MEPC 81 Summary Report

IMO Marine Environment and Pollution
Committee Eighty-First session (MEPC 81)

Summary Report
Executive Summary
The following was agreed during MEPC 81:
• Adoption of amendments to MARPOL Annex VI concerning definitions of fuel oil and gas fuel and when
the sampling requirements of MARPOL Annex VI regulation 14 do not apply to them, replacement of a
steam engine and NOx compliance under MARPOL Annex VI regulation 13, and expansion of data
required to be reported according to MARPOL Annex VI regulation 27 (expected to enter force 1 August
2025).
• Agreement to the reclassification of LNG carriers that are currently reported as gas carriers for the
purpose of the data reporting in Annex VI regulation 27 and CII.
• Agreement to an illustration of future MARPOL Annex VI regulations to implement mid-term GHG
measures and confirmation that the mid-term measures will include a fuel standard and an economic
requirement.
• Approval of ECAs for SOx and NOx in the Norwegian Sea and Canadian Arctic (both expected to enter
force 1 March 2026).
• Endorsement of a comprehensive list of instruments which require revision and or development as
part of the review of the BWM Convention.
• Adoption of, with effect from 22 March 2024, MEPC.387(81) Interim guidance on the application of the
BWM convention to ships operating in challenging water quality conditions. This guidance will assist
ship owners and operators in planning for compliance with the BWM Convention and the D-2
discharge standard when a type-approved BWMS encounters operational limitations or meeting
operational demand in challenging water quality (CWQ) conditions.
• Approval of, with effect from 22 March 2024, BWM.2/Circ.82 Guidance for the temporary storage of
treated sewage and/or grey water in ballast water tanks. Noting that this procedure should only be
undertaken temporarily in specific ports and areas which restrict the discharge of treated sewage
and/or grey water (TS/GW) and where the ship does not have dedicated tanks with adequate storage
capacity.
• Approval of, with effect from 22 March 2024, MEPC.1/Circ.909 Recommendations for the carriage of
plastic pellets by sea in freight containers. This circular will act as a short-term measure with the aim of
reducing the environmental risks associated with the carriage of plastic pellets in packaged form by
sea ahead of mandatory instruments being developed.
Lloyd’s Register Briefing Note – Summary Report MEPC 81 Page 2

March 2024 ©Lloyd’s Register 2024
Introduction
MEPC 81 took place 18-22 March 2024. This report summarises discussions which are significant to Lloyd’s
Register’s work with our customers.
Decisions of Other Bodies

Additional Information
LR’s MSC 107 Summary Report
Guidelines for the sampling of fuel for determination of compliance with the revised
MARPOL Annex VI and SOLAS Chapter II-2
MEPC considered a draft MSC-MEPC Circular on Guidelines for the sampling of oil fuel for determination of
compliance with the revised MARPOL Annex VI and SOLAS Chapter II-2. The Guidelines address both the sample
required by MARPOL Annex VI 18.5.1 and 18.8.1 (demonstration of Sulphur Requirements) as well as SOLAS II-
2/4 (flashpoint of fuel). MEPC specifically considered the difference in defining oil fuel (generally petroleum
products to which SOLAS requirements consider) against fuel oil (any fuel delivered intended for use on board
which the MARPOL Annex VI requirements consider).
Accordingly, MEPC made further amendments to the Circular approved by the Maritime Safety Committee
(MSC) to clarify the inclusiveness of the definition in MARPOL by referring to fuel oil instead of oil fuel as well
as further clarifying the sections of the guidelines which support MARPOL and which support SOLAS
requirements.
MEPC subsequently approved the draft MSC-MEPC circular on Guidelines for the sampling of fuel oil for
determination of compliance with MARPOL Annex VI and SOLAS Chapter II-2, subject to concurrent approval by
MSC (noting changes of substance since MSC approved the circular) at MSC 108 (May 2024) as an urgent
matter.
MEPC also agreed to revoke resolution MEPC.182(59) on the 2009 Guidelines for the Sampling of Fuel Oil for
Determination of Compliance with the Revised MARPOL Annex VI as soon as the joint MSC-MEPC circular enters
into effect.
MSC 107 Electronic certificates

MEPC discussed the proposed joint FAL-MSC draft circular on Guidelines for the use of electronic certificates, as
well as considering which electronic certificates fell under their purview that could be included in this circular.
The aim of these draft guidelines is to establish a single set of guidelines for all electronic certificates. MEPC
concluded that the circular should be a joint FAL-LEG-MEPC-MSC circular, and the joint guidance should be
limited to include certificates only, with a view to future consideration of record books and electronic bunker
delivery notes, due to the understanding that their inclusion would require further work around security
considerations. MSC, FAL and LEG will be informed of these decisions.

