IMSML Web Article 18/2026: Malaysian Shipping Notice (MSN) 06/2025 Introducing Resolution MEPC.403(83) - Amendments to the 2022 Guidelines on Survey and Certification of the Energy Efficiency Design Index (EEDI) - The Regulations: Regulations 30-46 (Part 2 of 3)
This article is a continuation of the previous article on MEPC.403(83). Regulation 30 onwards contains provisions on Chapter 5, Regulations on IMO’s Net-Zero Framework.
What does Regulation 30 apply to?
All ships of 5000 gross tonnage and above, see Regulation 30.1.
What is the Goal?
Reduction of greenhouse gas (GHG) emissions from international shipping as soon as possible, by delivering on the reduction targets set out in the 2023 IMO Strategy on Reduction of GHG Emissions from Ships, see Regulation 31. The provisions also promote energy transition of shipping and providing the world’s fleet with incentive whilst contributing to a level playing field and a just and equitable transition.
What are the Functional Requirements under Regulation 32?
[1] Continuous improvement of the ship’s GHG fuel intensity, see Regulation 32.1.
[2] GHG emissions pricing contributions for excess emissions and rewards for the uptake of zero or near-zero GHG emissions technologies, see Regulation 32.2.
What is the Attained Annual GHG Fuel Intensity (ie Attained Annual GFI)?
Calculation of the GFI for each ship, over a 12 month period from 1 January to 31 December, starting from the end of calendar year 2028, and after the end of each subsequent calendar year thereafter, using data collected and IMO guidelines, see Regulation 33.1. The calculation is o be made in accordance with the formula provided in Regulation 33.2, taking into account:
[1] Fuel type;
[2] Total number of fuels used during the reporting period;
[3] GHG intensity expressed on a well-to-wake basis of a fuel type;Energy consumption of fuel type;
[4] Total amount of energy used by the ship in the the reporting period. Note, this is not limited to fuel oil, electricity delivered from shore power and zero-emission energy sources (such as wind propulsion and solar power).
What are Sustainable Fuels Certification Schemes?
This is calculated using GHG emission factors and take into account all relevant metrics and indicators as documented in the Fuel Lifecycle Label(s) (ie FLL), see Regulation 34.1. The FLL shall be certified by the appropriate recognised Sustainable Fuels Certification Schemes (SFCS) taking into account IMO Guidelines, see Regulation 34.2.Certifies in information in the FLL may accompany bunker delivery notes, see Regulation 34.3.
Renewal of SFCS are subject to renewal every 5 years and periodic review, see Regulation 34.4. The Secretary General of IMO shall publish a list of recognised SFCSs by 1 March 2027, see Regulation 34.5. Note, that this list shall be updated periodically.Within 3 months of the following calendar year (starting the end of 2027), recognised SFCS should report data of their relevant activity for the calendar year (or portion thereof) to ensure transparency, traceability and environmental integrity in the certification process, see Regulation 34.6.
What is the Target Annual GHG Fuel Intensity (Target Annual GFI)?
Regulation 35 provides for a base target and a direct compliance target, which is listed in Table 4 starting from 2028 to 2035, see Regulation 35.2. For 2036 to 2040, the IMO Committee shall determine the Z-Factor target. For 2040 onwards the base target shall be set at 65 percent, see Regulation 35.3.
What are the Annual GFI Compliance Approaches?
The GFI Compliance should be equal to the Direct compliance target annual GFI minus the Attained Annual GFI, multiplied by the Total Energy, see Regulation 36.1. If the GFI compliance balance is equal to or greater than zero, the ship is in direct compliance. The ship is therefore eligible to receive surplus units for its positive compliance balance, see Regulation 36.2. However, if the GFI compliance balance is less than zero, the ship is technically in compliance deficit, see Regulation 36.3.
How is Compliance Deficit Assessed?
For Tier 1 compliance deficit, it is done through remedial units acquired by means of GHG emissions pricing contributions to the IMO Net-Zero Fund, priced at benchmarked rates, see Regulation 36.5. For Tier 2 compliance deficit, the following can be taken into account under Regulation 36.6:
[1] Surplus units transferred from other ships, see Regulation 36.2.1;
[2] Surplus units banked from previous reporting periods (see Regulation 36.6.2); AND/OR …
[3] Remedial units acquired by means of GHG emissions pricing contributions to the IMO Net-Zero Fund priced at Tier 2 benchmark rates, see Regulation 36.6.3.
Details on ‘remedial units; can be found in Regulation 36.8 to 36.10. Whilst ‘surplus units’ are governed by Regulation 36.11 to 36.15.
How is Reporting and Verification of the Annual GFI performed?
