The International Maritime Organization’s Revised Greenhouse Gas Strategy: A Political Signal of Shipping’s Regulatory Future

Abstract

The International Maritime Organization (IMO) 2023 Strategy on Reduction of GHG Emission from Ships offers few specifics from a legal perspective, but is an important political signal. IMO Member States have committed to adopt binding rules to incentivise greenhouse gas emission reductions in 2025 which will enter into force by 2027. Moreover, the Strategy calls for the elimination of shipping emissions by or around 2050 and sets checkpoints to track progress. IMO now faces key decisions to implement the Strategy, including how to structure a goal-based fuel standard, how to integrate an economic element (e.g., an emission levy) into its regulatory framework, its methods for assessing upstream emissions and effects of fuel production, and specific reduction pathways. These measures will likely be effectuated as amendments to Annex VI of the International Convention for the Prevention of Pollution from Ships, leveraging its existing compliance and enforcement tools, including port State controls.