Adoption of Amendments to Mandatory Instruments
Amendments to the International Ballast Water Management Convention

See section below on Amendments to regulations A-1 and B-2 of the BWM Convention on the use of electronic
record books.
Amendments to Protocol I of MARPOL Article V

MEPC adopted MEPC.384(81) Amendments to Protocol I of MARPOL Article V, concerning Reporting Procedures
for the loss of containers, making the procedures for reporting the loss of containers mandatory by cross
referencing SOLAS V/31 and V/32 requirements on danger messages.
In the event of a container loss the master of the ship is required to report the incident without delay to both
the nearest coastal State, any ships in the vicinity and to the flag State. This amendment will enter into force
on 1 January 2026 in alignment with SOLAS and is applicable to any ship carrying one or more containers or
observing a lost container.
Amendments to MARPOL Annex VI

MEPC adopted amendments to MARPOL Annex VI (MEPC.385(81))concerning a definition of gas fuels and the
associated clarification on fuel sampling and bunker delivery notes for low-flashpoint fuels and gas fuels, NOx
requirements related to replacing a steam system with a marine diesel engine and notification of the same to
the IMO, and expansion of data required pertinent to regulation 27 (Collection and Reporting of Fuel Oil
Consumption Data).
The amendments related to gas fuels uses the definition of “gas” in the IGF Code as a basis, and further clarify
the non-applicability of the fuel sampling point (MARPOL VI, Reg 14.12) to such fuels.
The amendments related to engine replacements (steam to diesel or diesel to diesel) clarify that a steam to
diesel modification is an engine replacement. Where a Tier III engine would be required and a Tier II engine is
permitted for installation as the replacement, the flag Administration must report this to the IMO.
The amendments to Appendix IX to Annex VI add granularity to the data which must be reported by ships to
which regulation 27 of Annex VI applies (ships of 5,000 GT or above). This will require fuel consumption per
fuel consumer when underway, and when not underway, as well as information related to attained CII.
These amendments are expected to enter force on 1 August 2025.
Guidelines required by regulation 13.2.2 of MARPOL Annex VI

MEPC adopted the 2024 Guidelines as required by regulation 13.2.2 of MARPOL Annex VI in respect of non-
identical replacement engines not required to meet the Tier III limit (MEPC.386(81)) replacing the current 2013
Guidelines. The 2024 Guidelines add further points for consideration by the Administration in determining the

Tier of engine required when replacing a steam system as follows:
• The total available engine-room space, including tanks, made available by the removal of the steam
system being replaced should be considered with regard to the space and support service
requirements of a Tier III engine;
• If the steam system is not removed, but only decommissioned, that should not affect the
determination as to whether a Tier III replacement engine could be installed; and
• The level of work required to provide the structural support for the marine diesel engine to be installed
in relation to any additional work required to accommodate a Tier III engine, and if such additional
work should reasonably be expected to be undertaken.
Further to the regulatory changes and the guidelines facilitating a replacement engine, it was noted that a flag
State allowing a Tier II engines where a Tier III engine would otherwise be required to be installed must inform
the IMO in such cases. Accordingly, MEPC agreed to the inclusion of sharing this information via a new tab in
the MARPOL Annex VI module of the GISIS.
Harmful aquatic organisms in ballast water
Amendments to regulations A-1 and B-2 of the BWM Convention on the use of
electronic record books
MEPC adopted MEPC.383(81) Amendments to the BWM Convention on the use of electronic record books, which
include:
• A definition for the “Electronic Record Book”.

• Reference to the requirements for an electronic record book to be approved by the Administration,
considering the necessary guidelines developed by the IMO (which include MEPC.372(80) Guidelines For
the use of Electronic Record Books under the BWM Convention)
These amendments will enter into force on 1 October 2025.
Approval of Ballast Water Management Systems (BWMS)

Information on the following approved BWMS was noted:
• Semb-Eco BWMS
• Cyeco BWMSBalClor®
• Smart BWMS
• RADClean® BWMS
The following ballast water management systems were considered and granted basic approval by the
committee:
• ERMA FIRST FLOW BWMS

Review of the Ballast Water Management Convention
Following the approval of the circular BWM.2/Circ.79 Convention Review Plan (CRP) under the experience-
building phase associated with the BWM Convention, work progressed intersessionally via correspondence
group, to further define objectives for changes to specific convention provisions and/or instruments, or the
need for new provisions, addressing the issues in the annex to the CRP.
MEPC endorsed a list of instruments which require revision and or development as part of the review of the
BWM Convention. Work will continue via correspondence group to prepare draft amendments to the BWM
Convention, the associated instruments and development of new guidance, with the view to reporting
progress at MEPC 83.
Modifications to BWMS with existing type approval

To enable shipowners to use BWMS under different scenarios and regions, or to adapt to supply chain
changes, or improve component performance, it can become necessary to change existing parts within a
BWMS. However, due to the Type Approval Certificate and the specific list of components associated with the
BWMS type approval, changing these parts can become difficult.
MEPC discussed the type approval requirements for BWMS, with existing approval, which have since
undergone modification and decided to revise BWM.2/Circ.43/Rev.1 as an interim measure ahead of further
review and a more permanent solution to be developed as part of the BWM Convention review. However, due
to limited time to discuss all the necessary changes, amendments to BWM.2/Circ.43 Guidance for
Administrations on the type approval process for ballast water management systems were not concluded. As
such it is anticipated that this will be worked on intersessionally, and further concrete proposals were invited
to be submitted to MEPC 82, with a view to finalisation of the guidance.
Ports with challenging water quality

