Key takeaways
IMO delays adoption of net zero framework
Consensus building remains critical for global shipping goals.
Industry faces uncertainty on emissions targets
Stakeholders urged to prepare for stricter future measures.
Collaboration is key to achieving maritime decarbonisation
Shared strategies will drive compliance and innovation.
IMO’s Net-Zero Framework: adoption adjourned, and consensus building continues
On 14 to 17 October 2025, the Marine Environment Protection Committee (MEPC) of the International Maritime Organisation (IMO) met for its second extraordinary session in person at IMO headquarters in London.
The discussions were focused on issues relating to the Net-Zero Framework (NZF), which comprises a new set of regulations aimed at reducing greenhouse gas emissions (GHGs) from ships. In particular, the MEPC was expected to consider, with a view to adopting, draft amendments to MARPOL Annex VI, including the NZF, as approved at the MEPC meeting in April 2025 (MEPC 83).
Instead, however, the MEPC voted by a majority to adjourn a decision on the adoption of the NZF by one year. The market response to this development has comprised both positive and negative views alike. In this article, we consider the context and significance of this postponement.
Net-Zero Framework
The NZF is an IMO initiative forming part of its 2023 GHG Strategy, which revised the Initial GHG Strategy laid down in 2018. Specifically, the GHG Strategy envisages a reduction in carbon intensity of international shipping by at least 40% by 2030, compared to 2008.
The revised GHG Strategy also includes new targets for the uptake of zero or near-zero GHG emission technologies, fuels and/or energy sources which are to represent at least 5%, striving for 10% of the energy used by international shipping by 2030.
The NZF applies to all ocean-going ships over 5,000 GT. It introduces:
A global fuel standard that requires ships to gradually reduce their annual GHG fuel intensity (GFI). This is based on how much GHG is emitted for each unit of energy used, across a fuel’s life cycle. And
A pricing mechanism with set prices for emissions exceeding the GFI threshold, aimed at encouraging the industry to lower emissions to comply with the global fuel standard.
In essence, ships can earn surplus units where their consumption is lower than the thresholds. Ships that emit above the set thresholds can balance their emissions deficit by: (i) transferring surplus units from other ships; (ii) using surplus units they have already banked; and (iii) using remedial units acquired through contributions to the IMO Net-Zero Fund.
The IMO Net-Zero Fund will be established to collect pricing contributions from emissions. These revenues will then be disbursed, among other things, to reward low emission ships, support innovation and transition initiatives in developing countries and mitigate negative impacts on vulnerable states.
So far, so good.
Approval/adoption
The IMO Net-Zero Framework was approved at MEPC 83 in April 2025 after many years of negotiation. The draft legal text was then shared with Member States for review, aiming for formal adoption at a special MEPC session in October 2025. Those discussions have now, however, been adjourned until 2026.
It was intended that detailed implementation guidelines would be approved at MEPC 84 in Spring 2026. Query whether that approval will now also be adjourned, notwithstanding that work on implementation measures is said to be continuing pending adoption.
To become legally binding, the amendments to MARPOL must go through the IMO’s tacit acceptance procedure. Under the tacit acceptance procedure, once an amendment has been adopted, it is deemed accepted at the end of a minimum period of 10 months, unless within that period objections are made by no less than one third of the State Parties or by State Parties with a combined merchant fleet tonnage of not less than 50% of world tonnage. If neither condition is triggered, the amendment is considered accepted.
Once adopted, the amendments would be expected to enter into force 16 months later (six months after the end of the 10 months deemed acceptance period). At that stage, Member State governments will be responsible for enforcing them. Therefore, realistically, the NZF will not now come into force until sometime in 2028 at the earliest.
What happened?
It was generally believed that the new measures having been approved at MEPC 83, the adoption of the NZF in October 2025 would be a formality. The hard work had been done and the battle won.
The US
However, the US had objected to the measures at MEPC 83 and withdrawn from the meeting. In August 2025, the US suggested that it could impose trade, port and other restrictions on Member States that voted in favour of the measures. This threat of retaliatory measures was followed by a White House statement on 10 October 2025, describing the NZF as an “unsanctioned global tax regime” that would unfairly burden international shipping.
The EU
The EU nonetheless issued a statement, reiterating its support for the measures and urging adoption. This notwithstanding that both the FuelEU Maritime Regulation and the EU Emissions Trading Scheme (EU ETS) make express provision with regard to the IMO’s adoption of the NZF. The EU ETS has applied to maritime emissions since January 2024.
The relevant provisions require the European Commission to report to the European Council and Parliament within 18 months of adoption on how the NZF aligns with and/or conflicts with the EU’s climate change regulations and whether amendments/revisions may be required to Fuel EU Maritime and/or the EU ETS.
A House Divided
At the MEPC meeting, the US was joined by Saudi Arabia and Russia (major fossil fuel producing countries) in objecting to the NZF adoption. Ultimately, it was Saudi Arabia that proposed a vote to adjourn adoption by one year. The motion passed with 57 votes in favour, 49 against and 21 abstaining. Among those objecting were the UAE, Liberia and Singapore. Greece and Cyprus abstained. Most EU Member States and the UK were among those voting in favour of adoption.
While some industry stakeholders have described this development as disappointing, others have expressed the view that it allows for further dialogue and time to bridge differing positions among IMO Member States in order to achieve consensus. Ultimately Member States appeared keen to avoid adopting the measures on the basis of a narrow majority, preferring to aim for true global agreement.
The objections
The key concern is stated to be the lack of a sufficient supply of clean fuels that would comply with the GFI. There will also be significant compliance challenges in the immediate term for some countries due to the high costs of producing compliant fuels. Additionally, the pricing mechanism is expected to adversely and disproportionately impact developing nations. A further concern was whether there would be any inconsistency between the NZF and the EU ETS.
Looking ahead
While consensus building continues among IMO Member States, global shipping continues to grapple with different emissions regulatory regimes and multiple regulatory and reporting systems.
Amongst other anticipated developments, the UK ETS Authority is currently planning to expand the scheme to maritime emissions from 1 July 2026 for vessels over 5,000 GT.
In the EU, the FuelEU Maritime Regulation is scheduled for review in December 2027. It may be that the maritime dimension of EU ETS may also be up for review in 2027 on the basis of the required three years of implementation data for such review.
It also remains to be seen how much input and influence the US will have in amendments to and modifications of the NZF text going forward. Will there be a watering down or a shoring up?
