Base Target Annual GFI: The Looser Tier of Draft Reg 35

The base target annual GFI is the looser of the two annual greenhouse gas fuel-intensity targets in draft regulation 35.1.1 of a new MARPOL Annex VI Chapter 5, the legal text of the IMO Net-Zero Framework circulated as MEPC/ES.2/2. For each calendar year it cuts a 2008 reference intensity of 93.3 gCO2eq/MJ by a factor in Table 4: 4.0 percent in 2028, 8.0 percent in 2030, 30.0 percent in 2035 and 65 percent in 2040. A ship whose attained annual GFI is above the base target owes a Tier 2 compliance deficit on the excess, settled with surplus units or Tier 2 remedial units at USD 380 per tonne CO2eq for 2028 to 2030, and also owes a Tier 1 deficit on the whole band down to the stricter direct compliance target. The draft was approved at MEPC 83 on 11 April 2025 and has not been adopted.

What the base target is

The base target is one of two values that together make up the target annual GFI. Draft regulation 2.3.18 defines the target annual GFI as the values of “the two-tier target annual GFI (base target and direct compliance target) in accordance with regulation 35”, and regulation 35.1 lists the base target first and the direct compliance target second.

The base target is the higher number, so it is the easier one to meet. In 2028 it is 89.568 gCO2eq/MJ, against 77.439 for the direct compliance target . A ship’s attained annual GFI , calculated under draft regulation 33.2 on a well-to-wake basis, is compared with both values each year.

The two targets divide the intensity scale into three zones:

The base target is therefore the line at which the higher price starts. It is not a pass mark: a ship at or just under it still pays for every gram between its attained value and the direct compliance target.

Formula and reference value in draft regulation 35

Draft regulation 35.2 gives one formula for both tiers. The base target for year T is the reference value reduced by the base target factor for that year:

Here GFI_T is the target for calendar year T, Z_T is the reduction factor from the base target column of Table 4, and GFI_2008 is the reference value. The Secretariat note to MEPC/ES.2/2 records that the percentage symbols were removed from Table 4 “to avoid possible confusion on the orders of magnitude”, aligning it with the EEDI and EEXI reduction tables, so a factor of 4.0 means a 4.0 percent cut.

The 93.3 gCO2eq/MJ reference value

Regulation 35.2 describes GFI_2008 as “equivalent to 93.3 gCO2eq/MJ (well-to-wake), representing the average GFI of international shipping in year 2008”. The draft publishes no derivation. The value is fixed in the text, so it is not recalculated when the MEPC.391(81) LCA Guidelines default factors change, and regulation 44.1 names the reduction factors, not the reference value, as the review item.

The emissions are weighted on AR5 GWP100 values under draft regulation 2.3.2, which is why methane and nitrous oxide factors from MEPC.391(81) Appendix 2 feed into the intensity that is compared with the base target.

Calendar-year basis

The subscript T in regulation 35.2 is “the calendar year referred to in Table 4”. The base target changes every 1 January, and a ship’s attained GFI for the calendar year is compared with that year’s value. There is no interpolation between checkpoints: Table 4 prints a factor for every year from 2028 to 2035.

Base target values, 2028 to 2040

Table 4 of draft regulation 35 sets the base target factor for each year from 2028 to 2035, and regulation 35.3 fixes the 2040 factor. The gCO2eq/MJ values below are this site’s arithmetic on the draft formula, rounded to three decimals.

The base target factor rises by 2.0 points a year from 2028 to 2030 and by 4.4 points a year from 2031 to 2035, so the annual step more than doubles after 2030. Between 2030 and 2031 the base target drops from 85.836 to 81.731 gCO2eq/MJ. A fleet plan that clears the base target in 2030 by a margin under 4.1 gCO2eq/MJ drops above it in 2031 without any change in fuel.

The full two-tier table, the 2036 to 2040 determination and the comparison with the Strategy checkpoints are in the GFI reduction trajectory article.

2036 to 2040

Draft regulation 35.3 reads: “By 1 January 2032, the Committee shall determine the Z-factor (ZT) for the Base target and Direct compliance target for the years 2036 to 2040. The 2040 ZT for the Base target shall be set at 65%.” The 2040 base target of 32.655 gCO2eq/MJ is therefore the only post-2035 value in the draft. Nothing is fixed for the 2040 direct compliance target, and nothing at all after 2040.

