Marine Policy 147 (2023) 105379

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Marine Policy
journal homepage: www.elsevier.com/locate/marpol

Short communication

IMO off course for decarbonisation of shipping? Three challenges for

stricter policy
Hanna Bach a, b, *, Teis Hansen c, d
a
Department of Human Geography, Lund University, Sölvegatan 12, SE-223 62 Lund, Sweden
b
Centre for Innovation Research (CIRCLE), Lund University, Sölvegatan 16, SE-223 62 Lund, Sweden
c
Department of Food and Resource Economics (IFRO), University of Copenhagen, Rolighedsvej 23, DK-1958 Frederiksberg C, Denmark
d
Department of Technology Management, SINTEF Digital, P. O. Box 4760 Torgarden, NO-7465 Trondheim, Norway

A R T I C L E I N F O A B S T R A C T

Keywords: The maritime shipping industry is responsible for around 3 % of global greenhouse gas (GHG) emissions, and is
Policy mix characteristics now under pressure to decarbonise. Until now, the shipping industry’s main regulator, the International Mari­
Policy mix consistency time Organisation (IMO), has failed to implement sufficient policy instruments to support the emission reduction
Policy mix comprehensiveness
targets set in its Initial GHG Strategy introduced in 2018, and the implemented policy mix lacks consistency and
Maritime decarbonisation
International Maritime Organisation
comprehensiveness. This could be considered surprising given that shipping is one of few sectors with a main,
MARPOL Annex VI global regulatory body, which should allow for a comprehensive and consistent policy mix. This is the puzzle
examined in this paper. We identify three main challenges for more consistent, comprehensive and stricter
regulation of GHG emissions from international shipping: (1) lack of capacity within the IMO to regulate multiple
and emerging technologies, (2) uncertainty around the IMO’s regulatory mandate, and (3) lack of political
consensus during negotiations. If the IMO is to play a more progressive role in mitigating climate change, these
factors needs to be considered to ensure that the combination of policy instruments are able to achieve set
emission reduction targets.

1. Introduction
Being a main contributor to anthropogenic greenhouse gas (GHG)
emissions and climate change, the shipping industry currently faces the
challenge of decarbonisation. Following the Paris Agreement, the
Glasgow Climate Pact and the latest IPCC reports, increasing pressure is
put on the sector to speed up the transition to alternative, low- and zero
carbon (LoZeC) propulsion technologies. So far, the efforts by the In­
ternational Maritime Organisation (IMO), a UN agency, to regulate GHG
have remained insufficient as total GHG emissions from ships has
increased in the last decade and remain on a high level (see Fig. 1) [15,
18]. The implementation of the Initial IMO GHG Strategy in 2018 marks a
turning point in the attention to reducing GHG emissions. However,
although three new instruments categorised as short-term measures will
come into force on January 1st 2023, the instrument design is yet to be
finalised, and it is therefore unclear if these instruments will be sufficient
to achieve the IMO GHG Strategy’s 2030 target aiming for at least 40 %
reduction of carbon intensity [38,39] (i.e. CO2 emissions/transport
work) compared to 2008. Furthermore, there has been no decision on
the type and stringency of the medium and long-term measures that are
to be implemented to ensure achievement of the 2050 target aiming for
70 % reduction of carbon intensity (compared to 2008), as well as a 50 %
reduction of total GHG emissions/year [16] (Fig. 1).
Consequently, IMO has since a long time been criticised for moving
too slowly with regard to developing efficient GHG regulation [4].
Despite the introduction of the GHG Strategy in 2018, implementation
of specific instruments targeting GHG emissions remains a slow process,
and the shipping sector is far from compliance with the Paris Agreement
[6]. Critique has been raised by for example governments [29],
ship-owners such as Mærsk [28], other industry actors such as vessel
inspection organisations [48], as well as NGOs [50]. Despite climate
change and GHG being on the top of the agenda for the latest meeting of
the Marine and Environmental Protection Committee (MEPC), only a
limited number of instruments addressing GHG have been implemented
and the regulatory focus remains on air pollution [14]. The details of
upcoming and suggested short and mid-term GHG regulations, such as
the Energy Efficiency Design Index for existing ships (EEXI), the updated
Ship Energy Efficiency Management Plan, and the Carbon Intensity

