 ($200-300/tonne CO₂) could add 15-25% to freight rates unless absorbed by efficiency gains.
  • Dry bulk (iron ore, coal, grain): Freight rates are more sensitive to fuel costs (fuel represents 50-60% of voyage costs). Carbon pricing impact: +10-15% freight rates at $100/tonne CO₂. This may shift trade patterns (shorter routes favored, modal shift to rail for continental distances).
  • Tankers (crude oil, product tankers): Similar to dry bulk; carbon costs passed through to oil refiners/importers, ultimately to consumers. Gasoline/diesel prices could increase $0.01-0.03/liter from maritime carbon costs (small relative to fuel taxes and oil price volatility).

Charter contract evolution: Time charter contracts are being rewritten to allocate carbon compliance costs and CII performance risk:

  • Fuel clause adjustments: Traditional bunker adjustment clauses (compensate owner for fuel price changes) now include carbon levy pass-through provisions. Charterer pays owner for GFI levy costs if charterer controls fuel purchasing; owner retains cost if owner controls fuel.
  • CII performance clauses: Charterers increasingly negotiate CII performance guarantees—owner guarantees ship will achieve B or C rating; if D/E, charterer entitled to hire reduction (5-10% discount) or early termination. Conversely, charterers accept operational constraints (speed limits, routing requirements) to achieve target CII.
  • Green charter premiums: Charterers with corporate net-zero commitments (e.g., Amazon, IKEA, Unilever) willing to pay 5-20% premium for zero-emission vessels to reduce Scope 3 emissions. This creates two-tier charter market: green premium for alternative-fuel ships, discount for non-compliant conventional ships.

Stranded Asset Risk for Vessels Non-Compliant by 2030

Ships unable to comply with 2030 fuel GHG intensity limits face severe devaluation:

  • Resale value impairment: Secondhand ship prices for non-compliant vessels (conventional fuel, no alternative fuel capability) declining 20-40% vs comparable compliant vessels (LNG or alternative-fuel ready). This is analogous to diesel vehicle resale values falling as Euro 6/7 emission standards tighten.
  • Charter rate collapse: Charterers avoiding non-compliant ships (reputational risk, Scope 3 reporting pressure, potential future trade restrictions). Non-compliant vessels seeing 15-30% charter rate discounts vs market, with some struggling to secure employment (idle time increases).
  • Early scrapping: Economic life of conventional ships shortening. Ships built 2010-2020 (designed for 25-year life, expected scrap 2035-2045) may be scrapped 2030-2035 if retrofit uneconomical and charter market access limited. This represents $50-100 billion in stranded asset value across global fleet.
  • Financing implications: Banks incorporating climate risk into ship finance—loan-to-value ratios declining for non-compliant vessels (higher equity requirement), interest rate premiums (+50-150 basis points for conventional vs green ships), shorter loan tenors (15 years vs historical 20 years). Some European banks (DNB, Nordea) no longer financing conventional fossil-fuel vessels ordered post-2023.
Fleet investment paradigm shift: Shipping has historically been a conservative, asset-heavy industry with 20-25 year investment horizons and proven technology bias. IMO 2030/2050 regulations force a fundamental shift: ships ordered today must operate in a net-zero world for most of their economic life. This makes alternative fuels, despite higher upfront costs and fuel uncertainty, the lower-risk investment compared to conventional ships facing regulatory obsolescence. The industry is experiencing its most significant technological disruption since the shift from sail to steam (1850s-1900s) or coal to oil (1900s-1950s).
-30% reduction) is the critical "go/no-go" signal for the maritime industry. If the checkpoint is missed (emissions only declining 10-15% by 2030), the following regulatory responses are likely:

Conversely, if the 2030 checkpoint is met or exceeded (25-35% reduction), the industry gains credibility and regulatory flexibility—2040 targets may be adjusted more gradually, allowing market-driven transition rather than mandates.

The Role of Digital Monitoring (OBFCM, DCS) in Enforcement

Digital monitoring systems are the enforcement backbone of IMO 2030/2050 regulations:

Onboard Fuel Consumption Monitoring (OBFCM)

IMO Data Collection System (DCS)

Satellite and AI-Based Verification

Technology Wild Cards: What Could Accelerate or Derail the Transition

Accelerators

Derailers

2028 Strategy Review
MEPC 88
Autumn 2028 - finalizes next strategy. Source
Mid-Term Entry (~2027)
First Compliance
2028 - GHG fuel intensity + pricing
Digital Enforcement
OBFCM + DCS
Real-time monitoring post-2027

IMO Regulatory Timeline: 2023-2050 (Key Milestones)

Based on IMO MEPC 80 (2023) and mid-term measures adoption timeline. Source

FAQ (Frequently Asked Questions)

What is the difference between the 2018 and 2023 IMO GHG strategies?

The 2018 Initial Strategy targeted at least 50% reduction in total annual GHG emissions by 2050 compared to 2008. (Source) The 2023 Revised Strategy adopted net-zero GHG emissions by or around 2050, with interim checkpoints: at least 20% reduction (striving for 30%) by 2030 and at least 70% reduction (striving for 80%) by 2040 compared to 2008. (Source) The 2023 strategy also introduces well-to-wake (lifecycle) emissions accounting, replacing the 2018 tank-to-wake approach.

When do EEXI and CII requirements apply?