Exceeding the base target: the Tier 2 deficit

A ship whose attained annual GFI is greater than the base target carries both deficits under draft regulation 36.4.2:

Both expressions are negative for a ship in deficit, since the target is lower than the attained value, and this article states them as positive tonnes of CO2eq. Energy_total is the ship’s total energy for the year in megajoules under regulation 33.2, including shore power, wind and solar energy, so grams per megajoule times megajoules gives grams, divided by one million for tonnes.

The Tier 1 part is fixed by the gap between the targets and does not grow as the attained value rises. Above the base target, every extra gram per megajoule lands in Tier 2. That is what makes the base target the commercial threshold: below it, each gCO2eq/MJ of excess costs USD 100 per tonne of resulting deficit; above it, USD 380.

Settling a Tier 2 deficit

Draft regulation 36.6 allows a Tier 2 deficit to be balanced by any combination of:

1. surplus units transferred from another ship (36.6.1);
2. surplus units the ship banked in an earlier year (36.6.2);
3. Tier 2 remedial units acquired by GHG emissions pricing contribution to the IMO Net-Zero Fund (36.6.3).

Regulation 36.9 sets the initial Tier 2 remedial unit price at USD 380 per tonne CO2eq on a well-to-wake basis for the reporting periods 2028 to 2030. Regulation 36.10 requires the Committee to adopt the mechanism for later prices by 1 January 2028. The Tier 1 part of the same ship’s deficit is balanced separately, with Tier 1 remedial units at USD 100 (36.5, 36.8).

Surplus units are issued to a ship whose compliance balance is positive, that is, below the direct compliance target (36.2, 36.11); a ship exactly on the target has a zero balance and receives none. Under regulations 36.12 to 36.15 a surplus unit can be used once: transferred to another ship to balance that ship’s Tier 2 deficit, banked, or voluntarily cancelled. Banked units are valid for two calendar years following the year of issuance and are then cancelled as a mitigation contribution. The draft attaches no ownership or fleet condition to a transfer, and the word “pool” does not occur in it.

Remedial units cannot be traded. Regulation 2.3.11 defines them as non-transferable, and regulation 2.3.16 defines surplus units as transferable. A ship above the base target can buy surplus units from a ship in another company, but it cannot buy remedial units from anyone except through the Fund.

Between the direct compliance target and the base target: the Tier 1 band

A ship whose attained annual GFI “is equal to or less than the base target but greater than the direct compliance target” falls under draft regulation 36.4.1 and carries a Tier 1 deficit only:

The only route to balance it is Tier 1 remedial units (36.5). Surplus units do not work here: regulation 36.6 applies to Tier 2 deficits, and the transfer permission in 36.12.1 is “to balance that ship’s Tier 2 compliance deficit”. A ship in the Tier 1 band cannot offset its deficit with units bought from a better-performing ship, and it receives no surplus units of its own.

Regulation 37.4 adds only the recording step: the compliance approach is recorded in the IMO GFI Registry within one month of the verified data, or by 31 July. The draft says nothing else about the band.

A ship exactly on a target

The draft settles both boundary cases in the wording. A ship exactly at the base target is inside regulation 36.4.1, “equal to or less than the base target”, so it carries a Tier 1 deficit and no Tier 2 deficit. A ship exactly at the direct compliance target has a GFI compliance balance of zero, and regulation 36.2 treats a balance “equal to or greater than zero” as direct compliance.

Why the base target carries the Tier 2 label

The draft numbers deficits by band, not by target, and the band above the looser target is the second band. Reading “base” as “first” and therefore “Tier 1” inverts the whole mechanism. The IMO Secretariat’s presentation to the WTO Trade and Environmental Sustainability Structured Discussions (TESSD) on 12 May 2025 describes “Two-tiered GFI reduction trajectories (‘base target’ and ‘direct compliance target’)”. Its diagram labels the zone above the base target “TIER 2 DEFICIT”, priced at USD 380 plus USD 100, and the zone between the targets “TIER 1 DEFICIT”, priced at USD 100.

Tier 1 is the cheaper tier and sits below the base target. Tier 2 is the dearer tier and sits above it. The price gap, USD 100 against USD 380 for 2028 to 2030, means a tonne of deficit above the base target costs 3.8 times a tonne between the targets.

