GFI Reduction Trajectory: Draft IMO Targets 2028 to 2035

The GFI reduction trajectory is the schedule of target GHG fuel intensities in draft regulation 35 of a new MARPOL Annex VI Chapter 5, the legal text of the IMO Net-Zero Framework . It sets two targets per calendar year, a base target and a stricter direct compliance target, each computed as a percentage reduction from a 2008 reference value of 93.3 gCO2eq/MJ well-to-wake. Table 4 prints the reduction factors for 2028 to 2035 only; a 65 percent base target factor is fixed for 2040, and the draft holds no value for 2050.

The trajectory is a draft. MEPC 83 approved it on 11 April 2025, the extraordinary session convened to adopt it adjourned in October 2025, and MEPC 84 in April and May 2026 did not adopt it. Every figure below is read from the approved text in IMO document MEPC/ES.2/2 and would bind nobody until an adoption resolution is passed and enters into force.

What the trajectory sets

The trajectory sets, for each calendar year from 2028, the attained well-to-wake GHG intensity a ship of 5,000 GT and above must reach to avoid buying compliance units. It does this through two numbers, not one:

• The base target annual GFI, the looser bound. A ship above it has a Tier 2 deficit.
• The direct compliance target annual GFI, the stricter bound. A ship at or below it is in direct compliance and earns surplus units for any margin.

Draft regulation 2.3.18 defines the pair together as the “target annual GFI”. Regulation 35.1 names the two tiers, regulation 35.2 gives the formula and Table 4, and regulation 35.3 sets the rule for 2036 to 2040. The rest of the Marine Global Fuel Standard methodology , the attained GFI in regulation 33 and the balancing rules in regulation 36, uses these targets as its benchmark.

A ship’s GFI is its energy-weighted average well-to-wake intensity across every fuel and energy source used in the calendar year, including shore power, wind and solar. The trajectory therefore regulates fuel choice, not speed or transport work. That is the difference from the carbon intensity indicator in Chapter 4.

Ships the IMO GFI targets would apply to

Draft regulation 30 applies Chapter 5, and so the Table 4 targets, to ships of 5,000 gross tonnage and above. That is the same tonnage threshold as the fuel consumption reporting of regulation 27, and the threshold the CII of regulation 28 applies to the ship types it lists, so the fleet that already reports to the IMO Data Collection System is broadly the fleet the trajectory would bind. The regulation excludes four groups:

• ships solely engaged in voyages within waters subject to the sovereignty or jurisdiction of their flag State;
• ships not propelled by mechanical means;
• platforms, including FPSOs, FSUs and drilling rigs, regardless of their propulsion;
• semi-submersible vessels, until further review.

The targets are the same for every ship in scope. Table 4 has no ship-type or size correction of the kind the CII applies through its reference lines, because a per-MJ intensity does not depend on how much cargo the energy moves. A 5,500 GT feeder and a 200,000 GT ore carrier on the same bunker mix have the same attained GFI and face the same target. Regulation 44 names extension to ships of 400 GT and above as a matter the five-yearly review shall consider; the approved text does not extend it.

Draft regulation 35: formula and reference value

Draft regulation 35.2 computes each target by one formula:

Here \( T \) is “the calendar year referred to in Table 4”, \( Z_T \) is the annual GFI reduction factor for that year and tier, and \( \text{GFI}_{2008} \) is the reference value. The same formula serves both tiers; only the \( Z_T \) column changes.

The 93.3 gCO2eq/MJ reference value

Regulation 35.2 fixes \( \text{GFI}_{2008} \) as “the GFI reference value equivalent to 93.3 gCO2eq/MJ (well-to-wake), representing the average GFI of international shipping in year 2008”. The value is a constant of the text. It does not float with fleet composition, bunker quality or later revisions of the default emission factors, and a change would need a MARPOL amendment.