Not all BWMS are appropriate to operate in all environments and a BWMS selected at construction may not be
suitable for the operational profile of the ship and thus may not be compliant with the BWM convention
requirements. Following on from extensive work on this topic over multiple previous sessions, MEPC finalised
and adopted, with effect from 22 March 2024, MEPC.387(81) Interim guidance on the application of the BWM
convention to ships operating in challenging water quality conditions.
This guidance will assist ship owners and operators in planning for compliance with the BWM Convention and
the D-2 discharge standard when a type-approved BWMS, that has been properly installed, operated, and
maintained, encounters operational limitations, or has difficulty meeting operational demand in challenging
water quality (CWQ) conditions. The recommended steps are outlined to restore or maintain effective
operation of a BWMS when operating in CWQ, and include steps to identify when a system is inoperable owing
to CWQ; actions to avoid bypass of the system; steps to recover from bypass including steps to return to
compliance with the D-2 discharge standard; and planning, record-keeping, and communication principles.
Ship operators using this guidance should include a ship-specific change-over procedure in the Ballast Water
Management Plan (BWMP).
This guidance is applicable to:
• Ships that are required to meet the ballast water performance standard in accordance with regulation

B-3 of the BWM Convention;
• Administrations approving BWMPs in accordance with regulation B-1 and applying articles 13
(Technical assistance, co-operation and regional co-operation) and 14 (Communication of information)
of the BWM Convention;
• Port States applying articles 8 (Violations), 9 (Inspection of ships) and 10 (Detection of violations and
control of ships) of the BWM Convention; and
• BWMS manufacturers defining troubleshooting procedures in the Operational, Maintenance and Safety
Manual in accordance with paragraph 4.8 of the BWMS Code.
Temporary storage of treated sewage and grey water in ballast water tanks
BWM.2/Circ.82 Guidance for the temporary storage of treated sewage and/or grey water in ballast water
tanks
The temporary storage of grey water and treated sewage in ballast tanks has become a global practice, and
the demand is increasing in those ships which do not have a dedicated tank for temporary storage of such
water, or when retrofitting such a tank is impractical. MEPC finalised and approved, with effect from 22 March
2024, BWM.2/Circ.82 Guidance for the temporary storage of treated sewage and/or grey water in ballast water
tanks.
The purpose of this guidance is to provide a procedure for the temporary storage of treated sewage and/or
grey water in ballast water tanks. As such, shipowners and operators should only store treated sewage / grey
water (TS/GW) temporarily in ballast water tanks, in specific ports and areas which restrict the discharge of
TS/GW and where the ship does not have dedicated tanks with adequate storage capacity for TS/GW. Mixing
ballast water and TS/GW in a BW tank should be avoided. In the cases where temporary storage of TS/GW in
ballast tanks occurs, shipowners/operators should make periodic inspections of the ballast water tanks'
coatings and take measures to prevent any impacts as appropriate.
Amendments to BWM convention
Following the approval of the circular it was concluded that no further amendments to regulations A-2 and B-2
of the BWM Convention were required. However, the corresponding amendment to Regulation B-1 could be
considered under the BWM Convention review.
Air Pollution Prevention
Engine Air Pollution Prevention (EIAPP) Certification

MEPC considered the conditions in which the EIAPP certificate remains valid, specifically on change of flag.
Two primary proposals were made, with one understanding that the EIAPP remains valid with the life of an
engine providing the NOx influencing characteristics of the engine are not altered after installation. In this way
a change of flag does not invalidate the certificate.
The other view was that the EIAPP certificate, like any other ship certificate must be issued under the
authority of the flag State i.e. on change of flag, the EIAPP is invalidated and must be re-issued under the
authority of the gaining flag State. In this way the methodology and conditions for re-issuance are at the
discretion of the gaining flag State.

However, MEPC noted that there was not sufficient support for the proposed interpretation regarding Engine
International Air Pollution Prevention (EIAPP) Certificate re-issuance at the time of change of flag of a ship due
to divergent views.
During the review of the associated regulations, MEPC noted an editorial mistake in regulation 9.9.3 of
MARPOL Annex VI where it refers to requirements of regulation 5.4 instead of regulation 5.5 of that Annex.
MEPC considered this to be editorial error and requested the Secretariat to correct this error in a future
publication of MARPOL Annex VI.
Exhaust Gas Cleaning System wash water effluent discharges

