IMO Net-Zero Framework: Draft MARPOL Annex VI Chapter 5

The IMO Net-Zero Framework is the draft global regime for greenhouse gas emissions from ships of 5,000 gross tonnage and above: a mandatory limit on the GHG intensity of the energy a ship uses, and a price on emissions above that limit paid into an IMO Net-Zero Fund. It is written as a new Chapter 5, regulations 30 to 44, of MARPOL Annex VI , published as MEPC/ES.2/2 on 16 June 2025.

It is not law. MEPC 83 approved the text on 11 April 2025 by a roll-call vote of 63 to 16 with 24 abstentions. The extraordinary session convened to adopt it, MEPC/ES.2 , adjourned in October 2025 for twelve months, and the resumed session is scheduled for 4 December 2026, subject to MEPC 85 . Every regulation cited below is a draft regulation.

Background: market-based measures at the IMO, 2010 to 2025

Carbon pricing for international shipping has been on the MEPC agenda for fifteen years. An Expert Group on Feasibility Study and Impact Assessment of possible Market-based Measures, chaired by Andreas I. Chrysostomou, analysed ten proposals against nine criteria in its report to MEPC 61 (MEPC 61/INF.2, 13 August 2010); its terms of reference barred it from making policy recommendations. MEPC 62 in July 2011 postponed the subject, MEPC 63 in 2012 agreed that an impact assessment was needed, and MEPC 65 in May 2013 “agreed to suspend discussions on MBMs and related issues to a future session”.

The Initial IMO GHG Strategy, resolution MEPC.304(72) of 13 April 2018, reopened the door by listing among candidate mid-term measures “new/innovative emission reduction mechanism(s), possibly including Market-based Measures (MBMs)”. At MEPC 76 in June 2021 the Marshall Islands and Solomon Islands proposed a mandatory levy of USD 100 per tonne of CO2 equivalent (MEPC 76/7/12), and the IMO briefing recorded that it would be further considered at the intersessional working group.

By June 2023 the proposals had settled into six families, reviewed for MEPC 80 in MEPC 80/INF.39/Add.1 (6 June 2023): the ICS fund and reward scheme, Japan’s zero-emission ship incentive feebate, Norway’s emissions cap-and-trade system, a GHG fuel standard from the EU Member States and others, a fund and reward proposal from Argentina, Brazil, China, South Africa and the United Arab Emirates with a Chinese fuel-standard variant, and the Pacific levy. The approved framework combines a fuel standard with a pricing mechanism and a Fund. MEPC 82 (30 September to 4 October 2024) worked on draft legal text for a “draft IMO net-zero framework”, refined at ISWG-GHG 17 (23 to 27 September 2024) and ISWG-GHG 18 (17 to 21 February 2025). The IMO levy and economic measure article covers this history in full.

The framework is the mid-term measure called for by the 2023 IMO GHG Strategy , resolution MEPC.377(80), adopted on 7 July 2023. Paragraph 4.5 of the Strategy asked for a basket “comprised of both: .1 a technical element, namely a goal-based marine fuel standard regulating the phased reduction of the marine fuel’s GHG intensity; and .2 an economic element, on the basis of a maritime GHG emissions pricing mechanism.”

Paragraph 4.6 asked for the measures to be adopted “along with the assessments of impacts on States”, The draft’s just-transition and food-security provisions are in regulations 41 to 43. Paragraph 4.1.2 required the basket to be “finalized and agreed by the Committee by 2025”, and paragraph 4.7 set a well-to-wake basis. The paragraph 6.2 timeline put approval at MEPC 83 in spring 2025, adoption at an extraordinary session six months later in autumn 2025, and entry into force “16 months after adoption (2027)”. The approval step was met; the adoption step was not.

The Strategy’s own checkpoints 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 framework regulates intensity per megajoule, a different metric.

Structure of draft Chapter 5

Chapter 5 is short. Its regulations divide as follows:

Regulation 32 states the two functional requirements: “.1 requirements on the continuous improvement of the ship’s GHG fuel intensity in accordance with regulation 35; and .2 requirements on GHG emissions pricing contributions for excess emissions and on rewards for the uptake of zero or near-zero GHG emission technologies, fuels and/or energy sources (ZNZs) in accordance with regulations 36 and 39.”