The draft does not show its working, and no published IMO document sets out how 93.3 was reached. On the default factors in MEPC.391(81) , a high-sulphur HFO pathway comes to about 92.8 gCO2eq/MJ well-to-wake and a DMA-grade marine gas oil pathway to about 93.9, so the two conventional fossil pathways bracket 93.3. That bracketing is arithmetic on today’s defaults, not a derivation of the 2008 value, and the regulation text is the only authority for the number.

Why 2008, and on what GWP basis

2008 is the base year of every IMO greenhouse gas ambition. The Initial Strategy, MEPC.304(72) of 13 April 2018, measured its targets against 2008, and the 2023 Strategy, MEPC.377(80) of 7 July 2023, kept the same base year. The Fourth IMO GHG Study 2020 is the inventory series behind those comparisons (Fourth IMO GHG Study ).

The “CO2eq” in the unit is weighted with 100-year global warming potentials from the IPCC Fifth Assessment Report: 28 for methane and 265 for nitrous oxide, the values MEPC.391(81) prescribes (AR5 GWP100 in maritime rules ). The reference value and every attained GFI are on that basis, so methane slip from an Otto-cycle LNG engine and N2O from ammonia combustion both count against the ship (methane slip and N2O ).

Table 4: the reduction factors and target values, 2028 to 2035

Table 4 of draft regulation 35 prints eight years of factors for each tier. The target values below are the formula applied to 93.3 gCO2eq/MJ; the draft prints the factors, not the resulting gCO2eq/MJ values.

The slope changes in 2031. The base factor rises 2.0 points a year from 2028 to 2030, then 4.4 points a year from 2030 to 2035. A ship that is comfortable in 2030 loses about 4.1 gCO2eq/MJ of headroom every year after it.

The band between the tiers is constant. In every year the direct compliance factor is exactly 13.0 points above the base factor, so the band is 13 percent of 93.3, or 12.129 gCO2eq/MJ, from 2028 to 2035. The Tier 1 exposure of a ship above the base target is therefore the same number of tonnes every year for a given energy use.

The table stops at 2035. Between 2035 and 2040 only one number is fixed: the 2040 base factor of 65 percent, which puts the 2040 base target at 32.655 gCO2eq/MJ. That is below the well-to-wake intensity of any fossil fuel pathway in MEPC.391(81) Appendix 2 and of every LNG pathway on default slip.

Secretariat note MEPC/ES.2/2 paragraph 5.6 records that the percentage signs were removed from the Table 4 cells to align it with the EEDI and EEXI reduction factor tables, so the table in the regulation shows bare numbers under a heading “in percentage”.

IMO GFI targets for 2036 to 2040 and after

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 text as approved leaves these gaps:

1. No factor exists for either tier for 2036, 2037, 2038 or 2039. The Committee has to set them, and it has until 1 January 2032.
2. The 2040 base target is fixed at 65 percent; the 2040 direct compliance target is not fixed at all.
3. Nothing in regulation 35 addresses any year after 2040.
4. There is no rule for filling gaps by interpolation. The only interpolation footnotes in the draft revised Annex VI sit in Chapter 4, against the carbon intensity tables.

A straight line from the 2035 base factor of 30 percent to the 2040 anchor of 65 percent would give 7.0 points a year. That is a modelling assumption and nothing more. The Committee may choose a different path, and the five-yearly review in regulation 44 may revisit the 2040 anchor itself.

The net-zero ambition “by or around, i.e. close to, 2050” comes from paragraph 3.3.4 of the 2023 IMO GHG Strategy . Regulation 31, the goal of Chapter 5, ties the chapter to “the reduction targets set out in the 2023 IMO Strategy”, but it translates none of them into a 2050 GFI number.

