March 28, 2024 | Circular No. 11653

Dear Member,

The IMO’s Marine Environment Protection Committee (MEPC) met last week in London. Below is a summary from a Canadian perspective of key topics covered:

Emission Control Area (ECA) in Canadian Arctic Waters: Canada’s proposal to establish an Emission Control Area for NOx, SOx and PM in Canadian Arctic Waters was approved at MEPC 81. The justification of this ECA is to provide Canadians north of 60 degrees the same health protection as the rest of Canada (the North American ECA ends at 60 degrees north latitude). This proposal will now go through a technical review. Assuming adoption at the next MEPC meeting (MEPC 82) this October, the requirements would be:

  • 0.10% fuel sulphur content from March 1, 2027.
  • Tier III NOx applying to ships constructed on or after January 1, 2025.

These requirements would enter into force in March, 2026 at the earliest.


  • Negotiations on the “mid-term measures” needed to meet the targets in the 2023 IMO GHG Strategy progressed. As noted in previous communications, these measures will include a marine a fuel standard, and a GHG pricing mechanism. Although several regulatory proposals were on the table at MEPC 81, none was adopted. Refined proposals, including possible legal language, will be discussed at MEPC 82 this October.
  • Revised Guidelines on the Life-Cycle GHG Intensity of Marine Fuels were approved. These guidelines set out methods for calculating well-to-wake, and tank-to-wake GHG emissions of fuels.
  • Canada hosted an event to share the results of a study on biofuel use by three Canadian-flagged vessels. The study considered operational impacts, technical preparations needed to use biofuels, and air emissions.

Underwater Noise: A Draft Action Plan on Underwater Radiated Noise was approved, and will be discussed further at MEPC 82. We are currently in the ‘Experience Building Phase’ of the Underwater Noise Reduction Guidelines that were approved in July 2023. To encourage uptake of these guidelines, Canada is taking actions domestically, which includes including extended funding for an underwater noise measurement station on the St. Lawrence River, and TC is encouraging ‘pilot projects’ such as vessel owners developing underwater noise management plans for vessels.

Ballast Water: Temporary Guidance on the Application of the Ballast Water Management Convention to ships operating in Challenging Water Quality, which has been under discussion for 6 years, was adopted at MEPC 81. This is of particular interest for vessels operating in the Great Lakes, where cold and silty water falls outside the operating parameters of many systems. Given that Canada indicated it would take a national approach if these international guidelines were not adopted at this meeting, we see this as a positive development. Guidelines on the temporary storage of treated sewage and grey water in ballast tanks was also adopted at this meeting.

Cargo Carriage & Loss:

  • Recommendations for the carriage of plastic pellets by sea in freight containers was approved, the first of a two-step approach aimed at reducing environmental impacts from plastic pellets. The second step, an action plan to address marine plastic litter from ships, will be reviewed at MEPC 82.
  • MARPOL amendments requiring that the loss of freight containers be reported in accordance with amended SOLAS regulations concerning danger messages, were also adopted at MEPC 81.

Please contact the undersigned with any questions,


Miako Ushio
Director, Environmental Affairs