The International Maritime Organization and climate change
What is the IMO?
The International Maritime Organization (IMO) is the UN specialised agency for global shipping, based in London. It sets global safety and security standards for shipping, including the safety of seafarers, and addressing pollution and other environmental impacts caused by shipping. The IMO’s 176 Member States meet regularly to discuss and agree on these standards, with over 100 intergovernmental and non-governmental organisations joining as observers.
International shipping produces around 3% of global greenhouse gas (GHG) emissions annually, mainly through the use of highly polluting fossil fuels. Decarbonising the shipping sector is therefore key to achieving global climate goals.
The IMO’s work on GHG reductions
First decarbonisation measures adopted with energy efficiency regulations.
Member States agree an initial strategy to reduce shipping’s GHG emissions.
IMO strategy on reduction of GHG emissions from ships is revised.
Member States set to approve a basket of mid-term measures to achieve these targets.
IMO set to adopt mid-term measures.
What are MEPC and ISWG meetings?
The Marine Environment Protection Committee (MEPC) is the responsible body for all matters related to the prevention and control of pollution from ships, including reducing GHG emissions from ships. The MEPC meets either once or twice a year, and is made up of all IMO Member States. Decisions are usually made by consensus, based on the Chair’s understanding of the views expressed during negotiations, although it is possible a vote may be requested.
Between MEPC meetings there are sometimes Intersessional Working Group on Reduction of GHG Emissions from Ships (ISWG-GHG) meetings. Because of the large quantity of work that the MEPC is responsible for, a ‘Working Group on GHG Emissions Reductions’ covers the MEPC’s GHG reduction agenda and recommends action to the Committee. This group meets during MEPC meetings or between them, ‘intersessionally’. The latter are the ISWG-GHG meetings.
The 2023 IMO Strategy on Reduction of GHG Emissions from Ships
The IMO’s 2023 Strategy sets emissions reductions targets of:
Reaching net-zero by or around, i.e. close to, 2050.
Meeting interim targets of a 20%,striving for 30%, GHG emissions reduction by 2030 and a 70%,striving for 80%, reduction by 2040.
Ensuring a 5%, striving for 10%, uptake of zero and near-zero GHG emissions technologies, fuels and alternative energy sources by 2030.
Reducing carbon intensity of international shipping by an industry-wide average of 40% by 2030.
The 2023 Strategy not only commits to emissions reductions, it also commits to achieve these goals in line with the principles of a just and equitable transition.
The basket of mid-term measures
The 2023 Strategy also set in motion the process of developing a basket of mid-term measures to achieve its targets. The basket of mid-term measures is set to be approved at MEPC in April 2025, and adopted in October 2025 at an Extraordinary MEPC, in time to enter into force in 2027.
The basket of mid-term measures will consist of two elements:
A technical element, which will consist of a goal-based marine fuel standard regulating marine fuels’ GHG intensity.
An economic element, on the basis of a maritime GHG emissions pricing mechanism.
Since the adoption of the 2023 Strategy, Member States and organisations have worked hard to develop an effective framework for reducing emissions while promoting a just and equitable transition. Four main policy combinations are now under consideration.
| Milestone | Key meetings | Dates |
|---|---|---|
| ISWG-GHG 19 | 31 March — 4 April 2025 | |
| Approval of measures | MEPC 83 | 7 — 11 April 2025 |
| Adoption of measures | ‘Extraordinary’ MEPC | 13 — 17 October 2025 |
| Measures enter into force | 2027 — 16 months after adoption |
To date, the majority of Member States who have voiced a position support a well-to-wake (WTW) Global Fuel Standard (GFS) mechanism combined with a universal price on all of shipping’s GHG emissions (called a ‘levy’ or ‘contribution’), and a reward for use of zero or near zero technologies, fuels and energy solutions. However, a number of States reject the inclusion of a universal price on GHG emissions.
Opportunity Green’s work at the IMO
Supporting climate vulnerable countries
The Climate Diplomacy team drives international policymaking that priorities a just and equitable global maritime decarbonisation, in line with the 1.5°C temperature target of the Paris Agreement. We do this by supporting climate vulnerable countries in negotiations, advocating for ambitious measures to ensure a truly just and equitable global maritime decarbonisation, and amplifying the voices of climate vulnerable change makers. Specifically, we:
Provide technical and capacity support for climate vulnerable countries to help increase their (active) participation;
Engage with countries to support the Voluntary Multi Donor Trust Fund (VMDTF);
Work on Emissions Control Areas (ECAs).
Find out more about our work:
Opportunity Green’s Legal analysis
The OG Legal Team has conducted analysis to strengthen IMO regulations and processes, ensure state and industry compliance with IMO regulation, and hold states accountable to international legal obligations with regards to climate change beyond IMO legislation. Our work includes:
A submission to the IMO highlighting that ships using scrubbers is not enough to satisfy MARPOL Convention air pollution requirements.
A supporting submission to the International Tribunal of the Law of the Sea (ITLOS) stating that States’ legal obligations to the marine environment go beyond the IMO.
A legal report showing that States must go beyond IMO measures to decarbonise shipping in line with their legal obligations under the Paris Agreement.
A legal report on how the UK is in breach of international obligations to reduce climate change by waiting for IMO legislation before decarbonising maritime.
A legal report on how the IMO should regulate upstream emissions from shipping fuels.
A report on the legal implications of a lack of transparency at the IMO and International Civil Aviation Organization (ICAO).
Find out more about our work:
FAQs
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There is no one definition of a just and equitable transition in relation to international shipping, but the term reflects the need for the green maritime transition to be fully global, taking steps to level the playing field and ensuring no one is left behind.
While a ‘just transition’ is usually associated with labour, for example promoting a safe, fair and inclusive environment for seafarers and other maritime workers, the concept of an ‘equitable transition’ relates to the inequalities between countries and communities, including inequalities that stem from the impacts of climate change and measures taken to address climate change.
A just and equitable transition that leaves no one behind requires strong support for developing countries, including small island developing states and least developed countries in the way policies are created and implemented.
Supporting fair and inclusive decision making at IMO negotiations is a crucial part of ensuring a just and equitable transition.
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The MEPC and its Working Group on GHG emissions reductions are responsible for many decisions related to climate change and shipping.
Decisions at these meetings are usually taken by consensus, based on the Chair’s understanding of the views expressed during the meetings. Member States can have their views considered by attending and intervening, and/or making written submissions to the meetings.
Observing organisations can also participate orally or in writing to express their views, however, they would not have a vote in the case one is called.
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The International Convention for the Prevention of Pollution from Ships (MARPOL) is the main international treaty preventing pollution of the marine environment by ships from operational or accidental causes. It includes regulations on the prevention of pollution from oil spills, sewage and garbage, air polluting gases, greenhouse gases and other harmful substances.
Work is currently underway to develop an ‘IMO net-zero framework’, to incorporate the mid-term emissions reduction measures. The draft IMO net-zero framework will add a new Chapter 5 to MARPOL, Annex VI.