How the IMO GFI targets produce a Tier 1 or Tier 2 deficit

Draft regulation 36 compares a ship’s attained annual GFI with both targets and turns the gap into tonnes of CO2eq by multiplying by the ship’s total energy use in MJ. The position of the attained GFI decides which deficits arise:

The tier labels run against intuition. The base target is the looser bound, yet exceeding it creates the Tier 2 deficit. The direct compliance target is the stricter bound, and the band beneath the base target creates the Tier 1 deficit. The base target annual GFI and the direct compliance target annual GFI each have an article of their own.

For reporting periods 2028 to 2030 the draft prices remedial units at USD 100 per tonne CO2eq for Tier 1 and USD 380 for Tier 2, paid as GHG emissions pricing contributions to the IMO Net-Zero Fund. The Committee is to settle the price review mechanism for 2031 onward by 1 January 2028. No price exists for any year after 2030. The pricing mechanics are covered under the IMO levy and economic measure , and the use of the revenue under Net-Zero Fund disbursement .

Surplus units earned below the direct compliance target may each be used once: transferred to another ship’s Tier 2 deficit, banked, or cancelled voluntarily. They remain valid for two calendar years after the year of issue. The draft contains no pooling provision; the surplus unit transfer is the only ship-to-ship mechanism. Accounts sit in the IMO GFI Registry under regulation 38.

Worked example: GFI deficits for a fossil-fuel ship, 2028 to 2030

This example applies Table 4 and regulation 36 to one ship with MEPC.391(81) default factors. The well-to-wake intensities are derived by this site from the Appendix 2 inputs; MEPC.391(81) prints the components and no well-to-wake total.

Fuel. A VLSFO-grade HFO pathway (RME, RMG or RMK, sulphur above 0.10 and up to 0.50 percent) carries well-to-tank 16.8 gCO2eq/MJ, lower calorific value 0.0402 MJ/g, CO2 factor 3.114 g/g, CH4 factor 0.00005 g/g and N2O factor 0.00018 g/g. With AR5 GWP100 weights, tank-to-wake is (3.114 + 28 x 0.00005 + 265 x 0.00018) / 0.0402 = 78.68 gCO2eq/MJ, and well-to-wake is 95.484 gCO2eq/MJ (per-fuel WtW for HFO ).

Energy. 10,000 tonnes of that fuel supply 10,000 x 10^6 g x 0.0402 MJ/g = 402,000,000 MJ. The ship uses no other energy.

2028. Attained 95.484 exceeds the base target of 89.568, so both deficits arise:

Paid entirely in remedial units, that is 4,875.9 x USD 100 plus 2,378.3 x USD 380, about USD 1,391,300 for the year.

2029 and 2030. The Tier 1 deficit stays at 4,875.9 t because the band is constant. The Tier 2 deficit grows to 3,128.4 t in 2029 and 3,878.5 t in 2030 as the base target falls. At the same prices the bills are about USD 1,676,400 and USD 1,961,400.

The same ship on DMA gas oil. A MDO/MGO pathway (DMX, DMA, DMZ or DMB, sulphur up to 0.10 percent) works out at 93.93 gCO2eq/MJ well-to-wake on the same method, and 10,000 tonnes supply 427,000,000 MJ. In 2028 the Tier 1 deficit is 5,179.1 t, larger because there is more energy, and the Tier 2 deficit is 1,863.4 t: about USD 1,226,000 in total (per-fuel WtW for VLSFO and MGO ).

A ship between the targets. A ship with an attained GFI of 80.0 gCO2eq/MJ in 2028 on the same 402,000,000 MJ has no Tier 2 deficit. Its Tier 1 deficit is (80.0 - 77.439) x 402,000,000 MJ = 1,029.5 t, about USD 103,000 at the Tier 1 price.

The Tier 2 cost is a ceiling, not a certainty, because a ship can cover a Tier 2 deficit with surplus units bought from another ship at whatever price the parties agree. Tier 1 has no such outlet: only Tier 1 remedial units balance it.