Regulation 31 states the chapter’s goal and ties it to “the reduction targets set out in the 2023 IMO Strategy”, using the Strategy’s language on an energy transition, a level playing field and a just and equitable transition. It is a statement of purpose, not a numeric obligation; the numbers sit in regulation 35.

The existing verification chapter of Annex VI would become Chapter 6, regulations 45 (the Code for Implementation) and 46 (the IMO Member State audit scheme under resolution A.1067(28)).

Ships covered by the Net-Zero Framework under draft regulation 30

Regulation 30.1 reads: “This chapter shall apply to all ships of 5,000 gross tonnage and above.” There is no international-voyage qualifier. Regulation 30.2 excludes:

• ships operating only in waters subject to the sovereignty or jurisdiction of their flag State (30.2.1), although Parties “should ensure” such ships act consistently with the chapter “so far as is reasonable and practicable”;
• “ships not propelled by mechanical means, and platforms including FPSOs and FSUs and drilling rigs, regardless of their propulsion” (30.2.2), which covers the FPSO fleet;
• “semi-submersible vessels until further review” (30.2.3).

On this site’s reading, because 30.1 has no voyage qualifier and 30.2.1 excludes only ships operating solely in their own flag State’s waters, a ship of one flag trading only between ports of another State would not be excluded by the text, although the IMO’s explanatory material describes the scope as oceangoing ships.

No ship type, size band or ice class gets a separate target. A 5,000 GT feeder and a 400,000 dwt ore carrier are measured against the same base and direct compliance targets. The IMO’s question-and-answer page on the framework puts ships over 5,000 GT at over 85 percent of global shipping emissions. Extension to ships of 400 GT and above is a review item under regulation 44.3.

The GHG fuel intensity standard

The technical element is a limit on attained annual GHG fuel intensity (GFI), in gCO2eq/MJ on a well-to-wake basis. The GHG fuel intensity article and the attained GFI methodology article cover the calculation in detail.

Attained GFI under regulation 33

Regulation 33.1 has each ship calculate its attained GFI “over a 12-month period from 1 January to 31 December for the preceding calendar year”. Regulation 33.2 divides the well-to-wake GHG emissions of all energy used on board by the total energy, including electricity from shore and from wind and other onboard sources. Default fuel factors come from the 2024 LCA Guidelines, MEPC.391(81) ; other values need a fuel lifecycle label certified by a sustainable fuels certification scheme recognized under regulation 34. CO2 equivalence uses the IPCC AR5 GWP100 values (AR5 GWP100 basis ). The GFI Calculation Guidelines that regulation 33 refers to are still to be developed.

Fuel certification under regulation 34

A fuel is scored at the MEPC.391(81) default unless it carries certified values. Under regulation 34 the Committee recognizes sustainable fuels certification schemes (34.4) and the Secretary-General publishes the list by 1 March 2027 (34.5), with the schemes reporting to the Organization from the end of 2027 (34.6). A certified value reaches the ship through a fuel lifecycle label. For biofuels, e-fuels and blue fuels, the certified pathway, not the fuel name, decides the ship’s attained GFI; the per-fuel well-to-wake methodology article covers blending.

Two targets under regulation 35

Each year has two targets, both cuts from a reference of 93.3 gCO2eq/MJ using the factors in Table 4:

The gap between the two is 12.129 gCO2eq/MJ in every year. Regulation 35.3 leaves the 2036 to 2040 factors to be set by 1 January 2032, so no value exists after 2035. The base target , direct compliance target and GFI reduction trajectory articles cover each series.

GHG emissions pricing: deficits, remedial units and surplus units

The economic element works through each ship’s GFI compliance balance (regulation 36.1), the target minus attained GFI times the ship’s total energy. Where the ship ends relative to the two targets decides what it pays or earns:

The USD 100 and USD 380 prices apply to the 2028 to 2030 reporting periods. Regulation 36.10 requires the Committee to determine by 1 January 2028 the mechanism for setting prices from 2031. Remedial units are bought “by means of GHG emissions pricing contributions to the IMO Net-Zero Fund” (36.5) and are non-transferable (2.3.11). The compliance deficit article covers the two tiers and the IMO levy and economic measure article the pricing history.