MEPC considered further reports on the environmental effects of discharges from Exhaust Gas Cleaning
System (EGCS) wash water into the marine environment.
MEPC considered a proposal to amend the 2021 Guidelines for Exhaust Gas Cleaning Systems (MEPC.340(77)) to
address when an EGCS of a similar design to the actual EGCS in question can be used to sample discharge
water for nitrate concentration instead of the EGCS subject. It was proposed to limit this to the instillation/
initial survey to ensure that the actual EGCS is sampled at each renewal survey and not one of a similar design.
It was agreed that insufficient evidence was provided to support such a change and MEPC invited interested
Member States and International Organisations to submit proposals with appropriate justifications to a future
session.
MEPC also received legal advice provided by the IMO Secretariat on the interlink between the use of EGCS as
an equivalent means of compliance to the sulphur requirements of MARPOL Annex VI, and the United Nations
Convention on the Law of the Sea (UNCLOS). The advice was that it is up to the IMO to establish at what
threshold the use of EGCS would cause deleterious effects and/or harm to the marine environment. If the IMO
determines as such, EGCS’ continued acceptance would be at conflict with UNCLOS and would require further
regulatory control for the use of EGCS.
The legal advice also considers the basis on which individual States can act unilaterally in limiting the use of
EGCS in their waters and when States must first consult the IMO. The legal advice concludes that whilst
coastal States have sovereignty over their territorial seas, they may not impose requirements in their EEZ that
are more stringent than international rules and standards without consultation with the IMO.
Noting that PPR 11 had also considered the advice in the context of its work on EGCS and that due to the
proximity of PPR 11 and MEPC 81 and that MEPC 82 will receive the report from PPR 11, MEPC agreed to
consider the legal advice at the same time as considering the report of PPR 11 during MEPC 82.
Black Carbon Emissions in and near the Arctic

In considering proposals for mandatory requirements for ships operating in or near the Arctic with a view to
reducing Black Carbon emissions in the region, requirements on the limit of fuel types acceptable for use in a
region north of latitude 60 degrees North, and a polar fuel standard, MEPC deferred the consideration of these
proposals to MEPC 82 at which point it will receive the report from PPR 11 which has developed related
measures.

Energy Efficiency of Ships
Review of the short-term measures (CII and EEXI)

MEPC noted a variety of reports on the use of the Operational Carbon Intensity Indicator (CII) after the first
year of its operation. Common themes for poor attained CII were due to issues such as long waiting times at
ports, difficulty in application of correction factors, communication between stakeholders, loading and
unloading operations and shorter voyages.
In considering the experience gained in the CII framework, MEPC noted work done by the ferry industry in
using differing methods to derive transport work (where transport work is currently derived as the product of
gross tonnage and miles travelled for Ro-ro ships) based on number of days in service as opposed to distance
travelled. MEPC, however noted that this would pose new challenges which would need to be overcome.
In reviewing existing instruments supporting Chapter 4 of MARPOL Annex VI, MEPC:
• Instructed the Secretariat to issue a corrigenda to the 2022 Interim Guidelines on correction factors and
voyage adjustments for CII calculations (CII Guidelines, G5) (MEPC.355(78)) to correct a reference to the G1
Guidelines concerning the definition of capacity (GT or DWT).
• Adopted amendments (MEPC.390(81)) to the 2021 Guidelines on the Shaft/Engine Power Limitation System
to Comply with the EEXI Requirements and Use of a Power Reserve (MEPC.335(76)). The amendments clarify
actions to be taken by the bridge officers when a control unit for calculation and limitation of the power
transmitted by the shaft to the propeller(s) which is independent from the engine automation is used, that
the use of unrestrained power should be reserved for scenarios which may endanger safe navigation of the
ship, and consideration of manoeuvring characteristics with unlimited and limited power.
• Adopted amendments (MEPC.389(81)) to the 2022 Guidelines for the Development of a Ship Energy Efficiency
Management Plan (SEEMP) (MEPC.346(78)) and 2022 Guidelines for Administration Verification of Ship Fuel
Oil Consumption Data and Operational Carbon Intensity (MEPC.347(78)) to support the required information
that will become mandatory upon entry into force of the amendments to Annex VI Appendix IX (1 August
2025) (See section on Adoption of Amendments to Mandatory Instruments). These amendments, amongst
other things, give guidance on the methodology for recording fuel consumption per consumer as well as
how to record when a ship is under way/ not underway for the purpose of data recording to the DCS.
MEPC recalled that the amendments to the 2021 Guidelines on the Shaft/Engine Power Limitation System to
Comply with the EEXI Requirements and Use of a Power Reserve MEPC.335(76) adopted at MEPC 80 included a
requirement to report to the Administration or its Recognised Organisation, instances of using reserve power,
and that, on an annual basis by 30 June each year the Administration should report to the IMO Secretariat
uses of a power reserve over a 12-month period from 1 January to 31 December for the preceding calendar
year. In this respect, MEPC approved a procedure for Administrations to report this information to the IMO
Secretariat (MEPC.1/Circ.908).
MEPC also agreed to the reclassification of LNG carriers that are currently reported as gas carriers for the
purpose of the data reporting in Annex VI regulation 27, and assignment of a CII rating as LNG carriers, and
invited the secretariat to recalculate Annual Efficiency Ratio (CO2 emissions per unit transport work) for LNG
and gas carrier fleets for 2021 and 2022 after the re-categorisation. LR expects that the Secretariat will work
with IACS members, through IACS, to conduct this reclassification in the Data Collection System on fuel oil
consumption reporting (DCS).