A ship below the direct compliance target

A ship whose attained GFI in 2028 is 70.0 gCO2eq/MJ on the same 402,000,000 MJ has a positive compliance balance of (77.439 - 70.0) x 402,000,000 MJ = 2,990.5 t CO2eq. Draft regulation 36.11 issues it 2,990.5 surplus units, each usable once and valid for two calendar years after 2028. Sold to a ship with a Tier 2 deficit, each unit displaces a USD 380 remedial unit, which sets the ceiling on what a buyer would pay.

Energy share of a ZNZ fuel needed to meet each target

The share of energy a ship must take from a lower-intensity source to reach a target follows from the energy-weighted average in regulation 33. For a ship otherwise on the VLSFO pathway at 95.484 gCO2eq/MJ, blending in a fuel of intensity \( I \) gives a required energy share of

Taking \( I \) at the regulation 39 ZNZ ceiling, 19.0 gCO2eq/MJ to the end of 2034 and 14.0 from 2035, the shares are:

A fuel at the ZNZ ceiling is the worst fuel that still earns ZNZ status, so these are upper bounds for ZNZ blending; a fuel with a lower certified intensity needs a smaller share. A drop-in biofuel above the ceiling needs a larger one. The step from 2030 to 2035 is where the blending requirement for the base target roughly triples.

Fuels and energy that reach the IMO GFI targets

Only fuels and energy sources with a well-to-wake intensity below the target lower a ship’s attained GFI toward it. Fossil residual and distillate fuels sit at about 92.8 to 95.5 gCO2eq/MJ on MEPC.391(81) defaults, above the base target in every year of Table 4, so a ship on fossil fuel alone is above both targets from 2028.

The options:

• Drop-in biofuels. FAME and HVO blends lower the attained GFI in proportion to their share and their certified intensity (biofuels in shipping ). The intensity has to be certified under a sustainable fuels certification scheme recognized under draft regulation 34, with the result carried on a fuel lifecycle label .
• LNG. Its attained intensity turns on the methane slip MEPC.391(81) assigns by engine type: 3.5 percent of fuel mass by default for an Otto-cycle medium-speed engine, 1.7 percent for Otto-cycle slow-speed and 0.15 percent for diesel-cycle slow-speed, each weighted at a GWP of 28 (LNG as marine fuel , per-fuel WtW for LNG , bio-LNG pathways ).
• Methanol and ammonia. The intensity is set by the production pathway, not by the molecule: fossil-derived grades and bio or e-fuel grades carry very different well-to-wake values (methanol as marine fuel , ammonia as marine fuel , per-fuel WtW for e-fuels ).
• Hydrogen in fuel cells or engines, with the intensity set by the production pathway (hydrogen as marine fuel ).
• Non-fuel energy. Wind, solar and shore power enter the energy denominator of regulation 33, so wind-assisted propulsion and shore power at berth dilute the attained GFI.

Energy efficiency acts differently. Slow steaming cuts the energy a ship uses and therefore the tonnes of any deficit, but it does not change the attained GFI, because intensity is per MJ.

The reward threshold for zero or near-zero fuels (ZNZs) in draft regulation 39 is far below any Table 4 value: not more than 19.0 gCO2eq/MJ until 31 December 2034, and not more than 14.0 from 1 January 2035. Those are about 80 and 85 percent below 93.3. A ship using ZNZs can draw rewards from the Net-Zero Fund on top of any surplus units it earns.

Relation to the 2023 IMO GHG Strategy

The trajectory implements the 2023 Strategy’s direction, not its numbers. MEPC.377(80) paragraph 3.4 sets two indicative checkpoints, both in total annual GHG emissions from international shipping against 2008:

• at least 20 percent, striving for 30 percent, by 2030 (paragraph 3.4.1);
• at least 70 percent, striving for 80 percent, by 2040 (paragraph 3.4.2).