Surplus units are the transferable half. A ship can use each once: transfer it to another ship’s Tier 2 deficit, bank it, or cancel it voluntarily, and it lapses two calendar years after the year of issuance (36.12 to 36.15). The draft has no pooling, no fleet averaging and no borrowing.

Worked example: a VLSFO-only ship

On MEPC.391(81) defaults a VLSFO pathway has a well-to-wake intensity of about 95.484 gCO2eq/MJ (site arithmetic). A ship burning 10,000 tonnes of VLSFO a year uses 4.02 x 10^8 MJ.

• 2028: Tier 1 deficit 12.129 x 402 = 4,875.9 t CO2eq at USD 100; Tier 2 deficit (95.484 - 89.568) x 402 = 2,378.3 t at USD 380. Total about USD 1.39 million.
• 2030: Tier 1 unchanged at 4,875.9 t; Tier 2 (95.484 - 85.836) x 402 = 3,878.5 t. Total about USD 1.96 million.

To reach direct compliance on VLSFO alone, the ship would need about 18.9 percent of its energy from zero-intensity sources in 2028 and 22.8 percent in 2030 (site arithmetic, 1 minus target over 95.484).

How a ship would settle a deficit in practice

The draft gives a ship in deficit a fixed sequence. Within one month of its verified data reaching the Registry, and no later than 31 July, it records its compliance approach (37.4). For the Tier 1 deficit the only approach is to buy Tier 1 remedial units by paying into the Fund; the Registry credits the remedial units acquired to the ship account and cancels them following proof of payment (38.4.5). For the Tier 2 deficit it can combine surplus units transferred from other ships, its own banked surplus units and Tier 2 remedial units (36.6). The ship account statement of 31 August then shows the result, and the Statement of Compliance follows.

Reducing the deficit itself is a matter of what the ship burns and how much energy it uses. Regulation 33.2 counts electricity from shore, wind and other onboard sources in the energy denominator, so shore power and wind-assisted propulsion lower attained GFI directly. Certified biofuels, LNG and methanol lower it by the difference between their certified well-to-wake intensity and the fuel they replace, and methane slip counts against LNG. Energy efficiency measures cut the total bill in proportion but do not change intensity, because the deficit is intensity gap times energy.

What compliance requires, year by year

The targets translate into fuel shares. On the same VLSFO pathway of 95.484 gCO2eq/MJ, the share of energy a ship would need from zero-intensity sources to reach each target is 1 minus the target divided by 95.484 (site arithmetic):

No fuel on the market is zero-intensity on a well-to-wake basis, so real shares are higher. A fuel exactly at the 19.0 gCO2eq/MJ ZNZ threshold would need to supply about 23.6 percent of energy in 2028 and 28.5 percent in 2030 for direct compliance. The cost of missing the targets on VLSFO alone rises year by year:

The table stops at 2030 because the draft sets no remedial unit prices after that year.

Rewards for zero or near-zero GHG fuels under regulation 39

The framework pays for the fuels it wants. Regulation 39.1 sets the ZNZ threshold at “not greater than 19.0 gCO2eq/MJ for an initial period until 31 December 2034, and from 1 January 2035 … not greater than 14.0 gCO2eq/MJ”. Ships “may receive rewards from the IMO Net-Zero Fund for the ZNZs used” (39.2), and the Committee is to define the reward and its methodology “No later than 1 March 2027 and every five years thereafter” (39.3). The ZNZ reward article covers the scheme. Candidate fuels include ammonia and hydrogen produced on certified low-intensity pathways.

ZNZ use is tracked separately from the balance. The Administration verifies the emissions avoided by ZNZ use when it verifies the annual data (6.9.7), the Registry records ZNZ energy and avoided emissions (38.6), and the Organization “shall monitor and publish the share of ZNZs in the total annual energy used on board” (39.4). The draft neither makes a reward conditional on direct compliance nor removes rewarded energy from the balance that produces surplus units.

The IMO Net-Zero Fund, regulations 40 to 43

The Fund receives every remedial unit payment. Regulation 40.1 reads: “The Secretary-General of the Organization shall establish the IMO Net-Zero Fund”, with its costs “borne by the Fund”. Regulation 40.2 has it receive and manage “GHG emissions pricing contributions made by ships pursuant to regulation 36”.