* Corresponding author at: Department of Human Geography, Lund University, Sölvegatan 12, SE-223 62 Lund, Sweden.
E-mail addresses: hanna.bach@keg.lu.se (H. Bach), teis.hansen@ifro.ku.dk (T. Hansen).

https://doi.org/10.1016/j.marpol.2022.105379
Received 8 July 2022; Received in revised form 19 October 2022; Accepted 3 November 2022
Available online 11 November 2022
0308-597X/© 2022 The Authors. Published by Elsevier Ltd. This is an open access article under the CC BY license (http://creativecommons.org/licenses/by/4.0/).
H. Bach and T. Hansen
Indicator (CII), are still being negotiated and the effects of these mea­
sures are yet to be seen. For example, the CII reduction rates from 2027
and onwards are still to be decided [7]. Given the long lifespans of ships
(15–40 years), there is an urgent need for rapid implementation of
stricter regulation of GHG emissions to ensure decarbonisation of the
shipping sector.
Clear policy instruments are an important driver for implementation
of better solutions to enable climate change mitigation. Previous
research indicate that there is a need for policy measures aiming for
‘creative destruction’, meaning implementing instruments promoting
new, better technologies (creation), while withdrawing support from
old, polluting systems (destruction) [9,23,43]. For the decarbonisation
of the shipping sector, this for example relates to the need for imple­
menting policy instrument aimed at driving widespread diffusion of
LoZeC propulsion solutions (such as research and development (R&D)
funding or development of classification standards), in combination
with policy instruments restricting the use of fossil fuels (through taxes,
bans etc.). Furthermore, a combination of different types of policy in­
struments, such as regulatory, economic and soft instruments, in
so-called policy mixes,1 is seen as an effective approach to address
multiple aspects of what is needed to enable a more rapid transition to
sustainable socio-technical systems [24]. Thus, the characteristics of
policy mixes, including level of comprehensiveness (i.e. how extensive
the policy mix is) and consistency (i.e. how well different parts of the
policy mix fit together), will influence the ability of the policy mix to
drive a transition [44].
With IMO being the main regulator of the shipping industry, theo­
retically, there is potential for clear connections between emission
reduction targets and the policy instruments aimed at achieving them.
Compared to other sectors that do not have an international organisa­
tion responsible for global regulations, shipping would be expected to
have favourable preconditions for establishing a comprehensive and
consistent policy mix for decarbonisation. However, this has not yet
materialised. This is the puzzle we examine in the current paper.
Previous research on efforts within the IMO to regulate GHG emis­
sions suggest that dominating organisational structures within the IMO
does not allow for more strict environmental regulation [26,32].
Following this, Monios and Ng [32] point to decreasing legitimacy for
IMO as the main governing body for the shipping sector, while at the
same time, an institutional lock-in prevents other forms of regulatory
1
Our definition of a policy mix follows Rogge and Reichardt’s [44] sugges­
tion that policy mixes refers to a combination of elements, i.e. policy strategies
including objectives and plans, as well as policy instruments combined in an
instrument mix.
2
Marine Policy 147 (2023) 105379
Fig. 1. Emission trajectories for different levels of ambi­
tion for emission reduction targets. The current trajectory
is based on data for one of the business-as-usual scenarios
(SSP2_RCP2.6_L) included in the Fourth IMO GHG Study
[18]. The 2008 baseline indicates the emission levels that is
the basis for the emission reduction targets in the IMO GHG
Strategy. Coincidentally, the emission levels in 2008 and
2018 are about the same [16]. The “Zero by 2040′′ and
“Zero by 2050′′ trajectories are consistent with implied
straight-line trajectories for the 1.5 ◦ C and well below 2 ◦ C
scenarios included in the Paris Agreement [21].
organisation, resulting in inaction around regulation of GHG emissions.
Lister et al. [27] list procedural delays, stalled ratification of new in­
struments by some member states, weak enforcement of environmental
regulation and strong resistance from the shipping industry as reasons
for increasing regulatory fragmentation and the lack of environmental
governance at IMO level. Lack of political consensus and the complexity
around the application of UN principles developed for general climate
negotiations (related to the UNFCCC) in IMO negotiations has also been
found as a major obstacles for implementation of stricter regulation of
GHG emissions [37,39,41]. Furthermore, Prehn [36] has analysed the
decision-making processes leading up to the adoption of the IMO GHG
Strategy, and argues that in that case, the decision should be seen as a
result of an internal processes within the IMO’s administrative organi­
sation rather than consensus among the member states. This indicates
that the context around decision-making at IMO is not always charac­
terised by the influence from powerful member states. In addition, there
has been calls for increasing transparency of IMO negotiations [26], for
example through updating the rules for the constellations of member
state delegations to limit disproportionate influence from individual