The Strategy adds a carbon intensity ambition of at least 40 percent by 2030 in CO2 per transport work (paragraph 3.3.2), an uptake ambition for ZNZs of at least 5 percent, striving for 10 percent, of energy used by 2030 (paragraph 3.3.3), and net zero by or around 2050 (paragraph 3.3.4). Paragraph 3.2 says the checkpoints “should take into account the well-to-wake GHG emissions of marine fuels”.

None of these is a GFI value, and the Strategy has no 2035 figure. The comparison that is often drawn, “8 percent in 2030 against a Strategy of 20 percent”, mixes a per-MJ intensity cut with a cut in total emissions. Total emissions also depend on trade growth and on energy efficiency, which Table 4 does not address. The 43 percent figure attributed to the Strategy for 2035 is the 2035 direct compliance factor in Table 4.

The Initial Strategy it replaced, MEPC.304(72), aimed at a cut of at least 50 percent in total annual GHG by 2050 against 2008 (paragraph 3.1.3) and at least 40 percent in CO2 per transport work by 2030, pursuing 70 percent by 2050 (paragraph 3.1.2). MEPC.377(80) operative paragraph 6 revoked it, and operative paragraph 5 plans a further revised Strategy for 2028.

Regulatory status and the adoption calendar

MEPC 83, held 7 to 11 April 2025, approved the draft revised MARPOL Annex VI containing Chapter 5 on 11 April 2025. IMO’s June 2025 submission to UNFCCC SBSTA 62 records that Saudi Arabia requested a roll-call vote, which returned 63 in favour, 16 against and 24 abstentions, after which the Committee approved the draft amendments “with a view to circulation”. Approval is a procedural step. It produced no resolution number, no deemed-acceptance date and no entry-into-force date.

The dates in the approved text are placeholders. The draft adoption resolution in MEPC/ES.2/2 shows deemed acceptance as “[1 September 2026]” and entry into force as “[1 March 2027]”, both in square brackets, drafted on the assumption of adoption in October 2025. That did not happen:

Adoption, when it comes, starts the tacit acceptance procedure of MARPOL Article 16. Under Article 16(2)(f)(iii) an amendment to an Annex is deemed accepted at the end of a period set at adoption of not less than ten months, unless objected to by one third of the Parties or by Parties whose combined merchant fleets make up at least 50 percent of world gross tonnage. Under Article 16(2)(g)(ii) it enters into force six months after acceptance. IMO’s 11 April 2025 briefing gave 16 months from adoption to entry into force. The Revised MARPOL Annex VI, MEPC.176(58), went through the same Article 16(2)(f)(iii) and (g)(ii) route over a longer period: adopted 10 October 2008, deemed accepted 1 January 2010, in force 1 July 2010, about 21 months in all.

An Annex amendment does not bind every Party. Article 16(2)(g)(ii) brings it into force for all Parties except those that, before that date, have declared that they do not accept it, and Article 16(2)(f)(ii) lets a Party give notice that an amendment will enter into force for it only after its express approval. Which flags, if any, would opt out of Chapter 5 cannot be known until the amendment is adopted.

The fixed 2028 calendar

Chapter 5 hard-codes calendar dates on the assumption that it would be in force by March 2027. The attained GFI is first calculated “after the end of calendar year 2028” (regulation 33), reports are due within three months after the end of 2028 (regulation 37), the list of recognized certification schemes is due by 1 March 2027 (regulation 34), and Registry accounts are due by 1 October 2027 (regulation 38). The approved text contains no provision for what happens if those dates arrive before entry into force. That is a drafting question for the resumed session, not something the current text answers.

Five-yearly review of the GFI factors under draft regulation 44

Draft regulation 44 requires the Organization to complete a review of Chapter 5 every five years. Regulation 44.1 lists what the review shall consider: amending the annual GFI reduction factors for both tiers in regulation 35, amending the ZNZ thresholds in regulation 39, and applying the chapter to ships of 400 gross tonnage and above.