The attained annual GFI, the target annual GFI and the the GFI compliance balance of the ship shall be reported to IMO in the standardised format for the purposes of verification within 3 months after the end of each calendar year starting 2028, and by 31 March after each reporting period thereafter, see Regulation 37.1.
Verification will be performed by IMO with 6 months after the end of 2028 and by 30 June o after each following reporting period, see Regulation 37.3. Within a month after verification, the details shall be recorded in the IMO GFI Registry, see Regulation 37.4.
How Does the IMO GFI Registry Operate?
The Registry was established by the Secretary General, see Regulation 38.1. By 1 October 2027 each ship should have an account and shall pay by 30 June 2028, and by 30 June of each year thereafter, the annual administration fee, see Regulation 38.2. The level of the fees payable is set to cover the administrative cost, see Regulation 38.3.
The Registry deals with surplus units and credit renewal units, see Regulation 38.4. A statement shall be issued by the Registry for each account reflecting all the transactions by 31 August after the end of each reporting period, see Regulation 38.5
Under Regulation 38.6, the Registry shall record the following:
[1] The ship account statement;
[2] Verified attained annual GFI;
[3] Total energy consumption;
[4] GHG emissions avoided;
[5] Statement of compliance related to the annual GHG fuels intensity;
[6] Any other information, taking into account IMO Guidelines.
Any organisation authorised by IMO shall be granted access to all recorded data in the account of the ships, see Regulation 38.7.
The Secretary General shall produce an annual report to the Marine Environment Protection Committee (MEPC)), see Regulation 38.9.
What is the Uptake of Zero or Near-Zero (ZNZ) GHG Emission Technologies, Fuels and/or Energy Sources?
ZNZs includes technologies, fuels and energy sources that are evaluated on a well-to-wake basis, see Regulation 39.1. Ships may receive rewards from the IMO Net-Zero Fund for ZNZs used, see Regulation 39.2. The reward shall be defined no later than 1 March 2027 and every five years thereafter, see Regulation 39.3. IMO has a duty to publish and share the ZNZs information the total annual energy used on board ships, see Regulation 39.4.
What is the IMO Net-Zero Fund?
The Fund receives and manages GHG emissions pricing contributions made by ships and where necessary, disburse the collected revenue, see Regulation 40.2. The Governing Board oversees day to day operations of the Fund, see Regulation 40.3. The Fund determines entities which may be eligible to received funds and the types of financing mechanisms by which funds may be disbursed, see Regulation 40.4.
The Governing Board shall have a gender and geographically balanced composition, see Regulation 40.5. The Fund shall be subjected to audits, see Regulation 40.8.
How is Revenue Disbursed under IMO’s Net-Zero Fund?
[1] Rewards for use of ZNZ, see Regulation 41.1;
[2] Promotion of an equitable transition by facilitating environmental and climate protection, see Regulation 41.2;
[3] Research and development of ZNZ technologies, see Regulation 41.1.2.1;
[4] Facilitation of information sharing, technology transfer and capacity building, see Regulation 41.1.2.3;
[5] Supporting and implementation of National Action Plans (NAPs), including fleet renewal and upgrade, see Regulation 41.1.2.4;
[6] Addressing disproportionately negative impacts, including food security, see Regulation 41.1..2.5.
How is Technical Cooperation and Transfer of Technology Relating to Continuous Improvement of a Ship’s GHG Fuel Intensity Promoted?
Cooperation, promotion and appropriate support of other organisations other than IMO, see Regulation 42.1. This cooperation (in particular with developing States) shall be subject to national laws, regulations and policies, see Regulation 43.2.
How are Food Security Concerns Addressed?
There is a duty to address this issue under Regulation 43.1, including keeping the potential impacts under continuous review, see Regulation 43.2.
How Often Should a Review Take Place?
Every five years, see Regulation 44.1.
How is Verification of Compliance Conducted?
Through periodic audits, see Regulation 48.1. This will be conducted by the Secretary General, see Regulation 46.2. The audits will be based on a schedule developed by the Secretary General, see Regulation 46.4.1.
Thank you for reading IMSML Web Article 18/2026
Stay tuned for the next IMSML Web Article 19/2026: IMSML Web Article 19/2026: Malaysian Shipping Notice (MSN) 06/2025 Introducing Resolution MEPC.403(83) - Amendments to the 2022 Guidelines on Survey and Certification of the Energy Efficiency Design Index (EEDI) - The Appendices (Part 3 of 3)
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
Faculty of Law
Universiti Teknologi MARA Shah Alam
Selangor, Malaysia
Tuesday, 5 May 2026
Note that I am the corresponding author for the IMSML Website Articles. My official email address is: uijoo310@uitm.edu.my