The European Union has signalled it is prepared to consider alternatives to the IMO Net-Zero Framework (NZF), but only if any replacement measure satisfies four specific conditions, according to a draft submission to the International Maritime Organization seen by Ship & Bunker.
The document, circulated to EU member states as an advance copy from the European Commission on July 6, is due to be filed with the IMO ahead of a July 20 deadline. It is co-sponsored by all 27 EU member states plus the Commission and is aimed at the 22nd Intersessional Working Group on GHG (ISWG-GHG 22), scheduled for September 1 to 4, Ship & Bunker reports.
Four Conditions for Any Alternative
According to the draft cited by Ship & Bunker, the co-sponsors state they are seeking “the widest level of support possible” for the final package of mid-term GHG reduction measures. Any replacement to the NZF must, per the draft: achieve well-to-wake net-zero emissions by or around 2050; incentivise the energy transition from the outset; be enforceable across compliance options while offering flexibility that avoids stranding assets; and support a just and equitable transition with “clear and plausible” funding mechanisms for developing nations, particularly small island developing states and least developed countries.
Where the EU Draws the Line
Ship & Bunker reports that the EU insists any measure must be introduced as regulatory text under MARPOL Annex VI and adopted via the tacit acceptance procedure — a position that directly contradicts the United States’ demand at MEPC 84 for an explicit acceptance procedure. The draft also calls for flexibility for ships unable to source low-GHG fuels at the ports they serve, though it maintains that reducing the GHG intensity of energy used should remain the most attractive compliance route.
Notably, according to Ship & Bunker, the draft avoids taking any position on individual fuel types, with no mention of biofuels, crops, or indirect land use change (ILUC) — a contrast to the EU’s own FuelEU Maritime rules, which effectively exclude crop-based fuels from compliance. The report notes this silence will be closely watched by producers of crop-based fuels such as ethanol.
A Crowded Negotiating Field
Ship & Bunker’s analysis notes that the EU is entering a negotiation already populated by competing proposals. Four sets of draft amendments to MARPOL Annex VI were circulated by the IMO Secretary-General in late May, filed by Liberia, Brazil, Tuvalu, and a joint submission from Australia, Canada, South Africa, and the United Kingdom, none of which align entirely with one another. Brazil, according to the report, wants the framework adopted largely as approved at MEPC 83, while Tuvalu’s version retains the IMO Net-Zero Fund and fuel reward mechanisms that the US has rejected outright.
The IMO is set to resume its extraordinary session and decide on adoption of the NZF on December 4, with MEPC 85 tentatively scheduled for late November to early December.
Does This Matter to You?
The outcome of these negotiations will shape the long-term regulatory landscape for marine fuel compliance, potentially affecting how vessel operators and fuel suppliers plan for low- and zero-GHG fuel adoption. The EU’s insistence on tacit acceptance versus the US push for explicit acceptance could influence how quickly and uniformly any global measure takes effect across fleets calling at EU and US ports.
For those tracking compliance costs and fuel availability, the EU’s silence on crop-based fuels and ILUC leaves uncertainty about whether a global framework will mirror the EU’s own restrictive stance under FuelEU Maritime. The interplay between a prospective IMO measure and the EU ETS and FuelEU Maritime review clauses, as noted in the draft, could also affect how regional and global rules interact going forward. The direct operational impact of these developments will depend on how the negotiations proceed toward the December 4 adoption decision.
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