The review is separate from the 1 January 2032 deadline in regulation 35.3. That deadline fills the 2036 to 2040 gap; the review can reopen any factor, including the 2040 anchor. Either outcome is a MARPOL amendment, adopted by the Committee and brought into force through Article 16, so a factor change would reach ships about 16 months after its adoption at the earliest. The 2023 Strategy runs its own five-yearly review cycle, the first in 2028, which could move the ambitions the trajectory is meant to serve.

Interaction with FuelEU Maritime and the EU ETS

For ships trading to the European Economic Area, the IMO trajectory would sit beside two EU instruments already in force. FuelEU Maritime , Regulation (EU) 2023/1805, caps the well-to-wake GHG intensity of energy used on voyages in its scope. Article 4(2) reduces a reference value of 91.16 gCO2eq/MJ by 2 percent from 2025, 6 percent from 2030, 14.5 percent from 2035, 31 percent from 2040, 62 percent from 2045 and 80 percent from 2050.

The two regimes do not use identical default factors, so the same bunker produces slightly different intensities under each (FuelEU intensity formula ). FuelEU’s own balancing rules, banking, borrowing and pooling, have no IMO equivalent beyond surplus unit transfer (FuelEU compliance balance ). Both EU instruments carry a review clause keyed to an IMO measure. FuelEU Article 30(5) requires the Commission to report, with a legislative proposal where appropriate, in the event of the adoption by the IMO of a global GHG fuel standard, including on the need to avoid duplicating regulation. The ETS Directive, Article 3gg(1), requires a review within 18 months of the adoption of a global market-based measure. Neither review has been triggered, because nothing has been adopted (EU ETS and FuelEU double compliance ).

The EU ETS maritime scope prices tank-to-wake emissions in allowances, a different basis again. A ship in EU trade in 2028 could face an ETS surrender, a FuelEU penalty or balance, and an IMO remedial unit bill on overlapping fuel.

The GFI trajectory in fleet and commercial planning

The Table 4 values are the only GFI targets in any IMO text, so a planning case built on them has to be labelled as a draft case.

Newbuilds and retrofits

A ship delivered in 2028 faces a base target of 89.568 in its first year and 32.655 in 2040. On MEPC.391(81) defaults a fossil-oil ship is above the base target from 2028, and the Tier 2 deficit per MJ widens by about 1.9 gCO2eq/MJ a year to 2030 and 4.1 gCO2eq/MJ a year to 2035. That is the case for specifying fuel flexibility at contract, dual-fuel capability or methanol and ammonia readiness, and for costing retrofit at a scheduled drydock rather than mid-cycle. The EEDI and EEXI requirements in Chapter 4 remain in force alongside, and they reward efficiency rather than fuel intensity.

Charter parties

Fuel choice usually sits with the time charterer, who orders and pays for bunkers, while the draft Chapter 5 obligations attach to the ship. Clauses written for the CII, such as the BIMCO CII clauses , allocate operational responsibility for an intensity rating; they do not allocate the cost of remedial units or the value of surplus units. A time charter party running past 2028 needs express terms on who bears Tier 1 and Tier 2 costs and who keeps surplus units.

Finance and disclosure

Lenders under the Poseidon Principles and charterers under the Sea Cargo Charter measure portfolio alignment against decarbonization trajectories of their own. Those are voluntary frameworks. The Table 4 values give a regulatory cost case for ship valuation : a remedial unit bill of about USD 1.4 million in 2028 for a ship burning 10,000 tonnes of VLSFO a year, and larger in 2029 and 2030, is a cash flow a residual-value model has to carry.

Common misreadings of the IMO GFI trajectory

The pre-approval drafts and secondary sources left several errors in circulation. Each is corrected against MEPC/ES.2/2.

