July 13, 2023 | Circular No. 11554

Dear Member,

IMO’s Marine Environment Protection Committee (MEPC 80) met in London last week, bringing together delegates from IMO member states and numerous non-governmental organizations. Despite taking place against a backdrop of political tensions including the ongoing war in Ukraine, the in-person format allowed delegates to discuss and, in some cases, reach a consensus on topics in a way that was not possible in the shortened virtual format these meetings used over the past few years due to the pandemic. The undersigned attended several sessions, and decision points were reached on the following topics:

DECARBONIZATION

The highly anticipated result of this session was adoption of the 2023 IMO Greenhouse Gas Reduction Strategy (GHG Strategy), which notably includes a goal to achieve net-zero GHG emissions from international shipping (on a well-to-wake basis) by or around 2050, and checkpoint reductions of:

  • 20%, striving for 30%, by 2030, compared to 2008 and
  • 70%, striving for 80%, by 2040, compared to 2008.

As BIMCO noted, “The newly adopted IMO GHG reduction strategy translates to a reduction of around 90% on average at the individual ship level [by 2040] due to expected fleet growth. And 2040 is only 17 years from now.”

Mid-term measures, which are to enter into force in 2027, will include a goal-based marine fuel standard regulating the phased reduction of the marine fuel’s GHG intensity, and a “marine GHG emissions pricing mechanism,” essentially a price on GHGs – including carbon dioxide and other GHGs such as methane. An IMO GHG intersessional working group will meet this fall to establish these measures.

Agreement on the GHG Strategy came after two last-minute modifications were made to achieve consensus, and the sentiments expressed in room when it was adopted reflected major compromise from many parties. We see the adoption of this GHG Strategy as a strong market signal about the amount of investment and speed of change needed to decarbonize the international shipping sector. These new goals represent a dramatic increase in ambition. At the same time, the adopted checkpoint levels for 2030 and 2040 are well below the levels many countries including Canada, the United States, Europe, and Pacific Island States advocated for, and below ‘science-based targets’ for keeping climate change within the increase targeted in the Paris Climate Agreement. Because of this, we anticipate that there will be a renewed push for a more ambitious revision at the next GHG Strategy review in 2028.

Review of the short-term measures (CII & EEXI) was also initiated, to be completed by Jan 1, 2026. This review will include correction factors and voyage adjustments for CII, experiences with enforcement of the short-term measures, and the CII metrics.

BALLAST WATER MANAGEMENT – CHALLENGING WATER QUALITY

Canada co-sponsored a submission to MEPC for temporary Guidance on the Application of the Ballast Water Management Convention to ships operating in Challenging Water Quality. Industry has been seeking such guidance to address ongoing challenges with operating Ballast Water Management Systems, particularly in some portions of the Great Lakes, and work to develop such guidelines has been ongoing at IMO for six years. The Federation flagged several concerns with the proposed guidance to TC prior to MEPC 80. The Guidelines were not adopted at MEPC 80, and will be revisited at MEPC 81 next year. TC indicated that it intends to move forward with a Canadian approach to these guidelines regardless of their adoption at IMO. We will be active in this consultation.

UNDERWATER NOISE REDUCTION GUIDELINES

Revised Guidelines to reduce underwater noise from ships were adopted at MEPC 80. Canada led this revision, and the Federation provided input on drafts. There are sections of the guidelines each directed at designers, shipbuilders, owners/ operators, and government administrations. We will provide further information on the Guidelines and share them once they are released publicly.

ARCTIC EMISSION CONTROL AREA (ECA)

Canada announced that it will be proposing an Emission Control Area (ECA) in the Canadian Arctic at the next MEPC meeting (Spring 2024). This would essentially extend the air quality measures for SOx and NOx that are currently in place for the rest of North America, to north of 60 degrees. This announcement received vocal support from several countries in the MEPC 80 plenary session, and has separately received strong support from our members currently conducting operations in the Canadian Arctic.

RATIFICATION OF THE SHIP RECYCLING CONVENTION (HONG KONG CONVENTION)

This convention is aimed at ensuring that ships, when being recycled after reaching the end of their operational lives, do not pose any unnecessary risk to human health and safety or to the environment. After being ratified by Bangladesh, one of the world’s largest ship recycling countries by capacity, and by Liberia, one of the world’s largest flag States by tonnage at MEPC 80, the Hong Kong Convention will enter into force on 26 June 2025.

Please contact the undersigned with questions, comments, or feedback on the above topics.

Sincerely,

Miako Ushio
Manager, Environmental and Regulatory Affairs