Mislabels: Tier 1 Required GFI, Chapter 4 ter and regulation 28ter

The label “Tier 1 Required GFI standard (MARPOL Annex VI Chapter 4 ter)” is wrong in each of its parts against MEPC/ES.2/2:

• “Required GFI” does not occur in the draft. The defined terms are target annual GFI (2.3.18), base target and direct compliance target (35.1).
• “Tier 1” describes the cheaper deficit below the base target, not the base target itself.
• “Chapter 4 ter” does not exist. The draft inserts Chapter 5, “Regulations on the IMO Net-Zero Framework”, after Chapter 4 on carbon intensity.
• “Regulation 28ter” to “31ter” do not exist. The targets are regulation 35, the deficits regulation 36, reporting regulation 37 and the review regulation 44.
• “Remediation Unit” is “remedial unit” in regulation 2.3.11.

The label “global fuel standard” comes from the IMO press briefing of 11 April 2025, not from the draft. The IMO global fuel standard methodology article covers how the attained value compared with the base target is calculated.

Ships measured against the base target

Draft regulation 30.1 applies Chapter 5 to ships of 5,000 gross tonnage and above, the same size threshold as the IMO Data Collection System . Regulation 30.2 excludes:

• ships solely engaged in voyages within waters subject to the sovereignty or jurisdiction of their flag State, which Parties “should ensure” act consistently with the chapter “so far as is reasonable and practicable”;
• ships not propelled by mechanical means, and platforms including FPSOs, FSUs and drilling rigs, regardless of their propulsion;
• semi-submersible vessels, until further review.

Extension to ships of 400 GT and above is a review item under regulation 44.1.3, not an application rule.

One base target for every ship

The base target is the same number for every ship in scope. Draft regulations 30 to 36 contain no correction factor and no ship-type, capacity, deadweight or ice-class term, and the “new ship” definition in regulation 2.3.10 is not used in regulations 33 to 36. A VLCC , a container ship and a ro-ro vessel of 5,000 GT and above face 89.568 gCO2eq/MJ in 2028.

This is a structural difference from the Carbon Intensity Indicator , which sets required values by ship type and size under MARPOL Annex VI regulation 28 and the reference-line guidelines. The GFI measures the fuel and energy used, per megajoule, and does not depend on transport work, so hull form, speed and cargo do not enter the comparison except through the energy mix.

Worked example: a VLSFO ship against the base target, 2028 to 2030

The example is this site’s arithmetic on MEPC.391(81) Appendix 2 default components, not an IMO calculation. The default factors do not print a well-to-wake total, so the intensities below are derived from the printed well-to-tank value, lower calorific value and emission factors, with AR5 GWP100 weights of 28 for methane and 265 for nitrous oxide.

Inputs. A ship burns 10,000 t of VLSFO (pathway HFO(VLSFO)_f_SR_gm: WtT 16.8 gCO2eq/MJ, LCV 0.0402 MJ/g, CfCO2 3.114, CfCH4 0.00005, CfN2O 0.00018) and uses no other energy.

• Energy_total = 10,000,000,000 g x 0.0402 MJ/g = 402,000,000 MJ.
• Tank-to-wake intensity = (3.114 + 28 x 0.00005 + 265 x 0.00018) / 0.0402 = 78.68 gCO2eq/MJ.
• Attained annual GFI = 16.8 + 78.68 = 95.48 gCO2eq/MJ, carried unrounded (95.484) through the deficit arithmetic below.

The Tier 1 figure is 12.129 x 402,000,000 MJ in each year, because the band between the targets does not change width before 2035. The Tier 2 figure grows by 750.1 t a year as the base target falls by 1.866 gCO2eq/MJ. In 2030 the Tier 2 part is 75 percent of the bill. No price is set beyond 2030 (regulation 36.10), so no cost is given for 2031 onward.

Fossil defaults against the 2028 base target

On the same derivation, the three fossil pathways with a printed well-to-tank value in MEPC.391(81) Appendix 2 all sit above the 2028 base target:

High-sulfur HFO derives lower than VLSFO because its printed well-to-tank value is 14.1 against 16.8. On these default factors, a ship on heavy fuel oil with an exhaust gas cleaning system starts closer to the base target than a ship on compliant low-sulfur fuel, though both are above it. Appendix 2 prints no well-to-tank value for fossil LNG, ammonia or hydrogen and has no methanol row, so no default GFI can be derived for those fuels from the resolution.

