Cost Recovery Under Draft IMO NZF Regulation 36.7
Draft MARPOL Annex VI regulation 36.7: recovering IMO Net-Zero Framework compliance costs from whoever decides fuel, cargo, route or speed for the ship.
Draft regulation 36.7 of MARPOL Annex VI Chapter 5 (MEPC/ES.2/2) states that a ship which has balanced its compliance deficit shall be considered as being compliant with its target annual GFI, without prejudice to recovery of the costs from the entity with operational responsibility, naming decisions on fuel, cargo, route or speed. It is the draft’s only provision on who bears the cost of remedial units bought against the base target annual GFI .
The full article will cover how the provision maps onto a time charter party , where charterers usually buy fuel and set speed and route, and how it compares with the pass-through of EU ETS allowance costs. The draft has not been adopted.