IMSML Website Article 13/2025: Resolution MEPC.377(80) - 2023 IMO Strategy on Reduction of GHG Emissions from Ships (2023 IMO GHG Strategy)
Work to address greenhouse gases (GHG) has been undertaken by IMO since Conference Resolution 8 (September 1997) on ‘CO2 Emissions from Ships’, see MARPOL Annex VI on the mandatory technical and energy efficiency measures. This morphed into a strategic direction to ‘Respond to Climate Change’ in December 2017 and 2021.
Therefore, Resolution MEPC.377(80) is not a new initiative. Prior to this, the MEPC at its 72 Session, has passed Resolution MEPC.304(72) on the ‘Initial IMO Strategy on Reduction of GHG Emissions from Ships, ie more popularly among IMO stakeholders as ‘Initial IMO GHG Strategy’. The resolution is part of a larger package of climate change measures and is a part of the UN’s 2030 Agenda for Sustainable Development, and the Paris Agreement adopted at the UN Climate Change Conference (COP21), re-affirmed at the Glasgow Climate Pact (COP26) and the Sharm el-Sheikh Implementation Plan (COP27).
Resolution MEPC.377(80) adopted on 7 July 2023 is set out in the Annex of the Resolution, see Annex 15, p 2. It was introduced in Malaysia via Malaysian Shipping Notice (MSN) 14 / 2023.
SECTION 1 - INTRODUCTION
What does the 2023 IMO GHG Strategy represent? A continuation of work by IMO as the appropriate international body to address GHG emissions from international shipping, continuing Assembly Resolution A.963 on IMO Policies and Practices times Related to the Reduction of Greenhouse Gas Emissions from Ships, adopted on 5 December 2023, see Paragraph 1.2.
What was IMO’s first milestone? Resolution MEPC.304(72) on the ‘Initial IMO Strategy on Reduction of GHG Emissions from Ships’. This was set out by MEPC 70 in its ‘Road Map for Developing a Comprehensive IMO Strategy on Reduction of GHG Emissions from Ships’ (ie The Road Map). This Road Map identified a revised strategy that was to be adopted in 2023.
What is the latest milestone set out in ‘The Road Map’? 2023 IMO GHG Strategy as set out in Resolution MEPC.377(80), adopted on 7 July 2024, which is the main focus of this article.
What is the broader context in which the 2023 IMO GHG Strategy operates? Paragraph 1.6 identifies the following:
[1] UNCLOS and UNFCCC, and its related legal instruments (including the Paris Agreement), see Paragraph 1.6.1;
[2] IMO playing a lead role in environmental regulations for international shipping, see Paragraph 1.6.2;
[3] Strategic direction entitled ‘Respond to climate change’ by Assembly (A32) in December 2021, see Paragraph 1.6.3;
[4] UN 2030 Agenda for Sustainable Development, see Paragraph 1.6.4.
What are the relevant levels of GHG emissions from shipping?
[1] 2012 - It is estimated International shipping in 2012 accounted for some 2.2 percent of anthropogenic CO@ emissions. Such emissions could grow between 50 percent and 250 percent by 2050, see Paragraph 1.7;
[2] 2020 - In 2020, the 4th IMO GHG Study estimated that GHG emissions from shipping in 2018 accounted for 2.89 percent of global anthropogenic GHG emissions. Such emission could represent between 90 percent and 130 percent of 2008 emissions by 2050, see Paragraph 1.8;
How can uncertainties associated with emission estimates be reduced? In the future, annual IMO emission and carbon intensity estimates will bear using the available data from the ‘IMO Ship Fuel Oil Consumption Database’ (IMO DCS), see Paragraph 1.9.
What are the 3 main objectives of the 2023 IMO GHG Strategy? Paragraph 1.10 lists down the following:
[1] Enhancing IMO’s international efforts in addressing GHG emission, see Paragraph 1.10.1;
[2] Identifying the critical role of international shipping in the continued development of global maritime trade, see Paragraph 1.10.2;
[3] Identifying appropriate measures for research, development and monitoring of GHG from shipping, see Paragraph 1.10.3.
SECTION 2 - VISION
What is IMO’s commitment? Reducing GHG emissions from international shipping.
What is a matter of urgency for IMO? To phase out GHG emissions as soon as possible.
What is IMO promoting? A just and equitable transition.