member states [41]. Finally, some studies point to specific measures
which, if implemented, would be effective measures to achieve the set
decarbonisation targets, including a global bunker levy to promote up­
take of alternative fuels [40] and introduction of emissions trading
schemes [42].
In this paper, we provide further insights regarding the regulatory
challenges for implementing stricter regulation of GHG emissions at
IMO level. We identify three key challenges through analysis of (a)
policy targets in IMO strategy documents,2 and (b) the development of
the type of policy instruments included in MARPOL Annex VI, com­
plemented with (c) insights from interviews with eight different industry
stakeholders In addition to insights from a technical officer at the IMO’s
headquarters, and representatives from the International Chamber of
Shipping as well as the classification society DNV, we specifically focus
on Scandinavian shipping actors’ (such as ship-owners and regulatory
bodies) perspectives on the regulatory challenges (see Appendix A for a
full list of the interviewed stakeholders organisations).3 Denmark,
2
The results from the document analysis have been triangulated through the
interviews as well as through participant observations during industry confer­
ences, webinars and policy briefs for the industry.
3
We appreciate that a larger number of interviews, including a broader
representation of nationalities, could have potentially provided additional
perspectives on the regulatory challenges for decarbonisation of the shipping
sector, given how ship-owners operate within specific national and regional
contexts. However, this is out of scope for this research project.
H. Bach and T. Hansen
Norway and Sweden can be seen as frontrunners in the shift to sus­
tainable shipping, given that they have implemented more ambitious
decarbonisation targets and policies than IMO [30], and are pushing for
stricter IMO regulation on GHG [36]. Furthermore, the Scandinavian
countries are active and influential member states during IMO negoti­
ations [41], implying that they have great insight into the dynamics of
the policy-making processes. Interviews were carried out in June 2021,
shortly after MEPC 76.
The following section briefly describes decision-making processes
within the IMO, followed by a section outlining the IMO policy mix,
while the challenges are presented in Sections 4–6.
2. Decision-making processes within the IMO
Implementation of new policy instruments regulating emissions to
air from ships (to be included in MARPOL Annex VI) are negotiated
during meetings within the MEPC, held around every six months. The
first policy instruments were implemented in 2005 after several years of
negotiations following the agreement on the Kyoto Protocol in 1997,
where the shipping industry was pointed out as accountable for
decreasing the sector’s GHG emissions. The MEPC is one of five main
technical committees within the IMO, and has two sub-committees: the
sub-committee on implementation of IMO instruments, and the sub-
committee on pollution prevention and response. As the IMO is a
member-state led organisation (with 175 members), decisions are typi­
cally preceded by legislative proposals submitted by member states and/
or organisations with consultative status (81 organisations) such as the
International Chamber of Shipping. During MEPC meetings, each
member state has one vote, and the proposals are negotiated between
the member states until they reach consensus (agreement between at
least 50 % of the member states) or decide to abandon the proposal [17].
3. The IMO policy mix regulating air emissions from ships
Since its establishment in 1958, IMO has mainly been a technical
organisation, setting standards for ship operations to ensure that they
are done in a safe way. The current instrument mix addressing emissions
to air (including air-polluting substances as well as GHG emissions) from
ships is mainly based on a number of codes (for example the NOx Code)
and certificates (such as the International Air Pollution Prevention
(IAPP) and International Energy Efficiency (IEEC) certificates), that a
ship needs to comply with. Since these policy instruments aims at
regulating ships’ day-to-day operations, it is implied that the in­
struments mainly aims to regulate already established technologies and
practices.
Our analysis of the development in regulations of emissions to air in
MARPOL Annex VI shows that the IMO has not established a compre­
hensive and consistent decarbonisation policy mix [14]. The types of
policy instruments included in the IMO’s instrument mix are very
similar to each other, and the vast majority of the instruments regulate
air-polluting substances, rather than GHG emissions. In short, the mix
mostly consists of regulatory instruments such as bans to carry
non-compliant fuel oil, emission standards through the global and
regional sulphur caps, and technical standards for engine installations.
In addition to regulatory instruments, there are a few ‘soft’ instruments
aimed at increasing knowledge around emissions from shipping, such as
the IMO GHG Studies. However, in general, there are very few in­
struments targeting GHG emissions, and there are no instruments
directly targeting economic incentives for the shipping industry to shift
to LoZeC technologies. This represents a very homogenous instrument
mix, which further confirms the IMO’s narrow approach to policy
making.
Furthermore, the technical standards are centred on conventional
