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IMO Adopts Measures To Reduce Ships’ Carbon Intensity

Source: International Maritime Organization (IMO)- MediaCentre on 17 June 2021

New mandatory measures to cut the carbon intensity of international shipping have been adopted by the International Maritime Organization (IMO), setting shipping on a course to meet greenhouse gas reduction targets established in the 2018 Initial IMO Strategy for Reducing GHG Emissions from Ships.

IMO’s Marine Environment Protection Committee (MEPC 76), meeting in a remote session from 10 to 17 June 2021, adopted amendments to the International Convention for the Prevention of Pollution from Ships (MARPOL) Annex VI that will require ships to reduce their greenhouse gas emissions. These amendments combine technical and operational approaches to improve the energy efficiency of ships, also providing important building blocks for future GHG reduction measures.

The new measures will require all ships to calculate their Energy Efficiency Existing Ship Index (EEXI) following technical means to improve their energy efficiency and to establish their annual operational carbon intensity indicator (CII) and CII rating. Carbon intensity links the GHG emissions to the amount of cargo carried over distance travelled.

Ships will get a rating of their energy efficiency (A, B, C, D, E – where A is the best). Administrations, port authorities and other stakeholders as appropriate, are encouraged to provide incentives to ships rated as A or B also sending out a strong signal to the market and financial sector.

A ship rated D for three consecutive years, or E, is required to submit a corrective action plan, to show how the required index (C or above) would be achieved.

IMO Secretary-General Kitack Lim said the adoption of the new measures would build on IMO’s previously adopted mandatory energy efficiency measures, to lead shipping on the right path towards decarbonization.

“The path to decarbonization is a long, but also a common path in which we need to consider and respect each other’s views. We have made a considerable amount of progress since the start of our journey,” Mr. Lim said, ” … your progress will continue to provide the benefit of experience to be able to make ambitious, and evidence-based decisions for phase 3 of the implementation of the operational measure which will be further strengthened and developed taking into account the review of the short-term measure and the latest climate science,” he added.

The amendments to MARPOL Annex VI (adopted in a consolidated revised Annex VI) are expected to enter into force on 1 November 2022, with the requirements for EEXI and CII certification coming into effect from 1 January 2023. This means that the first annual reporting will be completed in 2023, with the first rating given in 2024.

A review clause requires the IMO to review the effectiveness of the implementation of the CII and EEXI requirements, by 1 January 2026 at the latest, and, if necessary, develop and adopt further amendments. 

Impact assessment

In adopting the measure, MEPC also considered the outcomes of a comprehensive impact assessment of the measure which examined potential negative impacts on States, and agreed to keep the impacts on States of the measure under review so that any necessary adjustments can be made.

In adopting the amendments, the MEPC agreed in its resolution to undertake a lessons-learned exercise from the comprehensive impact assessment of the amendments to MARPOL Annex VI, with a view to improving the procedure for conducting future impact assessments.

Secretary-General Lim welcomed the approval and consideration of the outcome of the related comprehensive impact assessment and the decision to keep impacts of the measure under review and to initiate a lessons-learned exercise.

MARPOL Annex VI has 100 Contracting States, who between them represent 96.65% of world merchant shipping by tonnage.

The MEPC also adopted a work plan to develop mid-and long-term measures to further cut shipping’s GHG emissions, in line with the Initial IMO Strategy on reduction of GHG from ships

Guidelines adopted

Alongside the MARPOL amendments, the MEPC adopted related guidelines to support the implementation of the amendments.  (full list below).

The guidelines include the 2021 Guidelines on the operational carbon intensity reduction factors relative to reference lines (CII Reduction factor Guidelines, G3). This includes the required reduction (Z) factor, which is set at a rate, relative to 2019, of 11% by 2026. This would  be further strengthened after that date, taking into account the review of the measure and latest climate science.

