A week full of discussion in IMO with few concrete results

As expected, MEPC 82, with a historically high number of submitted proposals, created significant attention. Climate issues dominated, and besides the working group on reducing greenhouse gas emissions from shipping, the air pollution and energy efficiency group was also heavily influenced by discussions surrounding the Carbon Intensity Indicator (CII).

CII, in its current form, has significant limitations, and the desire for a fair and robust indicator is far from realized. The working group chairman received requests from multiple sides, highlighting the clear shortcomings of CII. For instance, some mechanisms allow ships to improve their CII through activities that, in practice, increase emissions.

There were also many calls for correction or compensation. For example, for ships sailing in ice, making frequent port calls (where maneuvering causes emissions but not recorded distance), or handling cargo themselves (e.g., self-discharging bulk carriers or ships with their own cranes). Various proposals came primarily from shipping organizations, citing issues with the current CII calculation basis and arguing why ships of specific types or operational patterns do not achieve a fair CII.

The meeting reflected strong self-interest and claims for accommodating specific conditions. However, in Danish Maritime’s opinion, it was harder to see the parties’ willingness to contribute to alleviating global warming. The meeting did not immediately lead to improvements or strengthening of the existing CII, but after lengthy negotiations, there was an agreement to meet again at the upcoming Intersessional Working Group on Air Pollution and Energy Efficiency to review and improve CII. This working group meeting was scheduled for March 2025, just before MEPC 83.

Better database in process

At MEPC 82, there was also a mutual understanding that the database in the current Data Collection System regarding ships’ annual fuel consumption should be strengthened. Meanwhile, guidelines for more detailed DCS reporting were approved.

Classification societies, on behalf of many flag states, collect this data, and the International Association of Classification Societies (IACS) uses Unified Interpretations (UI). However, UI is not direct regulation, and the working group chair emphasized that MEPC manages the following policy toward IACS:

• UIs are not mandatory.
• UIs must not exceed regulatory requirements.
• UIs must not conflict with regulations.

Many member states support the use of IACS UIs from a practical perspective, but some had their own views, and MEPC 82 could not reach an agreement. The compromise was an MEPC guideline: MEPC.1/Circ.913 Guidance on the Application of the Amendments to Appendix IX of MARPOL Annex VI (RESOLUTION MEPC.385(81)).

The greenhouse gas working group continued negotiations on the regulatory text for Mid-term GHG measures and agreed on an Intersessional GHG Working Group in February 2025.

Here too, progress was modest. A comprehensive study of various mid-term measures examined the impact on the fleet and the effect on countries due to different policy initiatives. To meet the IMO’s ambition, CO2 taxes in the range of $75 per ton of CO2 by 2030 and $150 per ton by 2040 are needed.

Consensus was reached to apply the framework to ships over 5000GT. The goal is to reduce greenhouse gas emissions from international shipping as soon as possible in line with the 2023 IMO Strategy on Reduction of GHG emissions from ships.

Certification requirements for Ballast Water Treatment Systems

MEPC 82 approved the 2024 Guidance on ballast water record keeping and reporting. This includes, among other things, reporting related to operations in ports with “challenging water quality.” It is unfortunate that it has come so far as to soften requirements for ships’ discharges of treated ballast water based on the type of seawater. Good systems can treat water of varying quality. Danish Maritime believes that it is not the water quality that is “particularly challenging,” but rather the lower-quality systems that face challenges. The agreement is far from ideal, but the compromise now allows a shipping company operating ships larger than 400GT with ballast water to use this guidance when operating in ports with challenging water quality.

Air pollution

It is encouraging that a new agenda item was adopted to strengthen the effective enforcement of NOx emission requirements. The Canadian Arctic and the Norwegian Sea will become emission control areas for SOx and NOx, expected to take effect on March 1, 2026.

Amendments to the NOx Technical Code 2008 were also approved, with expected implementation in the spring of 2027. Air pollution is an area that Danish Maritime has sought to strengthen and we continue to wish it further strengthened, as the health effects are significant.

Measurement of Black Carbon is another area where Denmark has strengths. However, no tightening has occurred, as the Guidelines on recommendatory Black Carbon emission measurement, monitoring, and reporting are voluntary. Ships using these guidelines are only encouraged to report their Black Carbon emissions to their flag state annually, which is then submitted to the IMO.

Scrubber emissions

The IMO Secretariat has reviewed various options for using the IMO’s Global Integrated Shipping Information System (GISIS) to provide shipping companies with a consolidated source of information on local and regional restrictions on the use of scrubbers. However, as there was no agreement at the previous subcommittee meeting PPR 11, and PPR 11 invited member states and NGOs to submit additional proposals to the upcoming PPR 12, MEPC 82 chose not to address the issue. The documents submitted to MEPC 82 will be forwarded to PPR 12.

IMO’s expert panel GSAMP also assesses emission factors, but no decisions were made at MEPC 82, and the material will be similarly forwarded to PPR 12.

Underwater noise

This topic is technically interesting for several of Danish Maritime’s members. A learning phase is scheduled to end in 2026, but it may be extended to 2028. Due to the high workload of MEPC, there was an invitation to submit proposals to SDC 11 & 12. The relationship between energy efficiency measures and underwater noise (URN) is of particular interest, and the aim is to gather experience on the use of MEPC.1/Circ.906/Rev.1 Revised guidelines for the reduction of underwater noise.

Arctic

Work has been ongoing to develop standards for “Polar fuel.” The report from PPR 11 was reviewed, and MEPC 82 invited further proposals regarding polar fuels to be submitted to PPR 12 for further discussion at the upcoming subcommittee meeting. Thus, the work is far from complete.

Slow progress

Overall, it is evident that many considerations must be made in the effort to create broad support, and once again, the meeting week of the consensus-based organization IMO was characterized by very slow progress.

We conclude with a quote from MEPC Chairman Dr. Harry Conway: “If you want to go far, you go together; if you want to go fast, you go alone – but you won’t go far.”

Patience is thus a virtue in our maritime world as well. Dr. Harry Conway was re-elected as Chairman of MEPC 82.