EEXI and CII entered into force on 1 January 2023, applying to ships ≥400 GT. (Source) EEXI is a one-time certification obtained at the first annual, intermediate, or renewal survey on or after 1 January 2023. CII is calculated annually based on the previous calendar year's operational data, with the first CII rating assigned for 2023 performance (reported in early 2024).

What happens if a ship receives a "D" or "E" CII rating?

Ships rated D for three consecutive years or E for one year must submit a corrective action plan. (Source) The plan is developed as part of the Ship Energy Efficiency Management Plan (SEEMP Part III) and must be approved by the flag state. While there is currently no direct IMO penalty for failing to improve CII ratings, market-based penalties are emerging—charterers refusing to hire D/E-rated vessels, and banks/insurers linking financing terms to CII performance.

When will the IMO mid-term measures (fuel GHG intensity standard and GHG pricing) enter into force?

Draft approved by MEPC 83 (April 2025); adoption at extraordinary MEPC session (Autumn 2025); entry into force 16 months after adoption (~2027); first compliance year 2028. (Source) The mid-term measures consist of a technical element (goal-based marine fuel GHG intensity standard with phased reduction) and an economic element (maritime GHG emissions pricing mechanism, including GHG Fuel Intensity levy).

What fuels qualify as "zero or near-zero" GHG emission fuels under IMO regulations?

Zero or near-zero fuels include: green ammonia (produced via renewable-powered electrolysis, ~2-5 gCO₂e/MJ well-to-wake), e-methanol (synthesized from green hydrogen and captured CO₂, ~10-20 gCO₂e/MJ), green hydrogen (~0-3 gCO₂e/MJ), advanced biofuels (certified sustainable with ≥65% GHG reduction vs fossil MGO, ~20-40 gCO₂e/MJ), and blue ammonia/methanol (fossil-based with carbon capture, ~15-30 gCO₂e/MJ). LNG is not considered zero or near-zero due to well-to-wake emissions of 75-90 gCO₂e/MJ. Lifecycle GHG assessment guidelines were adopted at MEPC 80. (Source)

How does EU FuelEU Maritime differ from IMO mid-term measures?

FuelEU Maritime (EU regulation) entered into force 1 January 2025, applying to ships ≥5,000 GT calling at EU/EEA ports. It sets annual well-to-wake GHG intensity limits declining from 2025 to 2050 (2030: ~86 gCO₂e/MJ; 2050: ~18 gCO₂e/MJ). Non-compliance triggers penalties (€2,400/tonne non-compliance in 2025, escalating). FuelEU also mandates onshore power use for container/passenger ships at major EU ports from 2030 and requires minimum 2% renewable fuels (RFNBO) from 2034. IMO mid-term measures (entry ~2027) are global and include both a fuel GHG intensity standard and an emissions pricing mechanism (GFI levy), with revenues supporting developing countries and R&D. Ships calling at EU ports must comply with both regimes.

Is LNG a compliant fuel for IMO 2030/2050 targets?

LNG is a bridge fuel, not a long-term solution. LNG has well-to-wake GHG intensity of 75-90 gCO₂e/MJ (15-20% better than HFO at ~95 gCO₂e/MJ but far from zero). LNG ships can comply with early years of the fuel GHG intensity standard (2028-2035) but will struggle post-2035 as intensity limits tighten. LNG does not count toward the 5-10% zero/near-zero fuel uptake target by 2030. Ships investing in LNG should plan for transition to bio-LNG or synthetic methane by 2035-2040, or face retrofitting to ammonia/methanol or early scrapping.

How much will IMO carbon pricing increase shipping costs?

Estimated impact varies by route and ship type. Assuming a $100/tonne CO₂e GHG Fuel Intensity (GFI) levy (indicative rate, subject to MEPC 83 finalization), and conventional fuel (HFO) with GHG intensity ~95 gCO₂e/MJ vs target intensity ~85 gCO₂e/MJ in 2030, the levy adds approximately $250-300/tonne fuel cost. For container shipping (Asia-Europe route), this translates to +5-7% slot cost, or +$50-100 per TEU. For dry bulk, impact is +10-15% freight rates. These costs will be passed through to cargo owners and ultimately consumers, but represent a small fraction of total supply chain costs (typically <2% of final product retail price for manufactured goods).

What is the IMO Data Collection System (DCS) and how does it work?

The IMO Data Collection System (DCS) requires ships ≥5,000 GT to report annual fuel consumption by fuel type, distance traveled, hours underway, and cargo carried. Data is submitted to the ship's flag state or recognized organization, which verifies and transmits anonymized aggregate data to IMO for global fleet analysis. MEPC 80 approved amendments requiring additional data elements: fuel consumption per fuel type and energy consumer, transport work, and energy consumer data; data accessibility expanded. (Source) DCS data is used to calculate CII ratings and will be the compliance database for mid-term measures (fuel GHG intensity and GFI levy invoicing from 2028).

When is the next IMO GHG Strategy review?

MEPC 86 (Summer 2027) initiates review; MEPC 88 (Autumn 2028) finalizes review with view to adoption of 2028 IMO Strategy. (Source) The review will assess whether the 2030 checkpoint (20-30% reduction vs 2008) is on track, evaluate alternative fuel uptake progress, and determine whether targets need to be tightened or timelines accelerated. If 2027 data shows insufficient progress, the 2028 strategy may introduce more stringent 2030/2040 targets or mandatory alternative fuel requirements for newbuilds.

Sources Cited (All Inline Citations Are Authoritative)

Every factual and quantitative claim is cited inline with full URLs. This list is provided for reference convenience.