SECTION 3 - LEVELS OF AMBITION, INDICATIVE CHECKPOINTS, AND GUIDING PRINCIPLES
What is IMO’s level of ambition? Zero or near zero GHG emissions technologies being integral to international shipping, see Paragraph 3.1. The following levels of ambition are addressed directly under the 2023 IMO GHG Strategy (see Paragraph 3.3):
[1] Energy efficiency got new ship, see Paragraph 3.3.1;
[2] Declining carbon intensity of international shipping, see Paragraph 3.3.2;
[3] Uptake of zero or near-zero GHG emission technologies, fuels and/or energy sources to increase, see Paragraph 3.3.3;
[4] GHG emission from international shipping to reach net zero, see Paragraph 3.3.4.
Why is working within the framework of the ‘Guidelines on Life Cycle GHG Intensity of Marine Fuels (LCA Guidelines)’ important to the objective of reducing GHG emissions? These Well-to-Wake GHG emissions should be prevented from shifting of emissions to other sectors, see Paragraph 3.2.
What are the indicative checkpoints to reach net-zero GHG emissions from international shipping? The following are the indicative checkpoints to reach net-zero GHG emissions from international shipping, ie to reduce the total annual GHG emissions from international shipping, compared to 2008 (see Paragraph 3.4):
[1] By at least 20 percent, striving for 30 percent by 2030, see Paragraph 3.4.1;
[2] By at least 70 percent, striving for 80 percent, by 2040, see Paragraph 3.4.2.
What are the guiding principles for the 2023 IMO GHG Strategy? Paragraph 3.5 identifies 5 specific strategies:
[1] Non-discrimination and no more favourable treatment, see Paragraph 3.5.1.1;
[2] Principled of common but differentiated responsibilities and respective capabilities due to different national circumstances, see Paragraph 3.5.1.2;
[3] Implementation of mandatory measures regardless of flag, see Paragraph 3.5.2;
[4] Impact of measures on States, eg developing countries, of specific emerging needs, see Paragraph 3.5.3;
[5] Evidence-based decision making balanced with the precautionary approach, see Paragraph 3.5.4.
SECTION 4 - CANDIDATE SHORT, MID AND LONG TERM GH REDUCTION MEASURES WITH POSSIBLE TIMELINES AND THEIR IMPACTS ON STATES
What timelines should candidate measures be consistent with? The following are specified by Paragraph 4.1:
[1] Appendix 1 short-term GHG reduction measures to be finalised and agreed between 2018 and 2023, see Paragraph 4.1.1;
[2] Mid-term GHG reduction measures to be finalised and agreed by 2025 (ie this should be measures which could start to reduce GHG emission and defined to the basket to for each measure individually), see Paragraph 4.1.2;
[3] Other candidate mid-term GHG reduction measures to be finalised and agreed between 2023 and 2030, see Paragraph 4.1.3;
[4] Possible long term measures to be finalised and agreed beyond 2030, ie to be developed as part of the 2028 review of the IMO GHG Strategy, see Paragraph 4.1.4.
Is the list of candidate measures exhaustive? No, it is non-exhaustive and is without prejudice to measures IMO may further consider and adopt, see Paragraph 4.2.
Is there a deadline for a review of the mandatory goal-based technical and operational measures to reduce carbon intensity of international shipping (ie short term GHG reduction measures)? The completion deadline is 1 January 2026, and to be conducted in accordance with Regulations 25.3 and 28.11 of MARPOL Annex VI, see Paragraph 4.3.
What does the basket of candidate measure(s) deliver on reduction targets? Development of a Work Plan for delivery of the Strategy in accordance with the envisaged timelines, see Paragraph 4.5. This encompasses two matters:
[1] A technical element - A goal based marine fuel standard regulating the phased reduction of the marine fuel’s GHG intensity (see Paragraph 4.5.1); AND …
[2] An economic element - The basis of a maritime GHG emissions pricing mechanism (see Paragraph 4.5.2).
How are the candidate economic elements assessed? By observing specific criteria to be considered in the comprehensive impact assessment, with a view to facilitating the finalisation of the basket of measures, see Paragraph 4.5.
What is the basis of mid-term GHG reduction measures? The following are identified in the last sentence of Paragraph 4.5:
[1] Promote the energy transition of shipping;
[2] Provide the world fleet with a needed incentive on a level playing field;
[3] Ensuring [2] above is a just and equitable transition.
What is in PHASE III of the Work Plan? Development of measures in the basket, its adoption and assessment of impacts on States, see Paragraph 4.6.
