Levy-Based Framework Most Likely to Meet IMO Emissions Checkpoints, IMarEST Analysis Finds
Key Takeaways
- •IMarEST has submitted the first comparative analysis of all four proposed IMO Net-Zero Framework options ahead of ISWG-GHG 22 meetings scheduled for September 1-4.
- •A levy-based approach with fixed penalties for non-compliance and subsidies for zero-emission fuel operators is identified as most likely to meet IMO's 2030 and 2040 emissions reduction checkpoints.
- •Maintaining the NZF in its current form could produce the lowest average carbon abatement cost among pricing-based options, provided biofuel prices do not rise significantly before 2038.
- •The research was conducted using modelling from University College London's Energy Institute and the Rocky Mountain Institute, building on methods from the IMO's own Comprehensive Impact Assessment.
- •IMarEST has launched an industry consultation on the effectiveness of current IMO GHG measures, open to stakeholders until September 16.

The Institute of Marine Engineering, Science and Technology (IMarEST) has submitted a series of papers to the International Maritime Organization (IMO) that, for the first time, compare all four proposed Net-Zero Framework (NZF) options side by side.
The submissions come ahead of the 22nd Intersessional Working Group on GHG Emissions from Ships (ISWG-GHG 22), scheduled to meet from September 1–4 as member states work toward agreement on a framework for international shipping. International shipping accounts for approximately 3% of global anthropogenic greenhouse gas emissions, and the sector's regulatory pathway is closely watched by fuel suppliers, shipowners, and cargo interests worldwide.
The analysis evaluates each of the four proposed MARPOL amendment options against the emissions goals set out in the IMO's 2023 GHG Strategy, which calls for reducing total annual GHG emissions from international shipping by at least 20%, striving for 30%, by 2030, and by at least 70%, striving for 80%, by 2040, compared to 2008 levels. It concludes that a levy-based framework is most likely to deliver the 2030 and 2040 emissions reduction checkpoints. Under that option, fixed financial penalties would be imposed on vessels that fail to comply with emissions standards, while subsidies would be reserved for operators using zero or near-zero emission fuels and technologies.
However, the study also finds that keeping the NZF in its current form could yield the lowest average carbon abatement cost among the pricing-based options, provided that significant increases in biofuel prices are avoided before 2038.
The research draws on modelling conducted by University College London's Energy Institute Shipping and Oceans Research Group and the Rocky Mountain Institute.
"This is the first study to model the specifics of all four proposals side-by-side, building on the assumptions and methods used in the IMO's own Comprehensive Impact Assessment of mid-term measures," Dr Tristan Smith, professor of energy and transport at UCL's Energy Institute and head of the IMarEST IMO GHG delegation, said in a statement.
"As negotiations intensify ahead of MEPC 85 at the end of the year, we are hopeful our analysis will help guide IMO member states to a workable solution for the Net-Zero Framework." MEPC 85 — the next regular session of the IMO's Marine Environment Protection Committee, the body responsible for adopting environmental regulations under MARPOL — is where member states are expected to converge on the final NZF architecture.
IMarEST has also launched an industry consultation on the effectiveness of current IMO GHG measures, open until September 16 to individuals and organisations with a stake in maritime decarbonisation.
"By bringing together the views of engineers, scientists and technologists, we can help ensure the Institute's contributions at the IMO continue to reflect our sector's expertise and experience," said Alasdair Wishart, director of technical and policy at IMarEST.
Source: Ship & Bunker