fossil fuels. Standards and safety regulation for alternative LoZeC tech­
nologies are therefore currently lacking in policy instruments such as the
NOx code, which hinders implementation of such solutions. Especially
3
Marine Policy 147 (2023) 105379
noteworthy is the lack of emission standards for some alternative pro­
pulsion technologies to include in the calculations of the Energy Effi­
ciency Design Index (EEDI) and Energy Efficiency Existing Ship Index
(EEXI), or the Carbon Intensity Indicator (CII). This implies that ship-
owners who have already made investments in available options, such
as battery-hybrid propulsion, biodiesel, LBG or methanol, may not get
credit for this through the regulations coming in 2023 if emission
standards are not developed in time. Therefore, without additional
emission factors, the EEDI and coming EEXI and CII regulations create
very limited incentives for ship-owners to make investments in alter­
native solutions, especially as many ships can comply with the new
regulation through implementing an engine power limitation or shaft
power limitation on their existing engines [11,33]. Following this, the
current instrument mix is insufficient to achieve the emission reduction
targets in the IMO GHG Strategy. In the next sections, we go through
three main challenges for implementing regulations for decarbonisation
of the shipping industry.
4. Challenge 1: IMO’s limited capacity to regulate multiple and
emerging technologies
The shift to LoZeC propulsion technologies requires a portfolio of
solutions, energy carriers and fuels, due to the large quantity demands
from the shipping sector and the limited access to natural resources for
alternative fuel production [2]. Given that different types of ships sail
varying distances and routes, at different speeds, and have different
energy demands, certain solutions may be more suitable to some sectors
than others [3]. Currently, access to commercially available alternative
technologies is very limited, and it is still uncertain which options will
be possible to scale up, and when. Developing the IMO’s policy in­
struments to achieve the emission reduction targets in the IMO GHG
strategy therefore face the challenge of shifting from having regulated
the same fuel for more than 50 years, to providing a policy mix for
multiple solutions.
Furthermore, IMO has limited experience with governing innovation
and emerging technologies: “IMO has always had its starting point in
making regulations based on what is technically feasible, and put re­
quirements on ships that they are able to fulfil. So you need to have the so­
lution in place before it can be regulated.” explained a representative from
the classification society DNV. In addition, IMO strives to implement
technology neutral policy instruments, designed to target performance
standards and operational patterns for individual ships, rather than in­
struments promoting implementation of LoZeC technologies. This im­
plies that it is up to the ship-owner to make the decision around what
type of propulsion technology or operation pattern that should be
implemented to comply with the regulation. However, previous research
on climate policy indicates that technology neutral regulation is insuf­
ficient to provide incentives to reach climate targets such as the emission
reduction targets in the IMO GHG Strategy, and that there is a need for
technology specific regulation [45].
Following this, the current organisation of the IMO’s instrument mix
leaves little room for implementing policy instruments aimed at driving
technology development and innovation. Given the long lifespans of
ships (15–40 years), decarbonisation of the shipping sector needs to start
now in order to reach the emission reduction targets for 2030 and 2050.
Many ship-owners and other industry actors are therefore pushing for
instruments targeting innovation and implementation of alternative
technologies, as well as long-term clarity regarding the policy in­
struments in order to create a level playing field [19,47,49].
However, a technical officer at the IMO headquarter indicated that
the current administrative organisation of the IMO would have very
limited financial and human resources to administer for example a R&D
fund: “The permanent staff in London is about 300, the technical staff like
myself that deal with supporting the member states, developing the regulation,
we are less than 100. It is a small organisation really. If our mandate was to
run, to instruct, funding of R&D we would need to be 1000 I think.” The
H. Bach and T. Hansen
tradition of implementing technology neutral regulation and limited
experience with regulating emerging technologies, in combination with
limited human and financial resources within the administrative orga­
nisation of IMO, therefore constitutes a challenge for implementing
sufficient policy instruments to achieve the targets in the IMO GHG
Strategy. While regulatory anticipation would certainly make things
easier for the industry, when it comes to sustainability transitions and
governing uncertainty, it is also important to be careful not to imple­
ment policy instruments that exclude potentially future favourable op­
tions. Designing and implementing the most suitable instruments,
including appropriate safety measures for new fuel types, are therefore a
further challenge.
5. Challenge 2: uncertainty around IMO’s regulatory mandate
During IMO negotiations, there have been repeated calls for market-