A ship between the targets

Take an attained annual GFI of 80.0 gCO2eq/MJ in 2028, an assumed value not tied to a particular fuel, on the same 402,000,000 MJ. It is below the base target of 89.568 and above the direct compliance target of 77.439, so regulation 36.4.1 applies. The Tier 1 deficit is (80.0 - 77.439) x 402,000,000 MJ = 1,029.5 t, balanced only with Tier 1 remedial units at USD 100, about USD 102,950. The ship receives no surplus units and cannot use any.

Energy share needed to reach the base target

A VLSFO ship reaches the base target when the share of energy at zero well-to-wake intensity is at least 1 minus the ratio of the base target to 95.48. That is about 6.2 percent in 2028, 10.1 percent in 2030 and 31.6 percent in 2035. Energy that counts towards Energy_total under regulation 33.2 includes shore power , whose default intensity is the national grid value, and wind-assisted propulsion , whose method awaits the GFI Calculation Guidelines . A real biofuel or e-methanol carries a certified intensity above zero, so the share of that fuel needed is higher than these figures.

Surplus units from another ship

Take a second ship with the same 402,000,000 MJ of energy and an attained annual GFI of 70.0 gCO2eq/MJ in 2028, again an assumed value. Its compliance balance under regulation 36.1 is (77.439 - 70.0) x 402,000,000 MJ = 2,990.5 t CO2eq, positive, so it is in direct compliance and receives 2,990.5 surplus units (36.2, 36.11).

If it transfers 2,378.3 of them to the VLSFO ship above, that ship’s Tier 2 deficit for 2028 is balanced and it buys no Tier 2 remedial units. Its Tier 1 deficit of 4,875.9 t is untouched, because regulation 36.5 allows only Tier 1 remedial units against it, so it still pays USD 487,590 to the Fund. The remaining 612.2 surplus units can be transferred to another ship above its base target, or banked for the ship’s own later Tier 2 deficits within the two-calendar-year validity of regulation 36.15.

The draft sets no price for surplus units. A buyer above the base target has the Tier 2 remedial unit at USD 380 per tonne as its alternative for 2028 to 2030, and a ship between the targets cannot use surplus units at any price.

Marginal value of cutting intensity above and below the base target

Where a ship sits against the base target decides what one tonne of fossil fuel displaced is worth. Replacing the energy in one tonne of VLSFO, 40,200 MJ, with energy at zero well-to-wake intensity leaves Energy_total unchanged and removes 95.48 x 40,200 g, about 3.838 t CO2eq, from the ship’s deficit. At 2028 to 2030 draft prices:

The same tonne of displaced fuel is worth about 3.8 times as much above the base target as below it. Above the base target, cutting intensity never reduces the Tier 1 part, which stays fixed at the band width times total energy until the ship crosses the base target. The first cuts a ship makes are therefore the most valuable, and the value drops once the ship falls inside the Tier 1 band.

Averaged over the whole bill, the VLSFO-only ship in the worked example pays about USD 139 per tonne of fuel burned in 2028 (USD 1,391,300 over 10,000 t), USD 168 in 2029 and USD 196 in 2030. These are averages. The marginal figure in the table is what a decision to buy one tonne of a lower-intensity fuel should be tested against, net of the certified intensity of the replacement fuel.

Base target over a ship’s trading life

The base target applies to existing ships and to ships delivered after the draft enters into force on the same terms. The “new ship” definition in draft regulation 2.3.10, based on a building contract on or after 1 January 2028, keel laying on or after 1 July 2028 or delivery on or after 1 July 2030, is not used in regulations 33 to 36, so it gives no newbuild allowance against Table 4.

A ship delivered in 2028 would face 89.568 gCO2eq/MJ in its first year, 65.310 by 2035 and, if the Committee keeps the 2040 factor of 65, 32.655 by 2040, all inside the first 12 years after delivery. On the derived VLSFO intensity of 95.48 gCO2eq/MJ, the share of total energy that would need to come from zero-intensity sources to stay at the base target rises from about 6.2 percent in 2028 to about 31.6 percent in 2035 and about 65.8 percent in 2040.

The 2036 to 2040 path between those points is not yet set (regulation 35.3), and the five-yearly review under regulation 44.1 can change the factors. For an owner specifying dual-fuel engines or a gas-ready notation now, the fixed points in the draft are the 2035 base target and the 2040 base target factor of 65; everything between them depends on a Committee decision due by 1 January 2032.

