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What IMO MEPC 82 actually decided about shipping decarbonisation

By Muhammad Ali · · 11 min read

MEPC 82 met at IMO headquarters in London from 30 September to 4 October 2024. The headline coming out of the session was that the mid-term measures debate — specifically the choice between a market-based measure (a GHG levy or fuel tax) and a goal-based GHG Fuel Standard — finally narrowed from a wide-open menu to a specific combined proposal. The committee did not formally adopt anything at MEPC 82; it produced draft text that MEPC 83 in April 2025 acted on. Six months on, with MEPC 83 outcomes published and the legal text drafting in progress at MEPC 84, here is the actual decision tree.

I track IMO sessions because half the freight decarbonisation rule book on deep-sea is set at MEPC, and operators routinely conflate "discussed at MEPC" with "agreed at MEPC." They are not the same thing. The MEPC machine moves on a multi-session cycle: a measure is discussed, draft text is developed across two or three sessions, the text is adopted, then enters into force 16 to 22 months after adoption. MEPC 82 was the consolidation session for the mid-term measures; MEPC 83 was the adoption session for the framework; MEPC 84 in October 2025 began the technical detail. Operators planning capex against this regime need to be reading the MEPC reports, not the press releases.

What MEPC 82 confirmed

1. The 2023 GHG strategy stays in place, with the trajectory unchanged

MEPC 80 in July 2023 adopted a revised GHG strategy with three indicative checkpoints: 20% absolute emissions reduction by 2030, 70% by 2040, and net-zero "by or around" 2050, all against a 2008 baseline. MEPC 82 confirmed the strategy text and explicitly closed off member states’ attempts to relitigate the 2050 net-zero target. The 5% and 10% near-term zero-or-near-zero-emission energy targets for 2030 were also confirmed. Anyone hoping the strategy would soften at MEPC 82 was disappointed; if anything, the language firmed up. The MEPC 82 outcomes statement is on the IMO website.

2. The CII rating system continues, with a tightening review on the table

The Carbon Intensity Indicator entered force 1 January 2023 and rates each vessel above 5,000 GT on an A–E scale. The reduction factor — how much each year’s required intensity tightens against the 2019 baseline — was 5% for 2023, 7% for 2024, 9% for 2025, and 11% for 2026. MEPC 82 received MEPC 81’s commissioned correspondence-group review of the CII methodology and confirmed the rating mechanic continues, with the post-2026 reduction-factor schedule to be set by MEPC 84 or MEPC 85. The expected trajectory is a continued ~2 percentage point annual tightening through 2030, but the committee deliberately did not lock that number in at MEPC 82.

What is being reviewed is the formula itself. The current Annual Efficiency Ratio (AER) form is dimensionally dwt-distance-based and treats a partially-laden vessel the same as a fully-laden one. The IMO Marine Environment Protection Committee Working Group on Reduction of GHG Emissions from Ships has had a multi-year debate about moving to a capacity-utilisation-adjusted indicator like cgDIST or EEOI, both of which would change which vessels grade well and which grade poorly. MEPC 82 did not resolve that debate. The acknowledged gap: cargo-utilisation data is not currently in the IMO Data Collection System, and adding it requires a separate amendment to MARPOL Annex VI Chapter 4. My read on the working group: cgDIST is more likely than EEOI, and the change comes at MEPC 86 or later, not at MEPC 84.

3. Mid-term measures: the combined GHG levy plus GHG Fuel Standard

This is the consequential one. Through 2023 and into 2024, IMO member states had been split between two camps. The Marshall Islands, Solomon Islands, and Pacific island states were pushing a per-tonne GHG levy — an explicit price on every tonne of CO2e emitted, with revenue going partly to climate finance and partly to a just transition fund. The European Union and Japan were pushing a Goal-Based Fuel Standard — a regulatory cap on the GHG intensity of fuel used onboard, similar to FuelEU but applied globally, with penalty units for non-compliance but no direct levy.

MEPC 82 narrowed this to a combined proposal: a Greenhouse Gas Fuel Standard (the regulatory cap) plus a price mechanism on emissions above a threshold (effectively a hybrid levy on the residual emissions after the standard kicks in). The draft text developed at MEPC 82 had a tiered structure — vessels below the GHG intensity floor pay nothing; vessels in the middle band pay a "remedial unit" price; vessels failing the standard pay a higher per-tonne penalty. The price levels were left as placeholders for later sessions.