based measures (MBMs) and financial support for R&D of alternative
solutions since the late 2000s, however, nothing has been implemented
yet. For example, there have been proposals from the industry [20]
regarding implementation of a global R&D fund aimed at LoZeC fuels
and other propulsion solutions. These proposals have been discussed in
the Marine Environment Protection Committee (MEPC), but there has
been no consensus. Some nation-state delegates have expressed con­
cerns about the role and jurisdictional focus of the IMO.4 Referring to
MEPC 76, a representative from the IMO explained:
“For many IMO members, the role of IMO is to develop regulations and
requirements; it is not to support R&D or things like that. You had for
example last week a member of a delegation saying ‘We wonder whether
legally, we could actually include the market based measures in MARPOL
Annex VI, because this is not setting new requirements for the reduction of
air emissions from ships so how can we do that?”.
Although it is positive that a work plan with clear deadlines in place
for continued negotiations around medium- and long-term measures
(including MBMs) was adopted during MEPC 76, the statements
regarding uncertainty around the IMO’s regulatory mandate indicates
that these types of attitudes among member states might also provide a
hinder for implementation of further regulation of GHG emissions from
ships.
6. Challenge 3: lack of political consensus within the IMO
Having a global policy mix for an international sector such as ship­
ping certainly has its advantages with regards to creating a level playing
field, but there are also challenges with having a member-state led
organisation as the main regulatory body – especially when it comes to
politically sensitive topics such as climate change. The lack of policy
instruments driving implementation of alternative, more sustainable
propulsion solutions can, at least in part, be explained through a lack of
consensus between the IMO member states regarding what type of in­
struments to implement, and how strict these should be. Most in­
terviewees mentioned lack of political will as one of the main challenges
for implementing stricter GHG regulation, which would match the set
decarbonisation targets. A representative from the International
4
Article 1(a) of the Convention on the International Maritime Organisation
states that the purpose of the IMO is “to provide a machinery for cooperation
among Governments in the field of governmental regulation and practices relating to
technical matters of all kinds affecting shipping engaged in international trade; to
encourage and facilitate the general adoption of the highest practicable standards in
matters concerning maritime safety, efficiency of navigation and prevention and
control of marine pollution from ships” [22]. This formulation is open to different
interpretations of what technical matters could entail, including whether
implementation of for example MBMs and a R&D fund could be considered
included in the IMO’s regulatory mandate.
4
Marine Policy 147 (2023) 105379
Chamber of Shipping stated “IMO moves at the speed that governments
want it to move at, ultimately.” Furthermore, an official from the Swedish
Transport Agency reflected on the negotiations during the 76th meeting
of the MEPC in June 2021:
“The proposal from the industry about an R&D fund, it proposed a two
dollar fee per ton. Two dollars is not much, only during the time of the
meeting, the oil price fluctuated about the same amount, but not even that
could be tolerated. And if we could not even agree on that little, how are
we supposed to move forward and agree on the additional measures that
we will need to achieve the IMO GHG Strategy?”.
According to our interviewees, the inability of the IMO to reach
political consensus on a more comprehensive and consistent policy mix
driving decarbonisation can be attributed to several reasons. Two main
reasons connects to dynamics between member states, which appear to
differ between IMO negotiations and other UN contexts such as climate
negotiations within the United Nations Framework Convention on
Climate Change (UNFCCC) [36]. Although the IMO is regulating ships
and not nations, it is the nations who have to agree on regulation of GHG
emissions from ships.
First, the type of delegations differ between negotiations within these
two UN bodies. During climate negotiations such as the Conference of
the Parties (COP), delegations typically consist of representatives from
climate and foreign ministries, while IMO delegations usually include
technical staff from the national maritime authorities. The latter may
not have climate change mitigation as high on the agenda as the dele­
gates attending COP negotiations. “It’s not always the same persons who
participates in the IMO and UNFCCC negotiations respectively, sometimes a
nation has one level of ambition during UNFCCC talks, and then not the same
level when they come to IMO because then they have other aspects they need
to take into consideration.” the representative from the Swedish Maritime
Authority explained further. Furthermore, a previous study has showed
that some nations’ delegations have consisted mainly of employees of
shipping companies, as it is allowed for member states to include em­
ployees of corporations in their delegations. This implies that shipping
companies may have large influence on their government’s agenda
during IMO negotiations [25]. However, since delegation representa­