Meeting the initial GHG strategy ambition

The combined technical and operational measures referred to as short-term carbon intensity measures, are in line with the ambition of the Initial IMO GHG Strategy, which aims to reduce the carbon intensity of international shipping by 40% by 2030, compared to 2008.

The initial strategy sets out short- mid-and long-term measures. The measures just adopted fall into the short-term measures.

Future work

The MEPC discussed a number of submissions on how to progress the next stages of IMO’s work to cut GHG emissions from ships, leading to the revision of the initial GHG strategy in 2023.

The MEPC adopted a work plan on the concrete way forward to make progress with candidate mid-and long-term measures including measures to incentivize the move away from fossil fuels to low- and zero-carbon fuels to achieve decarbonization of international shipping.

A proposal initially considered by MEPC suggested a mandatory levy of $100 per tonne carbon dioxide equivalent on heavy fuel oil. This proposal will be further considered at the inter-sessional working group meeting in the context of the adopted work plan along with other proposals for mid-term measures.

The work plan envisages three phases:

•Phase I – Collation and initial consideration of proposals for measures (Spring 2021 to spring 2022);

•Phase II – Assessment and selection of measures(s) to further develop (Spring 2022 to spring 2023); and

•Phase III – Development of(a) measure(s) to be finalized within (an) agreed target date(s).

Mr. Lim welcomed the adoption of the work plan.

“Concessions have been made on all sides in the interest of securing the framework we have in place. Our consideration of mid-and long-term measures will demand even more of us. I am very pleased that the Committee has agreed on a work plan to support carrying out this dimension of our work in a structured way that will keep the membership together,” Mr. Lim said.

“Agreement on the work plan sends the signal that the Organization and its Member States are ready to further consider the current and future proposals for mid-term measures. We need to gear up work relating to the various phases of the work plan in order to give efficient and adequate consideration to concrete proposals for the reduction of greenhouse gases in keeping with our goals in the initial strategy.  Let us continue to work together on the tasks you have in front of you as we continue to make progress on this common path,” he said.

IMRB proposal

The Committee had a non-exhaustive consideration of a proposal to establish an International Maritime Research Board, funded by a tax on oil fuel used by shipping. The discussion will resume at the Committee’s next session.

Correspondence Group and Intersessional Working Group

The MEPC approved the terms of reference for a Correspondence Group on Carbon Intensity Reduction and meetings of the Intersessional Working Group on Reduction of GHG Emissions from Ships (ISWG-GHG 9 and ISWG-GHG 10). The ISWG-GHG 9 will meet 15-22 September and ISWG-GHG 10 18-22 October 2021, ahead of MEPC 77, which is scheduled to meet 22-26 November 2021.

MEPC 76 – other outcomes

The MEPC also adopted other amendments.

Prohibiting HFO in the Arctic

The MEPC adopted amendments to MARPOL Annex I (addition of a new regulation 43A) to introduce a prohibition on the use and carriage for use as the fuel of heavy fuel oil (HFO) by ships in Arctic waters on and after 1 July 2024.

The prohibition will cover the use and carriage for use as the fuel of oils having a density at 15°C higher than 900 kg/m3 or a kinematic viscosity at 50°C higher than 180 mm2/s. Ships engaged in securing the safety of ships, or in search and rescue operations, and ships dedicated to oil spill preparedness and the response would be exempted. Ships that meet certain construction standards with regard to oil fuel tank protection would need to comply on and after 1 July 2029.

A Party to MARPOL with a coastline bordering Arctic waters may temporarily waive the requirements for ships flying its flag while operating in waters subject to that Party’s sovereignty or jurisdiction, up to 1 July 2029.

The amendments were approved at MEPC 75, see

Amendments to MARPOL Annexes I and IV concerning the exemption of UNSP barges from survey and certification requirements

The MEPC adopted amendments to  MARPOL Annexes I and IV concerning the exemption of UNSP barges from survey and certification requirements.