One acknowledged gap: the draft text did not resolve how revenue would be allocated. Several member states pushed for explicit climate finance earmarks; others pushed for a less prescriptive fund structure. MEPC 83 made this slightly more concrete; MEPC 84 in October 2025 narrowed it further but didn’t finalise.

What MEPC 83 (April 2025) added

MEPC 83 was the formal adoption session for the combined measure framework. The committee adopted in principle the structure that MEPC 82 had drafted: a GHG Fuel Standard with a phased tightening trajectory starting in 2027, plus a remedial unit cost structure linked to the standard. The IMO outcomes statement for MEPC 83 sits on the IMO MEPC 83 summary page. The committee also adopted amendments to MARPOL Annex VI to legally underpin the new regime.

The GHG Fuel Standard trajectory adopted at MEPC 83 is more aggressive than what GLEC or industry had been modelling in 2023. The 2030 intensity cap sits at roughly 87.5 g CO2e/MJ WTW — about 4% below the 2008 baseline of 91.16 — with a published staircase to roughly 65 g/MJ by 2040 and ~25 g/MJ by 2050. Those numbers are not yet locked into the legal text; the formal entry-into-force amendment is being drafted across MEPC 84, 85, and 86 with expected adoption in 2026 and entry into force in late 2027.

What is locked in at MEPC 83: the remedial unit price band. Vessels that fall within the intermediate non-compliance zone (above the floor but below the cap) pay roughly USD 100 per tCO2e equivalent on the deficit. Vessels that breach the upper cap pay an additional penalty unit price. These are not final; member states have flagged willingness to revisit at MEPC 84. My take: the USD 100 figure is a placeholder that will likely move in either direction depending on which coalition holds at MEPC 85.

What is confirmed vs what is still draft

To save operators from misreading press coverage, here is the actual status as of mid-2026:

  • Confirmed: 2023 IMO GHG strategy targets (20% by 2030, 70% by 2040, net-zero "by or around" 2050, against the 2008 baseline). 5% / 10% zero-or-near-zero-emission energy targets for 2030. CII rating system continues. MARPOL Annex VI Chapter 4 amendments framework adopted at MEPC 83.
  • Adopted in principle, technical detail pending: The combined GHG Fuel Standard and remedial unit pricing regime. Entry into force expected 2027 at the earliest.
  • Still in draft: The exact 2030 intensity floor and cap values, the remedial unit price level (USD 100 is a placeholder), the revenue allocation between IMO funds, climate finance, and just-transition support, the CII formula revision, and the post-2026 CII reduction-factor trajectory.
  • Not currently on the agenda: A specific aviation-style radiative-forcing factor for shipping (methane slip is handled in the WTW intensity calculation, but there is no upward multiplier applied for non-CO2 forcings). Operators hoping this stays off the agenda probably get their wish through 2030.

Implementation timeline 2026–2030

The actual operator-facing dates, drawn from the MEPC 83 outcomes statement and the MEPC 84 work plan:

  • 1 January 2026: Methane and N2O enter the EU ETS Maritime calculation (this is EU, not IMO — but it is what most operators are tracking right now).
  • 1 January 2026: CII reduction factor moves to 11% below the 2019 baseline. Vessels with C, D, or E ratings face heavier scrutiny.
  • October 2025 (already past): MEPC 84 began the legal text drafting for the Annex VI amendment underpinning the GHG Fuel Standard.
  • April 2026: MEPC 85 expected to narrow technical text. Indicative confirmation of the 2030 intensity cap.
  • October 2026: MEPC 86 expected to adopt the formal Annex VI amendment text.
  • March 2027: Earliest entry-into-force date for the formal amendment, assuming 16-month tacit acceptance window from MEPC 86.
  • 1 January 2028: Realistic operational start date for the GHG Fuel Standard. First reporting cycle would close 31 December 2028.
  • 1 January 2030: GHG Fuel Standard reaches its first published intensity cap milestone. The 20% absolute reduction checkpoint from the 2023 strategy applies.

Two things to note. First, this timeline slipped relative to what some IMO observers were hoping for at MEPC 80 in 2023 (some had projected 2026 entry into force). Second, the IMO regime will sit alongside FuelEU Maritime, not replace it — the EU has been explicit that FuelEU stays in force regardless of what IMO adopts, with a review clause that could see FuelEU adjusted if the IMO regime is materially stronger. For the deep-sea fleet, that means dual reporting and dual compliance from 2028 onwards. My read: the EU will tighten FuelEU rather than relax it when the IMO regime activates. The wider rule book — ETS Maritime, CSRD Scope 3 Category 4, CBAM — is laid out in the 2026 freight compliance checklist.