tives are not allowed to reveal which positions other delegates have been
held in relation to specific proposals, and journalists only have limited
access to monitoring the negotiations, there is a lack of transparency.
Increasing the degree of transparency of IMO negotiations has been
pointed out as an important element to improve to enable imple­
mentation of stricter regulation of GHG emissions [41]. In addition,
research on how active specific member states are with regard to sub­
mitting legislative proposals to MEPC and MSC meetings shows that
large ship-owner nations such as Japan, USA, Germany, Norway and
China have been the most active since 2010. At the same time, other big
ship-owner nations, for example Greece are not very active [41]. Or­
ganisations representing ship-owners, such as the International Cham­
ber of Shipping and BIMCO, as well as delegations from classification
societies have also been increasingly active, especially since 2018 [39].
The number of submissions can be seen as an indicator for leadership
and a delegation’s influence during negotiations [41].
Second, power dynamics between member states differ following the
system allowing ship-owners to register their ships wherever, a phe­
nomenon called “flag of convenience” [10]. As many ship-owners have
registered their ships in nations with for example lower taxes or less
strict labour laws, big ship-owner nations such as Panama, Liberia and
the Marshall Islands in some cases hold more power during IMO nego­
tiations than in other UN contexts [8]. Some of these countries are
among the nations most vulnerable to climate change, while also being
dependent on income from ship’s registries and sensitive to increases in
maritime freight costs (this is especially the case for small island states,
which are completely dependent on shipping for import and export).
Despite their vulnerability to climate change, many of the big
ship-owner nations are opposing stricter GHG regulation. A
H. Bach and T. Hansen
representative from DNV, who have been monitoring MEPC negotiations
for many years expressed: “Developing states are quite vocal around that
they don’t accept any impact on their fleet and shipping operations or regu­
lation. The strategy says that you should avoid disproportionate negative
impact, and they say that any impact is disproportional for us.”.
Furthermore, some member states (e.g. Argentina, Brazil, India,
Saudi Arabia and South Africa) are often referencing the Common But
Differentiated Responsibilities and Respective Capabilities (CBDR-RC)
principle as an argument to block implementation of regulation of GHG
emissions [39]. In some cases relating to the implementation of the [18]
sulphur cap, negotiations were delayed as delegations insisted that the
design of the instrument had to be run by IMO’s Maritime Safety
Committee (MSC) to ensure the safety of low-sulphur fuels. Our in­
terviewees indicated that this might very well also be the case for ne­
gotiations of regulations for GHG emissions once the discussion will
focus more on the safety aspects of alternative fuels such as ammonia. A
representative from one of the ship-owners we interviewed further
explained: “What often happens is that you throw in some arguments about
CBDR and these principles from the UNFCCC, it could also be that some
people would throw the safety argument – because there is an issue with safety
for some fuels. And they do that to some extent already, and you can spec­
ulate a bit whether there is another background reason for that, political
reason, for those safety arguments to somehow stall the negotiations or so.”
However Psaraftis [39] argues that the CBDR-RC principle is contra­
dictory to the IMO principle around “no more favourable treatment”,
which states that a ship must not be placed at a disadvantage when their
flag state ratifies a new IMO convention. Given that IMO regulates ships
and not nations, Psaraftis argues that CBDR-RC should not be applicable
during IMO negotiations as all ships should be subject to the same
conditions. Since both principles are currently included in the IMO GHG
Strategy, this complexity creates further lock-ins during negotiations.
An additional hinder for reaching decisions during the latest MEPC
meetings during the COVID-19 pandemic has been the digital format
with shorter meeting hours, which has caused delays as there has not
been time for all agenda items to be discussed, and several issues have
been pushed forward to later meetings. Furthermore, our interviewees
expressed concerns around the lack of interaction between member
states during coffee breaks and break out meetings, as they experienced
that this has slowed down decision-making. Despite the online meeting
format, the 70 (out of 174) IMO member states in the “Intersessional
Working Group on Reduction of GHG Emissions from Ships” reached an
agreement in early June 2022 to implement a MBM [1], which marks a
positive step forward. However, there was no consensus on what type of
measure to implement during the latest MEPC meeting and negotiations
will restart again in November this year [46].
7. Concluding discussion
GHG emissions from ships are continuously increasing, and maritime
shipping’s share of global emissions is expected to increase. Although an
Initial IMO GHG Strategy with targets for decarbonisation of the shipping
industry has been introduced, the implemented policy instruments are
insufficient to support this transition. Furthermore, the emission