The amendment specifies that the Administration may exempt a UNSP barge from the annual survey and certification requirements, for a period not exceeding 5 years provided that the UNSP barge has undergone a survey to confirm that certain conditions are met.

The amendments also provide the form for the International Oil Pollution Exemption Certificate for Unmanned Non-self-propelled Barges. The MEPC also approved a related circular on guidelines for exemption of UNSP barges.

The amendments were approved at MEPC 75, see

Amendments to AFS Convention – cybutrene

The MEPC adopted amendments to the IMO Convention for the Control of Harmful Anti-fouling Systems on Ships (AFS Convention), to include controls on the biocide cybutryne.

The AFS Convention already prohibits the use of biocides using organotin compounds.

The draft amendments were approved at MEPC 75, see

Further information

Carbon intensity measures in detail

The short-term measure is aimed at meeting the target set in the IMO Initial GHG Strategy – to reduce carbon intensity of all ships by 40% by 2030, compared to 2008. These will be mandatory measures under MARPOL Annex VI. They will bring in

•Attained Energy Efficiency Existing Ship Index (EEXI) is required to be calculated for ships of 400 gt and above, in accordance with the different values set for ship types and size categories. This indicates the energy efficiency of the ship compared to a baseline. Ships are required to meet a specific required Energy Efficiency Existing Ship Index (EEXI), which is based on a required reduction factor (expressed as a percentage relative to the EEDI baseline).

•Annual operational carbon intensity indicator (CII) and CII rating.

The CII determines the annual reduction factor needed to ensure continuous improvement of the ship’s operational carbon intensity within a specific rating level.  The actual annual operational CII achieved (attained annual operational CII) would be required to be documented and verified against the required annual operational CII.

This would enable the operational carbon intensity rating to be determined.  The rating would be given on a scale – operational carbon intensity rating A, B, C, D or E – indicating a major superior, minor superior, moderate, minor inferior, or inferior performance level. The performance level would be recorded in the ship’s Ship Energy Efficiency Management Plan (SEEMP).

A ship rated D for three consecutive years, or E, would have to submit a corrective action plan, to show how the required index (C or above) would be achieved.

Administrations, port authorities and other stakeholders as appropriate, are encouraged to provide incentives to ships rated as A or B.

In simple terms, the short-term term measure are aimed at achieving the carbon intensity reduction aims of the IMO initial GHG Strategy.

They do this by requiring all ships to calculate their Energy Efficiency Existing Ship Index (EEXI) and to establish their annual operational carbon intensity indicator (CII) and CII rating

In other words, ships get a rating of their energy efficiency (A, B, C, D, E – where A is the best). A ship running on a low carbon fuel clearly gets a higher rating than one running on fossil fuel.

However, there are many things a ship can do to improve its rating through various measures, such as hull cleaning to reduce drag; speed and routing optimization; installation of low energy light bulbs; installation of solar/wind auxiliary power for accommodation services; etc.


The following comprehensive set of guidelines, adopted by MEPC 76, support the new requirements:

•2021 Guidelines on the method of calculation of the attained energy efficiency existing ship index (EEXI);

•2021 Guidelines on survey and certification of the energy efficiency existing ship index (EEXI);

•2021 Guidelines on the shaft/engine power limitation system to comply with the EEXI requirements and use of a power reserve;

•2021 Guidelines on operational carbon intensity indicators and the calculation methods (CII Guidelines, G1);

•2021 Guidelines on the reference lines for use with operational Carbon Intensity Indicators (CII reference lines guidelines, G2);

•2021 Guidelines on the operational carbon intensity reduction factors relative to reference lines (CII Reduction factor Guidelines, G3);

•2021 Guidelines on the operational Carbon Intensity rating of ships (CII rating guidelines, G4).

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EEXI and CII- The Factual and Contractual Considerations!