MEPC agreed that this re-categorisation should not be interpreted to affect the ship type indication on a ship’s
International Energy Efficiency Certificate (IEEC) and should not pre-judge the possible outcome of the CII
review process.
In considering a proposal to further refine the CII reference lines based on IMO DCS data and current ship type
specific correction factors specifically for the Secretariat to commission a study, MEPC agreed to consider this
at MEPC 82 (October 2024) as part of the review of the short-term measures (EEXI and CII).
Also deferred to MEPC 82 was a proposal to align the carbon intensity reduction trajectory with the levels of
ambition and indicative checkpoints in the 2023 IMO Strategy on Reduction of GHG Emissions from Ships as well
as for the metric to be one of energy efficiency in terms of Joules per tonne-mile, along with tangible
enforcement mechanisms and better incentives for achieving a B or A rating. This will also be considered in
the context of the wider review concluding by 2026.
Review of the data within the DCS database

Noting that the data IMO holds in the DCS for fuel oil consumption is a primary tool in reviewing the
effectiveness of regulatory measures as well as designing future measures, and that the data is not always
reported in a uniform manner, MEPC invited the Secretariat to conduct a review of the suitability of the IMO
DCS for the implementation and enforcement of current and future regulatory GHG measures. This will
include data quality and integrity, focusing on the identification and assessment of risks and vulnerabilities
and possible solutions to address them.
It was also agreed that the uniform reporting of VLSFO and ULSFO to the DCS would be beneficial and that
suitable nomenclature and naming conventions would avoid an excessive number of different and non-
standard fuel names in the DCS which will make processing and analysis of the data more consistent.
Accordingly, MEPC invited Member States and International Organisations to submit proposals for a unified
interpretation for the consistent reporting of VLSFO and ULSFO to a future session.
Transport of biofuels
MEPC considered challenges experienced in the transport of biofuels in bulk. Traditional fuel oil is transported
as a MARPOL Annex I product on tankers, whereas biofuels are classified as a MARPOL Annex II product and
cannot currently be transported in a traditional oil tanker (for products with higher percentages of biofuel
than 25%) and this poses an immediate challenge for the mass take up of biofuel as an alternative to VLSFO.
Accordingly, MEPC referred the matter to ESPH 30 (14-18 October 2024) for further consideration, with a view
to advising MEPC on the way forward.
Unified Interpretations of MARPOL Annex VI

MEPC agreed to an amendment to the unified interpretation on applicability of the phases for EEDI,
specifically those ships for which phase 1 commenced from 1 September 2015, clarifying that phase 1 applies
when:
• The building contract of which is placed in Phase 1, and the delivery is before 1 January 2024; or

• The building contract of which is placed before Phase 1, and the delivery is on or after 1 September
2019 and before 1 January 2024; or
• In the absence of a building contract:
− The keel of which is laid or which is at a similar stage of construction on or after 1 March 2016 and
before 1 July 2020, and the delivery is before 1 January 2024; or
− The keel of which is laid or which is at a similar stage of construction before 1 March 2016, and the
delivery is on or after 1 September 2019 and before 1 January 2024;
MEPC also agreed to a new unified interpretation of the definition general cargo ship where the definition
excludes specialised cargo ships such as heavy load carriers. The interpretation clarifies that heavy load
carriers are considered as:
• (Heavy load) Deck carriers;

• Semi-submersible project cargo carriers;
• Semi-submersible (Heavy load) deck carriers (including dock lift ships);
• Heavy lift multi-purpose ships;
• Premium project carriers; and
• Project cargo carriers.
These interpretations will be issued in a revision to Unified Interpretations of MARPOL Annex VI

(MEPC.1/Circ.795/Rev.8) which will be issued as Rev.9.
Reduction of GHG emissions from ships
Development of Mid-term measures

MEPC reviewed the report from the Intersessional Working Group on the reduction of Green House Gases
(ISWG-GHG 16) which took place the week before MEPC 81 in which the ISWG-GHG further considered a basket
of mid-term measures consisting of the following proposals for candidate measures:
Name and Sponsor Key features

GHG Fuel Standard Trajectory for GHG Fuel Intensity (GFI) reduction: incremental reductions
(Candidate Technical from entry into force through to 2050 when 100% reduction is anticipated
Element) (with intermediate figures to be discussed). The reduction values would be
Submitted by the compared to a reference calculated with data from the IMO data collection
European Union Members system (DCS) from 2023, 2024 and 2025.
Flexible compliance: ability to ‘bank’ ‘over compliance’ for use in future

years.
Allowance for ‘pooling’ of ‘over compliance’ with ships not able to comply
with the specified GFI.
Ability for purchase of remedial credits to make up deficiencies in

compliance.