reduction targets are not compatible with the efforts needed to reach the
Paris Agreement’s targets to limit global warming to well below 2 ◦ C,
and preferably below 1.5 ◦ C. This implies that there is a need for both
more ambitious policy targets in IMO’s GHG Strategy, as well as more
stringent policy instruments supporting the strategy. The current design
of the IMO’s policy mix for emissions to air from ships has a very narrow
regulatory focus, as most policy instruments regulate air pollution rather
than GHG, and the majority of instruments are very similar to each other
(emission standards, bans, technical standards for engines etc.). As of
now, the policy mix contains no economic instruments, and no in­
struments aimed at innovation and implementation of alternative pro­
pulsion technologies. Given the instrument mix’s inability to support the
decarbonisation targets in the GHG strategy, and the narrow regulatory
5
Marine Policy 147 (2023) 105379
focus, the policy mix lacks consistency and comprehensiveness. This
could be considered surprising given that shipping is one of few sectors
with a main, global regulatory body, which should allow for a
comprehensive and consistent policy mix.
This is the puzzle we have examined in this paper. We find three
main challenges for stricter IMO regulation of GHG emissions from
ships: lack of capacity within the IMO to regulate multiple and emerging
technologies, uncertainty around the IMO’s regulatory mandate, and
lack of political consensus during negotiations. Regarding IMO’s
restricted capacity to regulate emerging and multiple technologies, this
challenge relates to the organisation’s limited capabilities after having
regulated the same type of fuel for more than 50 years, and its routine of
implementing regulation after a solution has been developed. There is
therefore a need for capacity building. The second challenge, uncer­
tainty regarding the IMO’s regulatory mandate, stems from IMO being a
technical organisation with a history of regulating technical specifica­
tions of how ships should be operated. Some therefore question if it
actually would be IMO’s task to implement and enforce policy in­
struments aimed at increasing R&D, such as an R&D fund. Lack of po­
litical consensus constitutes the third challenge, as it appears that
consensus on sufficient GHG instruments is hampered by (a) less
ambitious efforts from member state delegations during IMO negotia­
tions compared to climate negotiations within UNFCCC, (b) the strong
negotiation role of big ship-owner nations from the Global South (due to
flag of convenience registrations), that often are concerned about losing
sources of income if strengthened GHG polices are implemented, and (c)
slower decision-making processes due to digital MEPC meetings during
the COVID-19 pandemic. Although the latter is a minor and hopefully
temporary factor, action for climate change mitigation is required as
soon as possible and any delays for decision-making are problematic.
The on-going revision of the IMO GHG Strategy (due in 2023) provides a
possibility for IMO to implement more ambitious policy targets striving
for emission reductions in line with the Paris Agreement. Furthermore,
the negotiations around updating the strategy also offers an occasion to
agree upon implementation of stricter instruments regulating GHG
emissions. Given the urgent need for a decarbonisation of the shipping
sector, this is an opportunity we strongly recommend IMO member
states to act upon.
However, the challenges we describe in this paper for IMO to
implement stricter GHG regulation risk causing inaction so severe that
the shipping industry fails to meet the decarbonisation targets. Partly as
a reaction to the inaction at IMO level to regulate the decarbonisation of
the shipping sector, other regulatory initiatives have emerged in the last
years, both from the public sector as well as the industry. Examples
include the inclusion of shipping in EU’s emission trading scheme [12],
the Poseidon Principles (a global framework for responsible ship
finance) [35], and the Clydebank Declaration for green shipping corri­
dors to promote uptake of alternative fuels [13]. A parallel can here be
drawn to the entry of cities as core actors in driving experiments focused
on climate change mitigation, which was provoked by inaction in
multilateral negotiations [5]. However, urban climate actions come with
distinctive benefits and limitations, and should be considered as com­
plements to rather than substitutes for action as the global level [31]. In
a similar way, the implementation of EU regulation of GHG emissions
from ships, or industry initiatives, is not an argument for abandoning
efforts to mobilise IMO as an arena for progressive action addressing the
decarbonisation of shipping. This especially given that IMO regulation
of the decarbonisation of shipping has the potential to contribute to
substantial emission reductions (as has been seen in the case of drasti­
cally decreasing sulphur emissions after the new sulphur cap came into
force in 2020 [34]), if the identified regulatory challenges are overcome.
To summarise, our findings highlight that one should be careful to
not overestimate the advantage of single regulatory bodies for achieving
consistent and comprehensive policy mixes. Furthermore, the effect of
policy mixes appears to be influenced by the regulatory capacity and
mandates of the regulatory body, as well as the character of decision-
H. Bach and T. Hansen Marine Policy 147 (2023) 105379

