Tuvalu has submitted the most stringent set of amendments under consideration for adoption at the International Maritime Organization's Marine Environment Protection Committee (MEPC 85) session in November, seeking to tighten compliance costs and accelerate emissions pricing for international shipping. The small Pacific island nation, which is among the countries most exposed to sea-level rise, has consistently positioned itself at the forefront of climate ambition within the UN body that regulates international shipping — a sector that accounts for approximately 3% of global greenhouse gas emissions.

The Net-Zero Framework (NZF), approved at MEPC 83 in April 2025, established a two-tier greenhouse gas fuel intensity (GFI) standard. It requires vessels of 5,000 gross tonnage (GT) and above to progressively reduce well-to-wake GHG emissions beginning in 2028, measured against a 2008 baseline of 93.30 grams of CO2-equivalent per megajoule (gCO2e/MJ). Reduction targets include a base target and a direct compliance target, spanning 4–17% in 2028 and tightening to 30–43% by 2035.

Under Tuvalu's proposal, the base targets would remain unchanged, but the 2028 step would be eliminated, with reductions starting at 6% in 2029 rather than 4% in 2028. The direct compliance target would be set at 100% from 2029 through 2035 — a level no vessel could realistically achieve — effectively ensuring that every tonne of emissions carries a price. This would transform the framework into what is functionally a carbon levy.

These recommendations align with a prior joint submission to MEPC 84 in April from Fiji, Kiribati, Nauru, Palau, Tuvalu, and Vanuatu. Pacific island states have argued that the MEPC 83 framework, while a landmark as the IMO's first binding emissions pricing mechanism, does not go far enough or fast enough to align shipping with the Paris Agreement temperature goals.

Tuvalu also proposes raising the Tier 1 remedial unit price to $300 per metric tonne of CO2-equivalent ($300/mtCO2e) — triple the $100/mtCO2e figure agreed in principle at MEPC 83. The Tier 2 remedial unit price, applicable to emissions exceeding the base target, would remain at $380/mtCO2e.

Additionally, the proposal would abolish the surplus unit mechanism in full. Ships that outperform required GFI targets would no longer receive surplus units to sell to non-compliant vessels. Instead, any deficit would be settled exclusively through direct payments into the IMO Net-Zero Fund.

The amendments are scheduled for discussion at the intersessional Working Group on Reduction of Greenhouse Gas Emissions from Ships (ISWG-GHG) meetings in September and November, prior to formal consideration at MEPC 85, which runs from 30 November to 3 December. The range of proposals on the table spans from Tuvalu's maximum-ambition approach to less stringent alternatives favored by other member states, and the intersessional negotiations will determine which elements make it into the consolidated text.

Should member states converge on a final text, the amendments could be formally adopted at the second extraordinary session of the MEPC (MEPC ES.2). That session was adjourned in October 2025 and is expected to reconvene on 4 December.

Source: By Konica Bhatt, ENGINE,