GHG Price on International Financial contribution: Flat rate of 150 USD/ per tonne CO2 equivalent (e).
Bunkers (Candidate
Economic Element) Flexible compliance: None.
Submitted by Belize et al.
Green Balance Mechanism Trajectory for GHG Fuel Intensity (GFI) reduction: Assumes a trajectory that
(Combination of a meets the indicative reduction checkpoints agreed in the 2023 IMO Strategy
Candidate Economic and a on Reduction of GHG Emissions from Ships (MEPC.377(80)) (20% reduction by
Technical element) 2030 and 70% by 2040) through to 100% reduction by 2050. These are
Submitted by WSC assumed to be compared to 2008 levels as per the strategy.
Flexible compliance: None.
Financial contribution: A concept in which ships not meeting the required

GFI pay a fee, those meeting the GFI and exceeding it by up to 10% pay
nothing and those exceeding the GFI by more than 10% receive a financial
reward.
The concept is for the fees to react to market conditions and to balance out
the rewarded fees with the fees collected. The reward would also factor in
the availability of near-zero and zero-emissions fuels in a given year.
IMO Maritime Financial contribution: Increasing fees with initial schedule proposed as:
Sustainability Platform 90 USD/ tonne of CO2 equivalent (e) in 2027
(Candidate Economic 100 USD/ tonne of CO2e in 2028
Element) 115 USD/ tonne of CO2e in 2029
Submitted by Canada 130 USD / tonne of CO2e in 2030
Further schedules would be set at least 5 years before their application.
The emissions to which are accounted are:

• Tank to Wake (TtW) emissions to avoid double counting of emissions
upstream; and
• Well to Tank (WtT), reported to land-based emissions counting
schemes.
However, a mechanism is proposed to ensure a fuel with large WtT but low
TtW emissions still receives a proportionate fee.

International Maritime Trajectory for GHG Fuel Intensity (GFI) reduction: Reductions are set
Sustainable Fuels and compared to a base value of 76.2 gCO2e/MJ (which is generally accepted as
Fund Combination of a the Tank to Wake (TtW) fossil fuel GFI) as:
Candidate Economic and a 2% (2027)
Technical element) 5% (2030)
15% (2035)
Submitted by Argentina et 35% (2040)
al. 65% (2045)
85% (2050)
Flexible compliance: Allowance for ‘banking’ of ‘overcompliance’ for use in

future years.
Allowance for Purchasing compliance credits to make up any deficit in

compliance.
Ability to ‘pool’ ‘overcompliance’ with ships not able to comply with the
specified GFI in private (collections of ships from specific companies) or
public (centrally administered) pools.
Over compliance can also be financially rewarded instead of saved or

pooled.
Financial contribution: Would be set by MEPC ahead of the relevant

reporting period.
Simplified Global GHG Trajectory for GHG Fuel Intensity (GFI) reduction: 5% reduction by 2030 and
Fuel Standard (Candidate 30% reduction by 2040, both compared to 2019 levels which may be
Technical Element) determined using data from DCS.
Submitted by ICS
Flexible compliance: Allowance to ‘pool’ ‘overcompliance’ with ships not
able to comply with the specified GFI ships.
Zero Emission Shipping Financial contribution: 20 USD/ tonne CO2e. In addition, there is a reward
Fund (Economic) available of 100 USD/ tonne CO2e prevented (compared to the same energy
Proposed by Japan consumption of HFO).

Zero Emission Shipping Financial contribution: Figures for contribution to be decided. There is a
Fund (Economic Measure) reward system per tonne of CO2e saved (compared to the same energy
Proposed by ICS consumption of marine diesel/ gas oil). The amount of reward is also to be
decided.

When considering the basket of candidate measures, MEPC noted the following timeline -as envisaged in the
2023 IMO Strategy on Reduction of GHG Emissions from Ships (MEPC.377(80)):
MEPC noted the following aspects related to progressing the basket of mid-term measures:
Elements related to a goal-based marine fuel standard regulating GHG Fuel Intensity (GFI) along a
reduction trajectory
MEPC 81 noted the following considerations of ISWG-GHG 16:
• Agreement to develop such a standard as part of a basket of mid-term measures taking account of
Well-to-Wake (WtW) GHG emissions of marine fuels;
• Confirmation that the agreed levels of ambition in the 2023 IMO Strategy on Reduction of GHG Emissions
from Ships (MEPC.377(80)) will frame GFI targets (namely that the GFI would reach net-zero by 2050)
and that the indicative check points (20% reduction by 2030, and 70% reduction by 2040, both
compared to 2008) would frame the GFI reduction trajectory;
• That further consideration is required for the exact reduction trajectory between the entry into force of
a fuel standard and 2050; and
• That the baseline for the reduction trajectory requires further consideration.
Proposals for flexible compliance strategies and relevant reporting and verification requirements in
support of the goal-based marine fuel standard
• MEPC 81 noted the following considerations of ISWG-GHG 16:

• General convergence of the members of ISWG-GHG on the inclusion of flexible compliance strategies as
an element of a goal-based marine fuel standard. However, some could not agree to proposed
flexibility mechanisms, expressing concern around unintended consequences and unequal access to
flexible compliance options. This view was particularly prevalent for those countries without the
experience and scale to operate trading markets, and which are served by older ships, therefore
resulting in an economic transfer from least developed economies to the most developed economies;

