Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping (MMMCZCS) looks at what is known about the International Maritime Organization Net-Zero Framework (IMO NZF) and associated guidelines expected to enter into force, reports Safety4sea.
The big picture
According to MMMCZCS, the IMO NZF will become a new chapter under MARPOL Annex VI if adopted at MEPC/ES.2 (14 – 17 October, 2025). The regulation must go through a process of adoption and tacit acceptance before entry into force. A series of guidelines need to be developed by 2028 for effective implementation of the IMO NZF.
What the process looks like for the IMO NZF
As shown in Figure 2 below, the IMO NZF was approved as draft amendments to MARPOL Annex VI at MEPC 83 in April 2025. The IMO normally makes decisions by consensus, so it was unusual for a vote to be called for on this occasion. In total, 103 states voted, with 63 yes votes, 16 no votes, and 24 abstentions. As abstentions are not counted, this vote met the requirement for a simple majority of 40. With 176 Member States in the IMO, these voting numbers may seem low at first glance. However, based on credentials and voting rights, only 118 states were eligible to vote, and 15 of these were absent on the day of the vote.
In April, the Secretariat circulated the IMO NZF as draft amendments to Member States for consideration. An extraordinary session of MEPC (known as MEPC/ES.2) in October 2025 marks the end of the 6-month consideration period and is where the amendments will be presented for adoption. While adoption is also typically done by consensus, with a vote taking place in April, another call for a vote is likely to take place at MEPC/ES.2. Only states party to MARPOL Annex VI are entitled to vote on adoption, and at least a two-thirds majority is required for the amendments to be passed.
Who may vote on adoption?
MARPOL Annex VI currently has 108 contracting states, comprising around 95% of the global fleet. States can become party to a protocol via ratification, acceptance, approval, or accession. This step can take several years and is completed when a state signs the necessary legal instrument and delivers it to the Secretary-General of the IMO.
Assuming adoption at MEPC/ES.2, the IMO NZF amendments enter into force automatically on 1 March 2027, unless objections are made by a specified number of parties. For MARPOL amendments, the acceptance period is a minimum of 10 months and is determined by the MEPC at the time of adoption.
The amendment is accepted unless during that period more than one-third of Member States party to MARPOL Annex VI, or with a combined gross tonnage of at least 50% of the world’s merchant fleet, formally communicate an objection to the amendment.
Following deemed acceptance, the amendments enter into force six months later. While the NZF is expected to enter into force in 2027, in effect ships will need to start complying from 1 January 2028, which is when the first reporting period begins.
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Source: Safety4sea