Reporting and verification against the base target

The base target is applied once a year, after the end of the calendar year, under draft regulations 33.1 and 37. The first reporting year is 2028. For each year:

The document is the Statement of Compliance related to annual GHG fuel intensity , issued under regulation 6.9 by the Administration or a recognized organization . Regulation 9.13 makes it valid for the calendar year of issue and the first nine months of the next, and it is kept on board for five years. Port state control may verify it under regulation 10.5. It is not a survey endorsement of the IAPP Certificate , and Chapter 5 adds no IAPP survey step.

The ship’s SEEMP must describe the data methodology and reporting processes for regulation 37 on or before 1 January 2028 under regulation 26.4.1. The data behind the attained value are reported under regulation 37.1, with fuel-specific values from a fuel lifecycle label certified by a recognized sustainable fuels certification scheme where the ship uses something other than the defaults (regulation 34).

Adoption status of the base target

The base target is not law. The draft amendments were approved at MEPC 83 on 11 April 2025. IMO’s note to UNFCCC SBSTA 62 (June 2025, para 9) records a roll-call vote, requested by Saudi Arabia, of 63 in favor, 16 against and 24 abstaining, after which the Committee approved the draft “with a view to circulation”.

The MEPC/ES.2 extraordinary session convened to adopt the amendments adjourned in October 2025 without adopting them. MEPC 84, 27 April to 1 May 2026, did not adopt them either; its summary records that Member States could submit new amendments and adjustments to the approved draft. The ISWG-GHG 22 meeting, 1 to 4 September 2026, reported no decision on substance. ISWG-GHG 23 is scheduled for 23 to 27 November 2026, MEPC 85 for 30 November to 3 December 2026, and the resumed ES.2 for 4 December 2026, subject to confirmation by MEPC 85.

The draft adoption resolution carries bracketed dates for deemed acceptance, [1 September 2026], and entry into force, [1 March 2027], set on the assumption of adoption in October 2025. Both dates have lapsed or cannot be met. Under the tacit acceptance procedure of MARPOL Article 16(2)(f)(iii) and (g)(ii), an amendment is deemed accepted after a period of not less than ten months and enters into force six months later.

Proposals to change the base target

An IMO officer’s presentation at the ISCC conference of 10 June 2026 lists four amendment proposals circulated to Parties by IMO circular letter:

• Circular Letter No.5213 (Liberia): “no RUs, no Fund, GFI trajectory determined as the market share weighted average emissions intensity of all commercially viable fuels”;
• Circular Letter No.5214 (Brazil): “less steep reduction trajectories for the base target and the direct compliance target towards 2035 (more SUs)”;
• Circular Letter No.5215 (Tuvalu): “no SUs, all emissions subject to RU payment at minimum rate of US$300 per tonne of CO2eq”;
• Circular Letter No.5216 (Australia, Canada, South Africa and the United Kingdom): “minor adjustments to the application dates”.

Brazil’s and Liberia’s proposals would both change the base target values: Brazil’s by flattening the trajectory, Liberia’s by replacing it with a market-weighted fuel average. The European Parliament briefing PE 780.423 (April 2026) lists further papers to MEPC 84, among them MEPC 84/7/38 (Argentina, Liberia and Panama) and MEPC 84/7/41 (United States), which remove the economic element, and MEPC 84/7/49 (Japan), which removes the mandatory payment and proposes less stringent targets. These are proposals; the Table 4 factors above are the approved draft text. The amendment proposals are tracked separately.

Base target and the 2023 IMO GHG Strategy

Draft regulation 31 ties Chapter 5 to “the reduction targets set out in the 2023 IMO Strategy”, resolution MEPC.377(80) . The Strategy’s indicative checkpoints (paragraph 3.4) are cuts in total annual GHG emissions from international shipping against 2008: at least 20 percent, striving for 30 percent, by 2030, and at least 70 percent, striving for 80 percent, by 2040. The base target is a cut in intensity per megajoule.

The two are not interchangeable. An 8.0 percent intensity cut in 2030 can coexist with higher total emissions if energy use grows, and a 20 percent total cut can be met partly by lower activity. MEPC.377(80) contains no 2035 figure, so the 30.0 base target factor for 2035 has no Strategy checkpoint to match. The 65 percent 2040 base target factor sits below the Strategy’s 70 percent total-emissions checkpoint for 2040, on a different metric.