• That flexible compliance strategies may include trading of over-compliance units, the purchase of
remedial units, and pooling; and
• That further work is needed on methodological issues relating to flexible compliance strategies as well
as how to set the price of remedial units to incentivise the transition to zero- and near-zero emission
fuels and technologies, whilst not over penalising non-compliant ships and maintaining a level playing
field.
Proposals on a maritime GHG emissions pricing mechanism, revenue collection and distribution:
MEPC 81 noted the following considerations of ISWG-GHG 16:
• Agreement to develop, as part of the basket of mid-term measures, an economic element, on the basis
of a maritime GHG pricing mechanism with the aim to “effectively promote the energy transition of
shipping and provide the world fleet a needed incentive while contributing to a level playing field and a
just and equitable transition”; and
• That further consideration is needed to agree if the pricing mechanism will follow either an integral
approach, where technical and economic elements would be integrated into the goal-based marine
fuel standard, or a separated approach where a separate economic element would be developed in
addition to the goal-based marine fuel standard.
Method to progress the development of mid-term measures
MEPC 81 endorsed the proposed way forward developed by ISWG-GHG 16 as follows:
• That a two-day expert workshop (GHG-EW 5) will be organised over the summer to consider the initial
findings of the IMO commissioned Comprehensive Impact Assessment, including consideration of
possible modelling of revenue distribution as part of the assessment of impact on States; and
• The next session of the IWSG-GHG (ISWG-GHG 17), will be held back-to back with MEPC 82 (scheduled
for 30 September – 4 October 2024) the week before (provisionally scheduled 23 – 27 September 2024)
with terms of reference to further consider the development of the basket of candidate mid-term
measure(s) taking account of the final report on the IMO commissioned comprehensive impact
assessment and the report of GHG-EW 5.
In addition, MEPC agreed to an Illustration of how an “IMO Net-Zero Framework” as amendments to MARPOL
Annex VI could be set out, which follows a similar structure to the amendments used to bring CII and EEXI into
force comprising amendments to:
• Chapter 1 (Definitions);
• Chapter 2 (Survey, Certification and Port State Control);
• Chapter 4 (SEEMP and Data collection);
• A new Chapter 5 (titled “Regulations on the IMO net-zero framework”) including sub-chapters on:
− Goal-based marine fuel standard regulating the phased reduction of the marine fuel’s GHG intensity;
and
− Economic mechanism(s) to incentivise the transition to net-zero; and
• Appendices (forms of certification).
LR’s expectation is that the illustration will form the structure for regulations upon agreement of candidate
measures or elements of candidate measures that are progressed into regulation. Whilst it remains uncertain
as to which measures will be progressed into regulation, it is clear that there will be a fuel standard and an
economic mechanism. LR expects the approval of regulations implementing the selected economic and
technical measures will occur at MEPC 83 (Spring 2025), and the associated regulations will enter into force in

the first half of 2027, as envisaged in the 2023 IMO Strategy on Reduction of GHG Emissions from Ships
(MEPC.377(80)).
Life-Cycle Assessment of GHG emissions

MEPC adopted the 2024 Guidelines on Life Cycle GHG Intensity of Marine Fuels (2024 LCA Guidelines)
(MEPC.391(81)) which introduce elements to the guidelines concerning, amongst other things, clarification of
emissions during bunkering and how these are assigned to WtT and TtW emissions and calculations of
emissions from carbon stock changes caused by direct land-use change, calculation of emissions from soil
carbon accumulation via improved agricultural management, and refinement of the approach to TtW default
emissions factors.
With regard to further review of the Guidelines on Life Cycle GHG Intensity of Marine Fuels (MEPC.376(80)), MEPC
agreed to the establishment of a scientific group under the auspices of GESAMP (Joint Group of Experts on the
Scientific Aspects of Maine Environmental Protection) as a GESAMP-LCA Working Group to further consider the
technical and scientific elements of the Guidelines. Elements related to social and economic sustainability
themes of marine fuels will be considered by a correspondence group reporting to MEPC 83 (scheduled for
April 2025). The areas of work for this GESAMP-LCA WG will include:
• A methodological refinement of the emission quantification in the LCA Guidelines, with a view to
ensuring the integrity of all information provided including:
− A scientific review of the LCA methodology;
− A scientific review of the WtT GHG default emission factors of fuel production pathways and
technologies;
− A scientific review of the TtW GHG default emission factors of fuel usage and onboard technologies
(explicitly mentioning onboard carbon capture and storage (OCCS) boundaries); and
− Sample calculations on LCA and reflecting the output into the existing Fuel Lifecycle Label (FLL).
• Consideration of sustainability themes/aspects including:
− Refining and further exploring indicators and metrics under the sustainability themes/aspects in the
LCA guidelines; and
− Consideration of approaches to Indirect Land Usage Change (ILUC) risk classification.
• Methodological requirements of the LCA Guidelines regarding certification including:
− Provision of external experience, and further information for the development and/or identification
of possible requirements for fuel pathway certification, including WtT and TtW actual values.
Onboard Carbon Capture and Storage (OCCS)

MEPC considered reports of ongoing projects for the use of OCCS and agreed to develop a framework for its
use as one of many solutions to meet emission reduction targets. MEPC tasked an intersessional
correspondence group to develop a work plan on the development of a regulatory framework for the use of
onboard carbon capture systems with the exception of matters related to accounting of CO2 captured on
board ships. MEPC further instructed the GESAMP-LCA Working Group to consider OCCS in the context of TtW
default emissions factors and associated system boundaries as discussed above.

