ISWG-GHG 20: Key outcomes

Lloyd’s Register (LR) has provided a summary of the key outcomes of IMO’s Intersessional Working Group on Reduction of GHG Emissions from Ships (ISWG-GHG 20), which took place 20-24 October.

As MEPC’s Extraordinary Session (MEPC ES.2) was adjourned, there was a lot of uncertainty regarding the future work of IMO on regulations reducing GHG. However, according to LR, the Intersessional Working Group demonstrates that the work is continuing. The below are the main points from this week:

• IMO is continuing to develop guidelines that are envisaged in the IMO Net-Zero Framework;
• That MEPC 84 (April/May 2026) will discuss options around resuming MEPC ES.2 which is expected in October 2026;
• Confirmation that ISWG-GHG 21 will still meet in April 2026, the week before MEPC 84; and
• That the terms of reference for the 5th IMO GHG Study will be concluded at MEPC 84.

Consequential update as a result of the NZF not being adopted

There was some uncertainty if the ISWG-GHG would be convened this week in light of the adjournment of the MEPC ES.2. At the outset it was clarified that the ISWG-GHG must fulfil its terms of reference received from MEPC 83 (April 2025).

During the week the Member States sought clarity from the Chair and the Secretariat on what the adjournment meant for issues such as the ability to amend or work on the NZF before the resumption of the MEPC ES.2, as well as if further developing guidelines is relevant at this point in time.

The IMO Secretariat later offered some clarification on the work surrounding the Net-Zero Framework whilst acknowledging that the ISWG-GHG 20 terms of reference was not to consider this matter:

• The IMO Secretariat is still analysing the impact of the adjournment of the MEPC ES.2;
• MEPC 83 (April 2025) agreed the agenda for MEPC 84 (May 2026). There is a provisional agenda and Member States have been invited to attend;
• The agenda for MEPC 84 includes item 13 on the work programme, where MEPC 84 will be able to consider the programming of the reconvened MEPC ES.2, including the exact dates it will take place;
• ISWG-GHG 21 (takes place the week before MEPC 84) will pre-consider documents submitted to MEPC 84 that are within its terms of reference.

Guidelines supporting the NZF

MEPC ES.2 finalised a work plan to consider the proposed guidelines in support of the NZF. The work plan was subject to adoption of the NZF, which did not take place, so we believe it will be further confirmed at the MEPC ES.2 resumption expected in Autumn 2026. When considering the various guidelines, it was agreed to not conclude any specific requirements at this point and to use this time to share views in the hope of finding a consensus going forward.

Reward for the use of Zero or Near Zero GHG emissions fuels and technologies

When considering the design of a reward for the use of Zero or Near-Zero GHG emissions fuels and technologies, most delegations expressed a desire for the Reward to be fuel/technology and feedstock agnostic, but it was also acknowledged that there is a balance between rewarding fuels and technology available today versus longer term technology readiness. It was also noted that many want the reward to be simple in design and easy to manage. There is still a range of views on the reward with many asking for a flat reward for the first 5 years, but others want to consider auctions and other reward designs.

IMO Net-Zero Fund

It was concluded that further work was needed on a number of elements related to the implementation of the IMO Net-Zero Fund. This included:

• Legal status of the governing provisions
• Participation on non-Party and observer organisations in the Governing Board
  
  The possibility of holding a GHG Expert Workshop to develop governing provisions of the Fund will be considered at MEPC 84.

GHG Fuel Intensity (GFI) and GFI compliance approaches

ISWG-GHG 20 focussed on exchanging views and not on concluding matters, noting the Net-Zero Framework adoption was adjourned, ISWG-GHG 20 invited delegations to work together intersessionally on development of guidelines on GFI compliance approaches and submit these to a future session.

Terms of Reference for 5th GHG study

The IMO’s 5th GHG Study is due to commence in 2026, with approval scheduled for Spring 2028. The IMO GHG Studies are used as a measure of the fleet’s emissions profiles, both as a measure of the success of existing regulations and to inform decisions on future regulations. The terms of reference were discussed and provisionally inter alia include:

• Provide an inventory of total annual GHG emission series from 2018 to 2025/6, or as far as that is possible with the statistical data available.
• Provide emission estimates for domestic and international voyages according to two methods – the “voyage-based allocation” and the “vessel-based allocation” of emissions.
• Develop clear and unambiguous definitions and refine methods for differentiation between domestic and international voyages with the aim to exclude domestic voyages from the inventory for “international shipping” to mitigate the risk of the double counting of emissions from ships.
• The emission estimate should include a thorough review of the methodology and assumptions used in the inventory forming part of the Fourth IMO GHG Study 2020, taking into account peer-reviewed/high-quality literature work undertaken since publication of the Fourth IMO GHG Study 2020.
• Estimates of GHG fuel intensity should be included, along with the share of zero- or near zero fuels and energy sources. GHG fuel intensity should be provided in well-to-tank, tank-to-wake and well-to-wake phases.
• The world fleet CO2 emissions and energy consumed (MJ) per transport work should be included for 2018-2025/6, based on the statistical data available.
• Emission estimates are to ensure that tank-to-wake estimates are comprehensive and include fugitive emissions, operational releases, and both combusted and non-combusted fuel emissions.
• Assessment of the embedded carbon of all equipment and infrastructure required for well-to-wake provision of the fuels and energy sources. This should include any depreciation, recyclability and other circular economy considerations for that pathway and vessels.

Further work will continue at MEPC 84 to approve the terms of reference and initiate the tendering process for the commencement of the study.

Fuel Lifecycle Assessment (LCA) Framework

It was noted that MEPC 84 (April/May 2026) is the next time the LCA Guidelines can be amended. The working group on Life Cycle GHG Intensity of Marine Fuels (GESAMP-LCA) may not be able to address all methodological issues whilst it prioritises the assessment of emissions factors which have been submitted to it. It was also acknowledged that there is a need to consider, within the LCA framework, ‘avoided emissions’ and ‘net-negative’ emissions fuels and technologies.

Outstanding unrelated MARPOL Amendments

It’s worth noting that a further consequence of the adjournment of the MEPC ES.2 meeting last week was that several amendments to MARPOL Annex VI were not adopted, although they have no impact on the NZF:

• Designation of the North-East Atlantic Ocean as an Emission Control Area for SOx & particulate matter and for NOx.
• IMO ship fuel oil consumption system (IMO DCS) data accessibility
• Review of the short-term GHG reduction measure
• Use of multiple engine operational profiles for a marine diesel engine related to NOx requirements
• Clarification of entries in data reporting required by regulations 27 and 28

It is yet to be confirmed how or when these will be adopted. It could be that they are separated from amendments which are in adjournment so that they can be adopted before the NZF is further considered, and therefore they could be adopted separately.

source : safety4sea