Despite the fact that January 2023 may appear to be a long way off, shipowners and operators must evaluate the impact of the Energy Efficiency Existing Ship Index and the Carbon Intensity Index.


For centuries, ships and vessels have been used to move cargo, beginning with self-propelled craft and progressing to sailing ships that harness the power of the wind to propel the vessel. Of course, such modes of transportation have a negligible carbon footprint. Steam-powered ships eventually replaced sailing vessels, giving rise to today’s commercial fleets powered by fuel oil, diesel oil, and, in some instances, LNG. The shipping sector aims to go full circle, at least in terms of minimizing carbon emissions, while also looking for inventive ways to retain efficiency, as the vital issues of climate change and ensuring a low carbon footprint rightfully come to the fore.

EEXI – The Energy Efficiency Existing Ship Index

EEXI – The Energy Efficiency Existing Ship Index is the latest measure to decarbonize shipping, focusing on greenhouse emissions rather than sulphur. The International Maritime Organization (IMO’s) suggests creating a minimum efficiency requirement for current ships based on design parameters. The Energy Efficiency Design Index (EEDI) is a variation of the EEXI that applies to new ships built after 2013. The EEXI is based on CO2 emissions per tonne mile, with the vessel’s installed power and cargo-carrying capacity being the essential components in its computation. When that goes into effect in January 2023, the EEXI will be a one-time ‘pass or fail’ paperwork test conducted at the first annual or special survey and will impact more than half of the world fleet.

Carbon Intensity Index (CII)

Whereas the EEXI is a one-time certification that focuses on design specifications, the Carbon Intensity Index (CII) is an annual examination of a ship’s actual carbon emission performance over the previous year, beginning in January 2023. It measures how effectively a ship delivers products or passengers in terms of grams of CO2 emitted per cargo-carrying capacity and nautical miles.

CII compliance will necessitate extensive planning to develop technical and operational solutions to improve vessel emissions performance. Noncompliance and/or low ratings are unlikely to have severe consequences until 2026, but it will be interesting to observe whether, in addition to remedial action, the market will generate its own practical sanctions in the longer future.


The proposed adjustments will affect all ships built before 2010, which burn significantly more fuel than current designs. They will also affect 60-70 percent of bulk carriers, primarily those larger than Panamax, and a considerable percentage of tankers, primarily those larger than Aframax, as well as LNG carriers and 250 steam turbine ships around the world. Slow-steaming, weather routing, optimized port rotation, cargo intake reduction, and the use of alternative fuels such as biofuels and LNG are just a few of the methods owners can use to cut CO2 emissions.

Contractual and Factual Considerations

With the introduction of the EEXI and CII fast approaching, owners and operators should consider the legal issues that may arise. Any first adjustments to satisfy EEXI criteria will almost certainly fall on the shipowner, who must comply with MARPOL and will certainly have contractual duties to ensure compliance with the convention and its regulations under charter parties. Owners and charterers will have to carefully assess their alternatives for time charters that run after 2023 and beyond. Shipowners, for example, may need to make sure that stipulations in their draught contracts allow them to address all technical issues emerging from the new IMO decarbonization obligations imposed by EEXI and CII. Owners may wish to make sure that they have the freedom to upgrade their vessels with new technologies before the new restrictions take effect in January 2023 or that they can take corrective action after that date. Owners may, for example, desire the ability to arrange for dry-docking the vessel during the charter for modifications or an additional dry-dock, so temporarily removing the ship from the charterers’ service without violating the charter.


Like it always does, the shipping sector will adjust to the significant new legislation aimed at reducing carbon emissions, and it is hoped that boats can be operated efficiently in the future from both an environmental and commercial standpoint. Owners and charterers will, as always with the introduction of new legislation, need to carefully evaluate the commercial, legal, and contractual position between themselves in advance to prevent potential problems when the new restrictions take effect.

Contact Frugal to know more about solutions that will help you to comply with these new regulations and make your Sea Journey a non-stoppable voyage.