Governance is set out in regulation 40:

• the Committee adopts “governing provisions” and appoints “a Governing Board to oversee the day-to-day operations” (40.3);
• the governing provisions specify eligible entities, financing mechanisms, operating procedures, cooperating organizations and “allocations of revenue to the different purposes set out in regulation 41” (40.4);
• the Board is to be “gender and geographically balanced”, with “adequate representation of developing countries, in particular of small island developing States (SIDS) and least developed countries (LDCs)” (40.5);
• the Board reports annually to the Committee, the Committee “shall periodically review the allocation of revenue”, and “The Fund shall be subject to audits” (40.6 to 40.8).

Regulation 41.1 lists three uses of revenue: ZNZ rewards (41.1.1); “promoting a just and equitable transition in States”, paying particular attention to LDCs and SIDS (41.1.2); and the Fund’s administration (41.1.3). Regulation 41.1.2 has five sub-purposes: research and deployment of ZNZs and “maritime, coastal and port-related infrastructure”; “enabling a just transition for seafarers and other maritime workforce”; technology transfer and capacity building; National Action Plans “including fleet renewal and upgrade”; and “disproportionately negative impacts on States, including on food security”.

Two of the sub-purposes point to other IMO instruments. National Action Plans refer to resolution MEPC.367(79) in footnote 117, and the food security clause cites MEPC.377(80) and MEPC.1/Circ.885/Rev.1 in footnote 118. The draft sets no percentage for any use and names no external fund. Regulation 42 covers technical cooperation and technology transfer, and regulation 43 requires the Committee to address and keep under review the negative impacts on food security . The IMO Net-Zero Fund disbursement article covers the Fund in detail.

Reporting, verification and the IMO GFI Registry

The annual cycle starts after the calendar year ends and runs to 30 September of the following year:

The Registry is established and administered by the Secretary-General (38.1) and holds each ship’s account of surplus and remedial units (38.4). An annual administration fee is payable by 30 June 2028 and each 30 June after (38.2). ISWG-GHG 21, meeting from 20 to 24 April 2026, asked the Secretariat for the Registry’s possible costs and functional requirements, including interoperability with the IMO Data Collection System . Regulation 38.9 requires the Secretary-General to report to the Committee each year on “transaction patterns in the issuance, transferring, usage and cancellation of surplus units and remedial units”.

Consequential amendments to the rest of Annex VI

The draft also amends existing regulations:

• Survey (5.5). The initial survey of a new ship verifies that the SEEMP required by regulation 26 is on board; for existing ships the Administration ensures the SEEMP meets regulation 26.4 before 1 January 2028.
• Statement of Compliance (6.9, 6.10, 8.5, 9.13). The Administration verifies the data and issues the Statement “no later than nine months after the beginning of the calendar year”; the form is appendix XIII; it is valid for the year of issue and the first nine months of the next, and kept on board for five years.
• SEEMP (26.4.1). “On or before 1 January 2028” the SEEMP must include the methodology to collect the regulation 37 data and the processes to report it.
• Port state control (10.5). “In relation to chapters 4 and 5, any port State inspection may verify, when appropriate, that there are valid Statements of Compliance related to … annual GHG fuel intensity, an International Energy Efficiency Certificate and a [SEEMP] on board.”

The draft adds no GFI item to the IAPP Certificate survey. The CII rating under Chapter 4 and the EEXI stay in place, so a ship would carry a CII rating and a GFI Statement of Compliance together; port state control would check both under regulation 10.5.

New ships, changes of flag or company, and withdrawal

Regulation 2.3.10 defines a new ship for Chapter 5 purposes by dates: a building contract placed on or after 1 January 2028, a keel laid on or after 1 July 2028, or delivery on or after 1 July 2030. For such a ship the initial survey verifies that the SEEMP required by regulation 26 is on board (5.5.1).

A ship that changes flag or company after 1 January 2028 reports for the part of the year up to the day of transfer and receives a Statement of Compliance for that portion (37.2, 37.7, 6.10). A ship permanently withdrawn from service follows regulation 37.8. None of these provisions says what happens to surplus units already in the ship’s Registry account, which is a point for the sale contract.