What this means for fleet capex decisions in 2026

If you are placing newbuild orders this year, the dual-fuel methanol and dual-fuel LNG options remain the rational hedges against the 2030 intensity cap. Pure VLSFO-only newbuilds being ordered today — there are still some — carry the implicit assumption that the operator either retrofits the vessel by 2030 or accepts persistent remedial unit costs through the vessel’s lifetime. Some operators are explicitly betting on the IMO trajectory slipping further; that is a legitimate read of the politics, but it is a bet, not a base case.

The ammonia-fuelled and methanol-fuelled vessels coming into service through 2026 and 2027 will sit comfortably below the 2030 intensity cap on initial bunker mixes, but how comfortably depends on the fuel’s WTW intensity in the buyer’s region. Green ammonia produced from European offshore wind has very different WTW intensity from blue ammonia produced with CCS in the Gulf. The IMO regime uses certified well-to-wake intensity, which means certificate-of-origin paperwork becomes a binding operational requirement, not a nice-to-have. The carriers I’ve talked to are now hiring fuel-supply-chain auditors, not just bunker traders. We document our own methodology against the same WTW boundary so the numbers we surface line up with whichever regime an operator is reporting against.

For the connection between IMO measures and the EU regime, the FuelEU Maritime pool penalty explainer walks through how the same fuel-intensity arithmetic translates into per-tonne penalty exposure under the EU framework. The two regimes use compatible methodologies but produce different numerical outcomes because the EU’s 2025 floor is set tighter than the IMO’s 2028 floor.

What probably comes out of MEPC 86 in late 2026

MEPC 86 in late October 2026 is the session where the formal Annex VI amendment text should be adopted. Three things to watch:

The final 2030 intensity cap. Currently sitting around 87.5 g CO2e/MJ in draft text. The G20 climate negotiations through 2026 will likely push for a tighter number; the African and small-island bloc will lobby for an earlier-trajectory tighter cap; the BIMCO / WSC carrier coalition will lobby for a wider safety margin. My read: the final number lands between 86 and 89 g/MJ.

The remedial unit price. The MEPC 83 placeholder of USD 100/tCO2e equivalent could rise to USD 150–200 under pressure from the Pacific bloc, or drop to USD 50–75 if the carrier coalition holds. Watch the Marshall Islands and Solomon Islands proposals at MEPC 85 in April for the direction of travel.

Revenue allocation. Where the money goes is what determines whether the developing-world bloc supports the final amendment text. The currently-favoured structure routes most revenue through a dedicated IMO Climate Action Fund with earmarked just-transition allocations; the alternative would be a national-revenue model that critics argue would dilute the climate-finance purpose. The political negotiation is unresolved.

One thing not on the agenda for MEPC 86 that probably should be: a clear interaction protocol with regional schemes (EU ETS Maritime, FuelEU, the UK ETS Maritime extension). Operators have flagged the double-compliance burden repeatedly; the IMO secretariat has acknowledged it; the committee has not yet developed text. That gap continues into 2027 at minimum.

Closing

MEPC 82 was the consolidation moment for the mid-term measures debate. MEPC 83 was the adoption moment for the framework. MEPC 84 began the legal text; MEPC 85 in April will narrow the technical detail; MEPC 86 in October 2026 is the realistic adoption date for the formal Annex VI amendment. Entry into force on the current trajectory sits in 2028, not 2026 as some operators had hoped. The fleet capex decisions being made right now should price in dual-fuel readiness and certified WTW fuel origin documentation, not the press-release narrative that everything is suddenly five years away. For the GLEC factor mechanics that feed into IMO WTW intensity calculations — particularly the methane-slip revision in v3.2 — see the GLEC v3.2 explainer.

Sources

IMO Marine Environment Protection Committee 82 outcomes statement, October 2024 — imo.org/en/MediaCentre/MeetingSummaries/Pages/MEPC-82.aspx. IMO MEPC 83 outcomes statement, April 2025 — imo.org/en/MediaCentre/MeetingSummaries/Pages/MEPC-83.aspx. IMO 2023 GHG Strategy revision text (resolution MEPC.377(80)) — imo.org/en/OurWork/Environment/Pages/2023-IMO-Strategy-on-Reduction-of-GHG-Emissions-from-Ships.aspx. CII rating system in MARPOL Annex VI Chapter 4 regulations. Working Group on Reduction of GHG Emissions from Ships, intersessional correspondence-group reports for the CII formula review.