Greenhouse gases (GHG) emissions

Overview

BIMCO's position on "greenhouse gases emissions" has been approved by the BIMCO Board of Directors.

Background

Reduction of GHG emissions from international shipping has been on the IMO agenda for many years. Regulatory requirements for new ships’ energy efficiency were incorporated in MARPOL Annex VI in 2011 and also a requirement for all ships to carry a ship specific energy efficiency management plan (SEEMP).

Parties to the United Nations Framework Convention on Climate Change (UNFCCC) have repeatedly recognised that their framework convention is unsuitable to address emissions from international shipping, and left the initiative to IMO. The Paris Agreement, adopted at COP 21 in December 2015, is silent about emissions from international shipping.  It does, however, expect all sectors of the economy to contribute to the global efforts.

The IMO has agreed to pursue further discussion on GHG emissions via a 3-step approach, with the first step being a data collection scheme to form the basis of the second step, being data analysis. The third step is a discussion and potential agreement on further measures to enhance energy efficiency in international shipping if required.  The IMO also agreed to a Road Map to develop a Comprehensive IMO GHG Strategy by 2023.The initial strategy was adopted at MEPC 72 in April 2018 with a vision to de-carbonise as soon as possible. The strategy contains the following objectives:

  • carbon intensity of the ship to decline through implementation of further phases of the energy efficiency design index (EEDI) for new ships to review with the aim to strengthen the energy efficiency design requirements for ships with the percentage improvement for each phase to be determined for each ship type, as appropriate;
  • carbon intensity of international shipping to decline to reduce CO2 emissions per transport work, as an average across international shipping, by at least 40% by 2030, pursuing efforts towards 70% by 2050, compared to 2008; and
  • GHG emissions from international shipping to peak and decline to peak GHG emissions from international shipping as soon as possible and to reduce the total annual GHG emissions by at least 50% by 2050 compared to 2008 whilst pursuing efforts towards phasing them out as called for in the Vision as a point on a pathway of CO2 emissions reduction consistent with the Paris Agreement temperature goals.

BIMCO’s position

  • Regulation of GHG must be adopted within IMO and be transparent, harmonised and applicable to all ships. Any possible GHG regulation for shipping should not limit transport supply. The objective is to limit GHG emissions from ships without compromising the shipping industry’s irreplaceable role in the global supply chain.
  • The mandatory Energy Efficiency Design Index (EEDI) for new ships and the SEEMP for all ships are effective regulation of CO2 emissions and provide, in BIMCO’s view, a tangible contribution to the global efforts to combat climate change.  The strengthening of EEDI targets, as called for in the IMO GHG strategy, should be implemented through the introduction of additional phases rather than amending the existing agreed phases.
  • BIMCO supports the agreed 3-step approach to enhancing energy efficiency of international shipping and welcomes the IMO adoption of a mandatory data collection scheme as the first step. Furthermore, in-sector emissions reduction efforts should be part of the Comprehensive IMO GHG Strategy.
  • BIMCO has established a set of guiding principles for GHG policy work:
  1. Aspirational targets should be realistic and deliverable, without a need to buy off-sets.
  2. The industry should not be required to contribute to the UNFCCC Green Fund.
  3. Funds should be collected in the industry for research and development (R&D) and for improvement of the existing fleet.
  • BIMCO welcomes the initial IMO GHG strategy and supports its vision and objectives. BIMCO is concerned about a potential future mandatory speed limit, as it not only raises serious enforcement issues but is also unequitable when applied to individual ships.
  • Operational efficiency indices, such as the IMO Energy Efficiency Operational Indicator (EEOI), are overly simplistic or even misleading on an individual ship basis and therefore irrelevant, and should not be considered for regulatory purposes. Also, such indices could be wrongly perceived as valid selection criteria when assessing the efficiency of a ship prior to chartering. 
  • Regulations should provide incentives for owners to invest in low-carbon technology. If technical and operational measures cannot wholly meet agreed reduction targets, then any funds generated by means of a globally applied Market Based Measure (MBM) for shipping must be controlled by the IMO and mostly be disbursed to support further technological development focused on energy efficiency in shipping aimed at new and existing ships.
  • BIMCO insists that it is imperative that EU must align its MRV regulation to IMO’s data collection system.

 

Rasmus Nord Jorgensen
in Copenhagen, DK

ELSEWHERE ON BIMCO

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