• “The trajectory runs from 2027 to 2050.” Table 4 runs 2028 to 2035, with a 2040 base anchor. There is no 2027 factor and no 2050 value.
• “The 2030 figure is 17 percent.” 17.0 is the 2028 direct compliance factor. The 2030 factors are 8.0 (base) and 21.0 (direct compliance).
• “Required GFI” and “Direct Compliance Threshold”. Neither term appears in the draft. The terms are base target annual GFI and direct compliance target annual GFI.
• “MARPOL Annex VI Chapter 4 ter”. The Framework is a new Chapter 5, regulations 30 to 44. “4 ter” appears nowhere in the approved text, and regulation references such as “28ter” or “31ter” point to nothing.
• “Linear interpolation between checkpoints.” Chapter 5 has no interpolation rule, and Table 4 has a value for every year it covers.
• “Tier 2 units are priced at a discount.” Tier 2 remedial units cost USD 380 against USD 100 for Tier 1.
• “Surplus units can be pooled across a fleet.” The draft allows transfer, banking and cancellation; it contains no pooling provision.
• “MEPC 84 in October 2025 would adopt the framework.” MEPC 84 met from 27 April to 1 May 2026 and did not adopt it. The October 2025 meeting was the extraordinary session, which adjourned.
• “The CII ends when the GFI starts.” The draft keeps the carbon intensity indicator in Chapter 4, with its own reduction factors , and the SEEMP framework alongside it.
• “The Chapter 5 GFI data uses a new bunker delivery note.” The bunker delivery note stays in regulation 18. Regulation 34.3 only permits the fuel lifecycle label to accompany it (bunker delivery note ).

Data behind a ship’s attained GFI

The target is only half the comparison. A ship’s attained GFI in regulation 33 is the energy-weighted sum of each fuel’s well-to-wake intensity, and the data comes from the fuel oil consumption reporting in regulation 27, which is the IMO Data Collection System , and the Chapter 5 reporting in regulation 37. Default well-to-wake factors come from the LCA framework in MEPC.391(81); actual values for a certified pathway replace them where a recognized scheme has certified the fuel (well-to-wake fuel pathways ).

The LCA framework itself is still moving. The IMO summary of ISWG-GHG 22 records that the LCA agenda item was deferred to ISWG-GHG 23, with a further report of the GESAMP LCA working group expected at MEPC 85. A change to a default factor moves a ship’s attained GFI without any change to Table 4.

Limitations

• Draft status. Every factor, target and price in this article comes from the text approved at MEPC 83 and published as MEPC/ES.2/2. None has legal force, and Member States were invited at MEPC 84 to propose amendments and adjustments before adoption.
• Computed values. Table 4 prints reduction factors. The gCO2eq/MJ targets, the 12.129 band, the well-to-wake intensities of HFO and MGO, and every tonne and dollar figure in the worked example are arithmetic on the draft and on MEPC.391(81) Appendix 2 inputs, done by this site and rounded to three decimals or to the nearest 100 USD.
• Default factors. MEPC.391(81) Appendix 2 prints components, not a well-to-wake total, and the default values may be revised through the GESAMP LCA process before or after adoption.
• The 93.3 reference value. The draft fixes the value; no public IMO document sets out its derivation, so this article does not offer one.
• 2036 onward. No factor exists for 2036 to 2039, nothing exists for the 2040 direct compliance target, and nothing exists after 2040. Any figure for those years is a modelling assumption.
• Timing. The entry-into-force date depends on the adoption date and on the acceptance period the Committee sets at adoption. The 1 March 2027 date in the draft is a placeholder in square brackets.
• Prices. Remedial unit prices are set for 2028 to 2030 only. Surplus unit prices between ships are a private matter the draft does not regulate.

Related Articles

• IMO Net-Zero Framework
• IMO Net-Zero Framework and GHG fuel intensity
• Marine Global Fuel Standard methodology
• Base target annual GFI
• Direct compliance target annual GFI
• Surplus units under the IMO Net-Zero Framework
• 2023 IMO GHG Strategy
• MEPC.391(81) LCA Guidelines
• FuelEU Maritime explained
• MARPOL Annex VI