The 2nd extraordinary session of the IMO’s Marine Environment Protection Committee (MEPC/ES.2) did not achieve consensus, leading to the delay in adopting key amendments related to the organization’s decarbonization goals.1 The meeting, which aimed to operationalize the IMO Net-Zero Framework, was adjourned for one year and is set to continue in October 2026.
Delayed Adoption of Revised MARPOL Annex VI (2025)
The meeting considered the adoption of two major amendments to MARPOL Annex VI, but consensus could not be reached among Member States:2
- IMO Net-Zero Framework: This key instrument includes new requirements on Greenhouse Gas (GHG) fuel intensity (GFI), combined with a pricing and reward mechanism.3 The committee voted 57 to 49 to adjourn, delaying the adoption and pushing the earliest possible entry into force to March 1, 2028.4
- Emission Control Area (ECA) Designation: The proposal to designate the North-East Atlantic Ocean as an ECA for Sulphur Oxides ($\text{SO}_\text{x}$), Particulate Matter (PM), and Nitrogen Oxides ($\text{NO}_\text{x}$) was also not adopted.
Finalization and Clarifications to the IMO Net-Zero Framework
Despite the delay in adoption, the session established a drafting group that made several significant editorial and technical modifications to the draft text:
- GFI vs. CII Distinction: Amendments clarified the relationship between the Ship Energy Efficiency Management Plan (SEEMP) and the GFI. Requirements related to the GFI (SEEMP part IV) are subject only to verification, not company audits, due to a conceptual incompatibility. This is distinct from the Carbon Intensity Indicator (CII) requirements (SEEMP part III), which are subject to both verification and audits.
- Surplus Units: The rules for Surplus units (credits) were updated, clarifying that they can be banked and transferred in subsequent reporting periods.5 The validity of these surplus units was capped at two years.6
- Definition of “New Ship”: The definition applicable to Chapter V was simplified to use only the vessel’s delivery date, moving away from the complex three-date criterion used for the EEDI (Energy Efficiency Design Index).
- Technical Corrections: The compliance formula was corrected to explicitly include the conversion factor to ensure unit consistency from grams to tonnes. Furthermore, reporting for Zero/Near-Zero fuels (ZNZs) is now required in energy units (MJ) instead of CO2 equivalents.
North-East Atlantic ECA Provisions
The previously approved proposal to designate the North-East Atlantic ECA contained specific requirements that were consequently delayed:
- Would have mandated the use of fuel oil with a sulphur content not exceeding 0.10% m/m, starting from March 1, 2028.
- Would have applied to new ships with a building contract placed on or after January 1, 2027, or with a delivery date on or after January 1, 2031.7
Amendments to MARPOL Annex VI
Amendments related to NO emissions and reporting were also considered but not adopted:
- Multiple Engine Operational Profiles: Changes would have clarified data reporting for marine diesel engines with multiple operational profiles, including updating the definition of “irrational emission control strategy” and adding new rows to the IAPP Certificate (Appendix I).
- DCS Data Accessibility: Proposed amendments to MARPOL Annex VI, Regulation 27 would have broadened access to the IMO DCS data to increase transparency, allowing full access to Recognized Organizations and anonymized access to public user accounts.
- Fuel Reporting: Appendix IX would have been updated to introduce two sets of fuel reporting dates for ships undergoing a flag change within a year, resolving discrepancies between Regulation 27 (IMO DCS) and Regulation 28 (CII).
Future Agenda for Decarbonization
The 20th session of the Intersessional Working Group on Reduction of GHG Emissions from Ships (ISWG-GHG 20) is scheduled for October 20 to 24, 2025, with a focus on:
- Developing and revising guidelines for the uniform implementation of the IMO Net-Zero Framework, covering Fuel certification, the ZNZ definition and reward, the IMO Net-Zero Fund, the GFI and compliance approaches, and the IMO GFI Registry.
- Further consideration of the development of the IMO Life Cycle GHG Assessment (LCA) framework.
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Source: Safety4sea