What should be taken into account for the development of the basket of candidate mid-term GHG reduction measures? Paragraph 4.7 provides for the following:
[1] Take into account the Well-to-Wake GHG emissions of marine fuels as addressed in the LCA Guidelines developed by tIMO;
[2] This should be the overall objective of reducing GHG emissions within the boundaries of the energy system of international shipping;
[3] A shift of emissions to other sectors should be prevented.
Should the potential synergies with other existing measures such as the Carbon Intensity Indicator (CII) be considered? Yes, in particular regarding the following (see Paragraph 4.8):
[1] Incentives for energy efficiency;
[2] Adoption of better operational practices in the shipping value chain;
[3] Other technologies for reduction of emissions from ships.
What are the other candidate mid-term GHG reduction measures to reduce GHG emissions from ships? Paragraph 4.9 identifies the following:
[1] Informed policy making:
[a] Undertaking emission and carbon intensity estimates, using available data from IMO DCS and other relevant sources (an any other studies to inform policy decisions), see Paragraph 4.9.1;
[b] Feedback mechanism to be developed to enable lessons learned on implementation of measures to be collated and shared through a possible information exchange on best practice, see Paragraph 4.9.2.
[2] Uptake of zero or near-zero GHG emission technologies, fuels and/or energy sources by supporting a global availability:
[a] Further development of the LCA guidelines, see Paragraph 4.9.3;
[b] Assessment of regulatory aspects associated with reducing GHG emissions. This should be a road map to support the safe delivery of the Strategy, see Paragraph 4.9.4;
[c] Emissions of methane and nitrous oxide should be considered and analysed, see Paragraph 4.9.5;
[d] Development and up take of new technologies via incentives for first movers, see Paragraph 4.9.6;
[e] Encourage port development and activities to facilitate global reduction of GHG emissions from shipping. This includes the following (see Paragraph 4.9.7):
[i] Provision of ship and shoreside/onshore power supply from renewable sources;
[ii] Infrastructure to support supply of zero or near-zero GHG emissions fuels and/or
energy sources;
[iii] Further optimize the logistics chain and its planning, including ports.
Should particular attention be given to the needs of developing countries? Yes, in particular for LDCs and SIDS. The impact on States of a measure, should be assessed and taken into account as appropriate before the adoption of measures, see Paragraph 4.10 The comprehensive impact assessment in order to inform further consideration of the proposed measures(s), and to take appropriate action, see Paragraph 4.11.
What following areas should the impact of the measures be assessed on? Paragraph 4.12 lists down the following areas:
[1] geographic remoteness of and connectivity to main markets, see Paragraph 4.12.1;
[2] cargo value and type, see Paragraph 4.12.2;
[3] transport dependency, see Paragraph 4.12.3;
[4] transport costs, see Paragraph 4.12.4;
[5] food security, see Paragraph 4.12.5;
[6] disaster response, see Paragraph 4.12.6;
[7] cost-effectiveness, see Paragraph 4.12.7; AND …
[8] socio-economic progress and development, see Paragraph 4.12.8.
When can measures be considered for adoption? Upon completion of the comprehensive impact assessment, and the disproportionately negative impacts assessed and addressed, see Paragraph 4.13.
What happens after a measure is adopted and enacted? IMO should keep its implementation and impacts under review. Any necessary adjustments may be made upon request by an IMO member state, see Paragraph 4.14.
SECTION 5 - BARRIERS AND SUPPORTIVE ACTIONS, CAPACITY-BUILDING AND TECHNICAL COOPERATION, AND R&D
Is there recognition of the challenges that some developing countries face, in particular LDCs and SIDs on GHG-related matters?
Yes, IMO should periodically assess the provision of financial resources through the Voluntary Multi-Donor Trust Fund established for the purpose of assisting developing countries (in particular LDCs and SIDS). Particular emphasis is given to attending the settings of MEPC and the Inter-sessional Working Group on Reduction of GHG Emission (ie ISWG-GHG), see Paragraph 5.2.
What should be given due consideration when developing mid and long term GHG reduction measures? Supportive measures that ensure a just and equitable transition is necessary to ensure that no country is left behind, see Paragraph 5.3.
Is there recognition that there could be specific barriers to the implementation of possible measures? Yes, especially when developing and making globally available zero and near-zero GHG emission technologies, fuels and/or energy sources, and developing the necessary associated port infrastructure, see Paragraph 5.4.
