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NGO letter ahead of ISWG-GHG

The IMO Initial Strategy, the historic 2018 climate deal agreed to by over 100 countries, risks being undermined at negotiations next week – the Intersessional Working Group on Reduction of GHG Emissions from Ships.

The three most important principles of the IMO Initial Strategy are:

  1. The agreement that the Paris Agreement applies to shipping. Specifically, the Initial Strategy refers to putting shipping on “a pathway of CO2 emissions reduction consistent with the Paris Agreement temperature goals”.
  2. The IMO Initial Strategy refers to prioritising Short Term measures that can achieve “further reduction of GHG emissions from international shipping before 2023″.
  3. The IMO Initial Strategy aims “to peak GHG emissions from international shipping as soon as possible”.

These three crucial commitments are under threat from a small minority of countries at IMO. A compromised proposal is on the table next week that would result in letting shipping’s 1 billion tonnes of annual emissions keep rising for another decade therefore violating the Paris Agreement, as well as the IMO Initial Strategy. If this attempt to backtrack on the Initial Strategy commitments succeeds, it would weaken the IMO’s status as a global regulator, paving the way for regional CO2 regulations which industry say it does not want

As supporters of the IMO, we urge all countries to respect, and actively reaffirm, the Initial Strategy they have committed to, and not undermine the IMO by backtracking.

Strong, clearly enforced, transparent regulation of shipping’s Carbon Intensity can reduce wasteful and costly fossil fuel consumption, 


  • NABU
  • Climate Generation Europe
  • CMW

NOTES: Under a compromise proposal (ISWG-GHG 7/2/26) between advocates of Operational Efficiency (regulated via Carbon Intensity Indicators) and “Technical” regulation such as the Energy Efficiency Existing Ships Index (EEXI), both policies have been combined. However, it appears the cost imposed by the least ambitious countries as part of this deal is to push back any actual enforcement of Carbon Intensity until 2029/2030.

Specifically, on page 5, section 26 of the proposal it explains that only in 2029 will ships rated “E” not be issued a Statement of Compliance. Ships rated “D” can have until 2030, it is proposed, before they risk losing their Statement of Compliance. (Meanwhile the majority of ships in the world already stamped A, B or C will have no regulatory requirement even in a decade’s time to improve their efficiency, e.g. using available technologies like Fletter rotors and bubble hull lubrication – currently installed on less than 0.1% of the world’s fleet.)

Leaving the operational efficiency of ships voluntary until 2029/2030, as ISWG-GHG 7/2/26 suggests, will allow shipping’s vast 1 billion tonnes of annual GHG emissions to keep rising for the next 10 years at least.

This clearly violates points 2) and 3) above – only enforcing a measure from 2029 will not reduce emissions before 2023, nor will it reduce GHG emissions “as soon as possible”. On point 1), Paris Agreement compliance, climate scientists made clear in last year’s IPCC 1.5 degrees special report, that global emissions have to be cut in absolute terms by approximately -45% by 2030, to stabilise global heating at 1.5C degrees – a temperature goal which all Paris Agreement signatories have committed to pursue.

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