White Paper on 2023 IMO Greenhouse Gas Strategy

Earlier this month, over 170 member states of the International Maritime Organization (IMO) met in London for the 80th session of the IMO’s Marine Environment Protection Committee (MEPC 80). The most significant outcome of MEPC 80 is a dramatic revision to the IMO’s initial strategy, adopted in 2018, for reducing the emission of greenhouse gases (GHG) in international shipping. The new strategy, unanimously approved by member states, establishes the ambitious goal of net zero GHG emissions from ships by or around the year 2050. The 2023 IMO Strategy on Reduction of GHG Emissions From Ships (2023 IMO GHG Strategy) further commits to ensure an uptake of alternative zero and near-zero GHG fuels by 2030 and imposes indicative checkpoints for 2030 and 2040.

While MEPC 80 adopted many other important measures addressing protection of the marine environment – which target such matters as ship energy efficiency, ballast water management, biofouling management, particularly sensitive sea areas, and underwater radiated noise – this presentation will focus on summarizing the revised strategy on reducing GHG emissions. 

 The MEPC initially adopted a strategy for reducing GHG emissions in international shipping when it met in 2018 at MEPC 72. The initial strategy was in part the response to a study conducted by the IMO in 2014 which estimated that GHG emissions from international shipping in 2012 accounted for 2.2% of anthropogenic CO2 emissions and that such emissions could grow by between 50% and 250% by 2050. The 2018 Initial IMO Strategy on the Reduction of GHG Emissions From Ships aimed to phase out GHG emissions from international shipping by the end of this century. More specifically, MEPC 72 set the goal of reducing total annual GHG emissions by at least 50% by 2050, compared to 2008; along with enumerated interim reduction benchmarks and goals. The overall vision of MEPC 72 was “reducing GHG emissions from international shipping and, as a matter of urgency, aim[ing] to phase them out as soon as possible in this century.” MEPC 72 recognized that this initial GHG emissions strategy will be revised by a strategy to be adopted in 2023.

In anticipation of revising its initial GHG emissions strategy, the IMO conducted further study in 2020 on GHG emissions from shipping and the corresponding environmental impacts of such emissions. That study estimated that GHG emissions from shipping in 2018 accounted for 2.89% of global anthropogenic GHG emissions and that such emissions could represent between 90% and 130% of 2008 emissions by 2050. 

The Paris Agreement, adopted by 196 nations at the United Nations Climate Change Conference (COP21) in Paris in 2015, and twice reaffirmed – in the Glasgow Climate Pact at COP 26 and in the Sharm el-Sheikh Implementation Plan at COP 27 – also provided significant background for MEPC 80. The Paris Agreement, which is a legally binding international treaty on climate change that entered into force in 2016, strives to hold the increase in the global average temperature to below 2°C above pre-industrial levels and to pursue efforts to limit overall temperature increase to 1.5°C above pre-industrial levels. The treaty recognizes that meeting these goals would significantly reduce the risks and impacts of climate change.  

Particularly sensitive sea areas (PSSAs) – MEPC 80 resolved to designate a PSSA in the North-Western Mediterranean Sea to protect cetaceans from international shipping. Designating an area as a PSSA comes with associated protective measures (APMs), which are recommendary in nature, to protect certain aquatic life that in the area. APMs include navigating with caution, reducing speed, keeping an appropriate distance from cetaceans, and reporting any collisions to designated coastal authorities. 

Underwater radiated noise (URN) – MEPC 80 approved guidelines providing for the reduction of URN. These guidelines provide sample templates to assist shipowners with the development of an URN management plan and include updated technical knowledge, including reference to international measurement standards, recommendations, and classification society rules. The Committee also approved guidelines developed by the Inuit Circumpolar Council for URN reduction in Inuit Nunaat and the Arctic, where sound levels are lower and sea life is more vulnerable to industrial activity. 

Other measures – MEPC 80 addressed other guidelines aimed at tackling climate change and pollution. These measures include developing recommendations for the carriage of plastic pellets by sea in freight containers and other marine litter, and for the environmental risks of ship-to-ship transfer. MEPC 80 also set effective dates for the protection of the Red Sea and the Gulf of Aden under MARPOL Annexes I and V, which define certain sea areas as “special areas” in which the adoption of special mandatory methods for the prevention of sea pollution is required due to their oceanographical and ecological makeup. 

“The adoption of the 2023 IMO Greenhouse Gas Strategy is a monumental development for IMO and opens a new chapter towards maritime decarbonization,” said IMO Secretary-General Kitack Lim. “At the same time, it is not the end goal, it is in many ways a starting point for the work that needs to intensify even more over the years and decades ahead of us. However, with the Revised Strategy that you have now agreed on, we have a clear direction, a common vision, and ambitious targets to guide us to deliver what the world expects from us. . . . Above all, it is particularly meaningful, to have unanimous support from all Member States. In this regard, I believe that we have to pay more attention to support developing countries, in particular SIDS and LDCs, so that no one is left behind.” 

While the 2023 IMO GHG Strategy identifies forthcoming measures in the coming years, a number of questions remain unanswered. The implications for trade for SIDS and LDCs, who heavily depend on imports for basic necessities and are at the mercy of high shipping costs, are unclear. The disproportionately negative impacts that may befall SIDS and LDCs may depend upon how developed member states and shipping industry participants respond to the Strategy. One forthcoming measure is the IMO’s Comprehensive Impact Assessment of MEPC 80 to MEPC 82, which will provide more detail in the addressing of these adverse consequences. MEPC 83 will approve and adopt the mid-term measures, which will enter into force sometime in 2027. 

The 2023 IMO GHG Strategy is subject to review every five years, and will be revisited at MEPC 88 through anticipated adoption of a 2028 IMO GHG Strategy. The review will take into account updated emission estimations, available data, and reduction options for international shipping. 

The 2023 IMO GHG Strategy is further criticized for boasting a “just and equitable transition” that leaves no country behind when the Strategy lacks any financial support for climate-vulnerable nations who have struggled to attend IMO meetings due to resource limitations. There were 12 delegations from climate vulnerable nations who were able to attend MEPC 80 with the benefit of donations from the Voluntary Multi-Donor Trust Fund, established to provide financial support for technical co-operation and capacity-building activities to implement IMO goals. However, out of a total of 175 IMO member states, only two extended contributions to the Fund, illustrating in the eyes of critics how little concern member states have towards fostering equitable change on a global scale.

Critics also rebuke the 2023 IMO GHG Strategy for failing to align with the 1.5°C Paris Agreement temperature goal. Ana Laranjeira, shipping manager at environmental justice NGO Opportunity Green, said in a press statement: “This week had everything to be a historical moment. The last chance for the IMO to align with the Paris Agreement temperature goal of 1.5°C, vital to secure a just and equitable transition for the world’s most vulnerable nations, and protect our global biodiversity, such as the world’s coral reefs which will cease to exist in a world above this temperature threshold... This agreement does not get us anywhere near to 1.5°C. We need to continue to work to decarbonize international shipping in a just and equitable manner as soon as possible.”