Japan has filed a formal proposal with the International Maritime Organization (IMO) seeking substantial revisions to the proposed Net-Zero Framework (NZF), arguing that mandatory payments into an IMO fund should be scrapped in favour of flexible, market-based compliance alternatives, according to Ship & Bunker.
Trading Units Over Mandatory Payments
As reported by Ship & Bunker, Japan submitted its proposal to the IMO’s Maritime Environment Protection Committee on March 18, calling for ships that fall short of GHG fuel intensity (GFI) targets to be permitted to offset their deficits through the trading of surplus compliance units. Under the current framework design, vessels missing emissions benchmarks would instead be required to make direct payments into the proposed IMO Net-Zero Fund — a mechanism that effectively functions as a global carbon pricing instrument.
Japan’s position, according to the report, is that broadening access to trading mechanisms would provide shipowners with greater operational flexibility. The proposal also responds to concerns raised by certain IMO member states who view the mandatory payment structure as equivalent to a global carbon tax.
Emissions Targets Also in the Crosshairs
Beyond the funding mechanism, Ship & Bunker reports that Japan is also pushing for a recalibration of the framework’s emissions targets. Tokyo has warned that current thresholds may be overly stringent and could restrict the viability of transitional fuels, including LNG. Japan has proposed that both base and direct compliance targets be recalculated using revised transport demand projections and anticipated gains in fuel efficiency, while maintaining alignment with the IMO’s broader 2050 net-zero ambition.
According to Ship & Bunker, Japan has framed its submission as a contribution toward closing the gap between diverging member state positions, ahead of what are expected to be critical negotiations on the IMO’s mid-term GHG measures.
MEPC 84 on the Horizon
The proposal arrives as the shipping industry prepares for the 84th session of the Marine Environment Protection Committee (MEPC 84), which Ship & Bunker notes is scheduled to convene from April 27 to May 1. The session is expected to serve as a key milestone in finalising the architecture of the IMO’s mid-term climate measures.
Gulf Bunkering does not provide operational or security guidance. This article is for informational purposes only. Operators should consult flag state authorities, P&I clubs, and relevant advisories for decisions relating to transit planning.
Sources: Ship & Bunker