Cost recovery under regulation 36.7

Regulation 36.7 states that a ship which has fully balanced its deficit “shall be considered as being compliant with its target annual GFI”, without prejudice to recovering costs relating to the operational responsibility of the ship, defined as “determining the fuel used or the cargo carried or the route or the speed”. The draft places the obligation on the ship and leaves the pass-through of remedial unit costs to a time charter party or other contract. The cost recovery article covers the provision.

Preparatory obligations before the first reporting year

If the text were adopted with its current dates, each party would have obligations falling before any GFI is measured. The list below follows the draft regulations; on this site’s reading, most dates would move on a later adoption.

• Company and ship. Open the ship’s account in the IMO GFI Registry by 1 October 2027 (38.2); add the regulation 37 data methodology to the SEEMP on or before 1 January 2028 (26.4.1); collect fuel, energy and certification data from 1 January 2028 (33.1); pay the Registry administration fee by 30 June 2028 (38.2).
• Fuel suppliers and certification schemes. Obtain recognition as a sustainable fuels certification scheme for the Organization’s list due by 1 March 2027 (34.5), so that fuels other than MEPC.391(81) defaults can be scored.
• Administrations and recognized organizations. Verify the SEEMP of each existing ship before 1 January 2028 (5.5.2), then verify the first annual data by 30 June 2029 and issue Statements of Compliance by 30 September 2029 (37.3, 37.6, 6.9).
• The Committee. Define the ZNZ reward by 1 March 2027 (39.3), decide the remedial unit price mechanism from 2031 by 1 January 2028 (36.10), adopt the Fund’s governing provisions and appoint its Governing Board (40.3), and set the 2036 to 2040 factors by 1 January 2032 (35.3).

Charterers and owners would also need contract terms for regulation 36.7 cost recovery and for surplus units credited to the ship, since the draft addresses neither.

Five-yearly review of the Net-Zero Framework under draft regulation 44

Regulation 44 requires “a review … every five years to assess the effectiveness of this chapter in achieving its goal as set out in regulation 31”. On that basis the Organization shall consider amending the Table 4 reduction factors, amending the ZNZ thresholds, and “the possible application of this chapter to ships of 400 gross tonnage and above”. The text names no first review year and does not include prices, which follow regulation 36.10. The regulation 44 review article tracks it.

Net-Zero Framework adoption status and timeline

The framework has moved through approval and stalled at adoption.

Adoption would be under MARPOL Article 16(2)(d), and entry into force would follow the tacit acceptance procedure . The draft resolution states that the amendments are “deemed to have been accepted on [1 September 2026]” unless one third of the Parties, or Parties with not less than 50 percent of world gross tonnage, object, and enter into force “on [1 March 2027]”. Both dates are in brackets and the first has passed.

The Strategy set a different clock. Paragraph 6.2 of MEPC.377(80) allowed “16 months after adoption” for entry into force. Under MARPOL Article 16(2)(f)(ii) and (iii) and (g)(ii), which the draft resolution invokes, deemed acceptance comes after a period the Committee sets at adoption of not less than ten months, and entry into force six months later. On this site’s arithmetic, adoption on 4 December 2026 would give entry into force no earlier than about April 2028, after the 2028 reporting period had begun.

The MEPC 83 package is broader than Chapter 5. The approved text in MEPC 83/17/Add.1, annex 11, circulated by Circular Letter No.5005 of 11 April 2025, also carries the North-East Atlantic ECA , changes on accessibility of IMO DCS data, amendments arising from the review of the short-term measure that MEPC.377(80) paragraph 4.3 required “by 1 January 2026”, and clarifications to regulations 27 and 28. The adjournment of MEPC/ES.2 held all of them up together.

Several dates inside Chapter 5 were written for adoption in October 2025: sustainable fuels certification scheme listing by 1 March 2027 (34.5), the ZNZ reward definition by 1 March 2027 (39.3), Registry accounts by 1 October 2027 (38.2) and the 2028 first reporting year. On this site’s reading, adoption in December 2026 or later would require most of them to move.

