Japan’s MEPC 84 submission: risks to IMO’s Net-Zero Framework

Background  

Japan’s submission to MEPC 84 proposes options that could drastically weaken the IMO’s Net-Zero Framework (NZF). The two options outlined by Japan, (1) removal of mandatory payments to the Net-Zero Fund and (2) revision of GHG Fuel Intensity (GFI) targets, would remove the stable and predictable economic elements of the NZF.    

The submission from Japan offers these two options as a way to address concerns from a number of Member States at ES.2, namely, opposition to a perceived ‘global carbon tax’ and the IMO Net-Zero Fund, and concerns about the feasibility and stringency of GFI targets, particularly their potential to effectively exclude LNG as a compliant fuel. 

What’s covered in the briefing? 

The briefing outlines key implications of Japan’s submission for effective decarbonisation of international shipping, by highlighting how it: 

• Undermines the economic backbone of the NZF, weakening the demand signal.

• Creates an unstable and potentially imbalanced compliance system.

• Introduces significant uncertainty for industry and investment planning. 

• Fails to support a just and equitable transition.

• Risks weakening ambition and delaying decarbonisation.

• Enables continued reliance on fossil-based pathways.

• Erodes a hard-fought multilateral compromise.

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Read also our IMO negotiation briefing: April 2026.