The IMO Net-Zero Framework combines a fuel standard with a mechanism for pricing emissions. It was substantially advanced at MEPC 83 in 2025 and is based on the 2023 revised IMO GHG Strategy, which targets a reduction of greenhouse gas emissions from international shipping by at least 20 % by 2030 (striving for 30 %), 70 % by 2040 (striving for 80 %) and net zero by around 2050 compared to 2008.
The framework consists of two main elements:
Global Fuel Standard (GFS): A worldwide fuel standard setting the maximum permissible GHG intensity of energy used on board on a well-to-wake basis. The concept resembles FuelEU Maritime but is intended to apply globally, making it relevant for operators outside EU/EEA waters as well. The precise limits and timeline were negotiated at MEPC 83 and are expected to be finalised at MEPC 84 (2026).
Economic mechanism: An economic mechanism that prices emissions – either as a levy per tonne of CO2 or as an emissions trading system (similar to the EU ETS). The current discussion at IMO level tends towards a combination: a GFS with compliance flexibility (similar to banking/borrowing/pooling under FuelEU) supplemented by a levy on emissions exceeding the standard. Revenue is intended to flow into a fund supporting developing countries in the transition to clean fuels.
Critically: the framework is not a finished rulebook but a negotiation process. Binding implementation requires amendments to MARPOL Annex VI, which could be adopted at the earliest in 2027–2028 and become effective from 2028–2030 after a transition period.
The framework targets large ocean-going vessels that account for the majority of CO2 emissions. The precise threshold is still being negotiated, but vessels above 5,000 GT are expected to be captured – analogous to MARPOL Annex VI, the EU ETS and FuelEU Maritime. Some states and NGOs are pushing for a lower threshold of 400 GT to include smaller vessels; however, this is politically contentious.
The impacts affect different segments differently:
Containers and tankers: As the largest emitters, these segments are in focus. Container ships on transcontinental routes and VLCCs generate the highest absolute emissions and will feel the strongest financial pressure from the economic mechanism.
Bulkers: With their large fleet numbers and long remaining service lives, bulkers form the backbone of the emission reduction task. The challenge: many bulkers are operated by small shipping companies with limited resources.
Passenger vessels and ferries: Already under EU regulation (ETS + FuelEU + shore power from 2030). The IMO framework extends pressure to non-EU routes.
Offshore and specialist tonnage: Dependent on the final threshold and any exemptions. The discussion about special provisions for certain vessel types (e.g. icebreakers, research vessels) is not yet concluded.
For operators with mixed fleets, a multi-layered compliance landscape emerges: EU waters (ETS + FuelEU), IMO global (GFS + levy) and potentially further regional systems (e.g. China, South Korea). The challenge lies in coherent implementation across all regimes.
The framework changes technical decisions across the entire value chain. For the marine engineer and superintendent, this is not an abstract regulatory topic – it has direct consequences for daily work:
Engine selection: Anyone ordering a newbuild today must factor the GFS into the engine specification. A MAN ME-C on conventional fuel will likely no longer meet the GFS from 2030. Dual-fuel capable engines (ME-GI, ME-LGIM, ME-LGIA) become a minimum requirement, even if no clear decision on the long-term fuel can be made today.
Retrofit planning: Existing vessels with 10+ years remaining service life must now be prepared for the GFS. This means: designing fuel systems so that a later switch to methanol, ammonia or other fuels is technically possible (“fuel ready” concept). This requires space reserves for additional tanks, piping and safety systems.
Docking decisions: The next docking may be the last opportunity to economically carry out certain retrofits (shore power, fuel-ready preparation, OCCS). Docking plans should incorporate IMO scenarios.
Spare parts strategy: If a fuel switch is planned in 5–8 years, the spare parts strategy for the current system must be adjusted. It is not sensible to conclude long-term spare parts contracts for a system that will become obsolete within a few years.
Emission data management: The IMO framework will introduce a global reporting obligation that goes beyond the EU MRV system. Operators who already have robust data collection in place are at an advantage. Those who react only when the regulation enters into force will face compliance problems.
Operators should segment their fleets into simple risk groups and develop robust scenarios. Three action areas are priorities:
1. Fleet segmentation: Divide your fleet into three groups: (a) vessels to be recycled before 2030 – efficiency measures and ETS management suffice; (b) vessels with 5–12 years remaining service life – bridge measures (OCCS, biofuel blending, speed optimisation) must be evaluated; (c) vessels with 12+ years remaining life or newbuilds – a fuel-switch strategy is mandatory.
2. Scenario planning: Develop three scenarios for the GFS and the economic mechanism: (a) moderate GFS with low levy (USD 10–20/t CO2); (b) ambitious GFS with medium levy (USD 50–100/t CO2); (c) strict GFS with high levy (USD 100–150/t CO2). Calculate the financial impact on each vessel category and the overall fleet.
3. Technical preparations: At every upcoming docking, assess whether “no-regret” measures make economic sense: creating space reserves for future tank installations, retrofitting shore power connections (where electrical work is already scheduled), strengthening data collection systems.
The IMO framework may still be in the negotiation process, but the direction is clear: international shipping is moving towards a global system that prices emissions and regulates the GHG intensity of fuels. Those who do not prepare now will face very expensive, hastily implemented retrofits in 3–5 years.
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