making processes. Finally, the findings in this paper highlights that if the Methodology, Writing – original draft, Writing – review & editing. Teis
IMO is to play a more progressive role in mitigating climate change, Hansen: Conceptualization, Methodology, Writing - original draft.
these factors needs to be considered in order to ensure that the combi­
nation of policy instruments are able to achieve set (and potentially Data Availability
more ambitious forthcoming) emission reduction targets.
Data will be made available on request.
CRediT authorship contribution statement

Hanna Bach: Conceptualization, Data curation, Formal analysis,

Appendix A. List of interviewees

Title Organisation Type of actor

Technical Officer, Air Pollution and Energy Efficiency Team of the Marine Environment Division International Maritime Organisation Regulatory body
Secretary General International Chamber of Shipping Industry association
Principal Consultant, International Regulatory Affairs DNV Classification society
International Liaison Officer for Climate and Marine Environment Swedish Transport Agency Regulatory body
Senior Policy Advisor, Safety and Climate Swedish Ship-owners Association (Sweship) Industry association
Technical Advisor, Public Affairs and Sustainability Stena Line Ship-owner
Senior Regulatory Affairs Manager, Air Pollution A.P. Møller-Maersk Ship-owner
Senior Regulatory Affairs Manager, Greenhouse Gases A.P. Møller-Maersk Ship-owner

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