Base target, FuelEU Maritime and the EU ETS

For ships trading to the European Economic Area, the base target would sit beside FuelEU Maritime , Regulation (EU) 2023/1805, which applies from 1 January 2025 under its Article 32. Article 4(2) cuts a reference value of 91.16 gCO2eq/MJ by 2 percent from 2025, 6 percent from 2030 and 14.5 percent from 2035, stepping to 80 percent in 2050.

The intensity formula in FuelEU differs from regulation 33.2, for example in its reward factor for RFNBOs (FuelEU formula ), so a ship’s IMO and FuelEU intensities for the same fuel are not the same number. FuelEU Article 30(5) requires the Commission to report on alignment if IMO adopts a global GHG fuel standard; nothing has been adopted, so the review has not started. The EU ETS for shipping prices tank-to-wake emissions in allowances, a third basis, and the EU ETS and FuelEU double compliance article covers the overlap between the two EU instruments.

Charter parties and cost recovery under regulation 36.7

The draft places the deficit on the ship. Regulation 36.7 states that a ship which has balanced its deficit “shall be considered as being compliant with its target annual GFI”, without prejudice to the ship recovering costs that relate to the operational responsibility of the ship, which it defines as “determining the fuel used or the cargo carried or the route or the speed”. The draft names no entity and says nothing about any particular charter.

Under a time charter party the charterer usually buys the fuel and sets speed and route, so the base target exposure follows the charterer’s bunker choices while the obligation sits with the ship. The allocation is left to contract. That differs from the EU ETS, where Article 3gc of Directive 2003/87/EC gives the shipping company a statutory right to reimbursement of allowance costs (EU ETS cost pass-through ). The cost recovery provision is covered separately.

Common errors about the base target

• Treating the base target as a pass mark. A ship at or below the base target but above the direct compliance target still owes Tier 1 remedial units (36.4.1, 36.5).
• Calling the base target Tier 1. The Tier 1 deficit sits below the base target; the Tier 2 deficit sits above it.
• Assuming surplus units can cover any deficit. They balance Tier 2 deficits only (36.6, 36.12.1).
• Charging Tier 2 on the whole gap to the direct compliance target. Above the base target, only the excess over the base target is Tier 2; the band between the targets stays at the Tier 1 price.
• Starting the table in 2027 or interpolating. Table 4 starts in 2028 and prints every year to 2035.
• Quoting a 2050 base target. The draft stops at 2040.
• Stating that the framework was adopted at MEPC 84 in October 2025. MEPC 84 met from 27 April to 1 May 2026, and neither it nor ES.2 adopted the amendments.
• Adding a ship-type correction. The base target is the same for every ship in scope.
• Reading the 2040 factor of 65 as the Strategy’s 70 percent checkpoint. One is intensity, the other total emissions.

A ship 10 percent below the 2008 reference, at 83.97 gCO2eq/MJ, does not fail the 2030 base target. It is under the 2030 value of 85.836, clears the base target in 2030 and falls above it in 2031, when the target drops to 81.731.

Limitations

• Draft text. Every regulation number, factor and price here comes from MEPC/ES.2/2 as approved at MEPC 83. Amendments circulated in 2026, including the Brazil proposal to flatten both trajectories, could change the base target values before adoption, and the figures should be re-read against any adoption resolution.
• Derived intensities. MEPC.391(81) does not print well-to-wake totals. The 95.48, 93.93 and 92.78 gCO2eq/MJ values are this site’s arithmetic on the printed components; the GESAMP-LCA work reporting to MEPC 85 may revise default factors.
• Prices. USD 100 and USD 380 apply to reporting periods 2028 to 2030 only. Later prices depend on a mechanism not yet adopted (regulation 36.10).
• Timing. The draft hard-codes 2028 as the first reporting year and deadlines in 2027 and 2028. It contains no provision for adoption late enough that those dates fall before entry into force.
• Guidelines pending. The GFI Calculation Guidelines and other guidelines referred to in footnotes 78 and 86 to 88 of the draft are still to be developed, so the treatment of wind and solar energy in Energy_total is not settled, and MEPC.391(81) sets the onboard carbon capture term in a fuel’s emission factor to zero pending guidance.
• No rationale in the text. Chapter 5 states no reason for the two-tier split or for the 13-point gap between the targets. The draft’s goal provision, regulation 31, refers only to the reduction targets of the 2023 Strategy.

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