Is there a need for a broad approach to regulating the safety of ships? Yes, using zero or near zero GHG emissions technologies, fuels and/or energy sources. This includes addressing the human element, to ensure the safe implementation of this Strategy, see Paragraph 5.4.
Will the Strategy have an impact on seafarers and other maritime professionals? Yes, instruments need to be assessed, including guidance and training standards to help ensure a just transition for seafarers, so that no one in the maritime workforce gets left behind, see Paragraph 5.6.
Why is facilitating public private-partnerships and information exchange important? To promote zero and near-zero GHG emission technologies, fuels and/or energy sources, see Paragraph 5.7.
What mechanisms should be facilitated? IMO should continue facilitating mechanisms for facilitating information sharing, technology transfer, capacity-building and technical co-operation, see Paragraph 5.8.
Is decarbonisation in shipping possible for all IMO member states? Yes, and it may create new opportunities for developing countries, including LDCs and SIDS, to take part in the value chain of the the production and distribution of zero and near-zero GHG emission technologies, fuels and/or energy sources for international shipping, see Paragraph 5.9.
Should IMO assess periodically the provision of financial and technological resources and capacity-building? Yes, to implement the Revised Strategy through the Integrated Technical Cooperation Programme (ITCP), the IMO GHG TC-Trust Fund and other initiatives, including both IMO and Member States-sponsored programmes (in Appendix 2), see Paragraph 5.10.
What additional measures may IMO implement? Paragraph 5.11 identifies the following:
[1] Developing programmes to support the training and skilling of seafarers to support GHG emissions reduction from ships, see Paragraph 5.11.1;
[2] Initiate R7D activities and pilots to enhance energy efficiency of ships, global availability, and uptake of low-carbon / zero-carbon fuels and technologies, see Paragraph 5.11.2;
[3] Support enhanced technical cooperation, capacity building activities, technology cooperation, and the implementation of existing short-term GHG Reduction measures, see Paragraph 5.11.3;
[4] Initiate availability of renewable fuel production, especially in developing countries, see Paragraph 5.11.4.
SECTION 6 - FOLLOW UP ACTIONS
Key stages to the adoption of a 2028 IMO GHG Strategy are classified as follows under Paragraph 6.2:
[1] Target dates;
[2] Milestones:
[a] Comprehensive impact assessment of the basket of candidate mid-term measures;
[b] Development of candidate mid-term measures;
[c] Other milestones.
Should the Marginal Abatement Cost Curve (MACC) for each measure be ascertained and updated? Yes, the evaluation should be conducted on a regular basis, as appropriate, see Paragraph 6.3.
SECTION 7 - PERIODIC REVIEW OF THE STRATEGY
How soon should a review of IMO’s GHG Strategy be conducted? It should be subjected to. A 5-yearly review. The first review is due in 2028, see Paragraph 7.1.
What should IMO do when it undertakes the review? Define the scope of the review and its terms of reference, see Paragraph 7.2.
What should reviews of the levels of ambition take into account? Paragraph 7.3 stipulates the following:
[1] Updated emission estimates;
[2] Emission reduction options;
[3] Availability for international shipping;
[4] Reports of the Intergovernmental Panel on Climate Change (IPCC);
[5] Future IMO GHG inventories;
[6] Studies (as relevant) to assess progress towards reaching net-zero GHG emissions of international shipping.
THE APPENDICES
APPENDIX 1 - This Appendix provides an overview of the work undertaken by IMO to address GHG emission from ships.
APPENDIX 2 - This Appendix provides an overview of relevant initiatives by IMO to support the reduction of GHG Emissions from ships.
Thank you for reading IMSML Website Article 13/2024
Stay tuned for the next IMSML Website Article 14/2025: Resolution MEPC.378(80) - 2023 Guidelines for the Control and Management of Ships’ Biofouling to Minimise the Transfer of Invasive Aquatic Species
Signing-off for today,
Dr Irwin Ooi Ui Joo, LL.B(Hons.)(Glamorgan); LL.M (Cardiff); Ph.D (Cardiff); CMILT
Professor of Maritime and Transport Law
Head of the Centre for Advocacy and Dispute Resolution
Faculty of Law
Universiti Teknologi MARA Shah Alam
Selangor, Malaysia
Tuesday, 1 April 2025
Note that I am the corresponding author for the IMSML Website Articles. My official email address is: uijoo310@uitm.edu.my