Proposals that would change the framework

MEPC 84 recorded that Member States “will be able to submit new amendments and adjustments to the draft amendments previously approved”. The 2026 amendment proposals include MEPC 84/7/38 (Argentina, Liberia and Panama, 20 February 2026), which would replace the two targets with a single GFI target and add borrowing. An IMO officer’s presentation to the ISCC conference of 10 June 2026 summarizes four circular letters: No.5213 (Liberia), no remedial units and no Fund; No.5214 (Brazil), less steep trajectories; No.5215 (Tuvalu), no surplus units and remedial units at a minimum of USD 300; and No.5216 (Australia, Canada, South Africa and the United Kingdom), “minor adjustments to the application dates”.

Member State positions on the Net-Zero Framework

The draft was approved by vote, not consensus, and opposition is on the record. The United States Secretaries of State, Commerce, Energy and Transportation stated on 12 August 2025 that the framework is “effectively a global carbon tax on Americans levied by an unaccountable UN organization” and that the United States would “not hesitate to retaliate or explore remedies”. A State Department statement of 10 October 2025 said the United States “is considering” measures including “additional port fees on ships owned, operated, or flagged by countries supporting the framework”, visa restrictions and sanctions on officials. The US position article tracks these statements.

The positions of other States are recorded in their MEPC submissions, such as MEPC 84/7/38, rather than in public statements, and the IMO has not published the MEPC/ES.2 discussion record.

Interaction with FuelEU Maritime and the EU ETS

Ships trading to the European Economic Area already run two EU instruments. FuelEU Maritime , Regulation (EU) 2023/1805, has applied since 1 January 2025 with a limit of 89.34 gCO2eq/MJ for 2025 to 2029, a penalty of EUR 2,400 per tonne of VLSFO-equivalent energy, and banking, borrowing and pooling . The EU ETS for shipping requires allowances for tank-to-wake emissions.

The draft IMO text contains no provision on the EU instruments, and neither EU text switches off on IMO adoption. Each carries a review clause instead:

• EU ETS. If the IMO adopts a global market-based measure, Article 3gg(1) of Directive 2003/87/EC, inserted by Directive (EU) 2023/959, requires the Commission to report within 18 months of adoption and before the measure becomes operational, on its ambition, environmental integrity and coherence, “while avoiding any significant double burden”. There is no automatic phase-down.
• FuelEU Maritime. On IMO adoption of “a global GHG fuel standard”, Article 30(5) of Regulation (EU) 2023/1805 requires a Commission report “without delay” on “articulation or alignment”, “including the need to avoid duplicating regulation”.

If the draft were adopted as approved, voyages in EU scope would fall under both regimes until the EU legislates. Neither clause has been triggered, because nothing has been adopted. The EU ETS and FuelEU double compliance article covers the EU overlap.

Common errors about the IMO Net-Zero Framework

• “Adopted at MEPC 83.” It was approved; adoption has not happened.
• “Required GFI”, “Direct Compliance Threshold”, “Remediation Units”. The draft terms are base target, direct compliance target and remedial units.
• “Chapter 4 ter.” The text is Chapter 5, regulations 30 to 44.
• “First reporting year 2027” or “in force 1 January 2027”. The first reporting period is 2028, and the draft resolution’s dates are bracketed and lapsed.
• “Tier 1 is the dearer tier.” Tier 1 is the USD 100 band between the targets; Tier 2 is USD 380 above the base target.
• “Surplus units can be pooled or offset Tier 1.” Neither is in the text.
• “The Fund gives a fixed share to SIDS and LDCs.” No percentage is set.
• “Reporting goes through the IMO DCS.” GFI data go to the Administration or RO and the IMO GFI Registry under regulation 37.
• “Verification at IAPP renewal.” The Statement of Compliance is annual under regulation 6.9.

Limitations

Everything described here is MEPC/ES.2/2, a draft approved in April 2025 and not adopted. Regulation numbers, dates, targets and prices could change at the resumed session or through the amendments MEPC 84 invited, and the lapsed dates in the draft resolution and in Chapter 5 will have to change if the framework is adopted. The GFI calculation, Registry, compliance and ZNZ reward guidelines do not yet exist.

The worked example is this site’s arithmetic on Table 4 and MEPC.391(81) default factors for one fuel pathway. The IMO has published no Fund revenue estimate, and none is given. Circular Letters 5213 to 5216 are described from an IMO officer’s conference presentation, not from the letters themselves, and the IMO question-and-answer page was used only for its scope figure.

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