Climate Nomenclature
MEPC requested the Secretariat to disseminate a glossary of climate change definitions developed by a variety
of non-governmental organisations as information through the online information portal of the “IMO Future
Fuels and Technology Project” .
Fifth IMO GHG study

Noting the short-term measures (CII and EEXI) came into effect in 2023 and the IMO has adopted a revised
GHG strategy, MEPC agreed to conduct the Fifth IMO GHG Study and instructed the Secretariat to submit a
proposal with draft terms of reference, suggested timelines, logistics and administrative arrangements to
MEPC 82 in October 2024 which will be considered and further developed by ISWG-GHG 17 the week before
MEPC 82.
Tank-To-Wake Emissions of Methane and Nitrous Oxide

MEPC considered how to develop a framework for the measurement and verification of Tank-to-Wake
emissions of methane (CH4), nitrous oxide (N2O) and other GHGs along with associated engine certification
issues in the context of the further development of the LCA Guidelines. To progress this matter, MEPC
established an intersessional correspondence group to:
• Consider how to develop a framework for the measurement and verification of actual Tank-to-Wake
methane (CH4) and nitrous oxide (N2O) emission factors and Cslip value for energy converters, which
may include, but not limited to:
− standardisation required regarding a test cycle approach (including mode points and weighting
factors);
− onboard monitoring;
− engine load distribution, and
− associated measurement equipment technology and procedures, as applicable;
• Consider how to develop a methodological framework for associated certification issues in support of
the application of the LCA Guidelines; and
• Identify the relevant gaps in existing instruments, and propose recommendations, with a view to
developing necessary regulatory or recommendatory instruments.
Marine Plastic Litter
Circular on the carriage of plastic pellets

MEPC approved MEPC.1/Circ.909 Recommendations for the carriage of plastic pellets by sea in freight
containers, following work undertaken by PPR and CCC. This circular will act as a short-term measure with the
aim of reducing the environmental risks associated with the carriage of plastic pellets in packaged form by sea
ahead of mandatory instruments being developed.

Review of the Action Plan on Marine Plastic Litter
The review of MEPC.310(73) Action Plan to Address Marine Plastic Litter from Ships which was deferred from
MEPC 80 was briefly discussed. However, noting the ongoing work in by PPR on this matter and that the
outcome of PPR 11 would be considered at MEPC 82, the review of the action plan on Marine Plastic litter was
deferred to that session.
Pollution Prevention and Response

Due to PPR 11 only concluding 3 weeks prior to this session of MEPC, outcomes of that session will be
discussed at MEPC 82, with the exception of the urgent item on the approval of the MEPC.1/Circ.909 on
Recommendations for the carriage of plastic pellets by sea in freight containers.
Reports of other sub committees
SDC 10 – Underwater Radiated Noise (URN)

Commercial shipping is one of the main contributors to underwater radiated noise (URN), which has adverse
effects on marine life, including marine mammals, upon which many coastal and indigenous communities
depend for their food, livelihoods, and cultures. MEPC considered the following urgent matters emanating
from Ship Design and Construction (SDC) 10 on URN:
URN Experience Building Phase (EBP)
The main objectives of the URN EPB are to collect information on lessons learned and best practices in the
application and the uptake of MEPC.1/Circ.906 Revised guidelines for the reduction of underwater noise from
shipping, by ship designers, builders, owners, and operators to reduce the URN of any given ship. MEPC
encouraged early uptake of the EBP through the implementation of the revised Guidelines for the reduction of
underwater radiated noise (MEPC.1/Circ.906) and invited submissions to MEPC 82 on this topic, where data is
available.
Draft Action Plan for reduction of URN from commercial shipping
Recognising the need for an action plan to address barriers to the uptake of MEPC.1/Circ.906 Revised
guidelines for the reduction of underwater noise from shipping, MEPC endorsed in principle the draft Action plan
for the reduction of underwater noise from commercial shipping, with a view to further consideration and final
approval at MEPC 82.
MEPC endorsed the draft Action Plan for the reduction of underwater noise from commercial shipping, which
aims to:
• Enhance public awareness, education, and seafarer training;
• Standardise the Underwater Radiated Noise Management Planning process;
• Develop Underwater Radiated Noise Targets;
• Further develop the policy for URN reduction;
• Develop tools to collect data and share information;

• Encourage research on URN and GHG/URN and Biofouling and the impacts of URN on species and
habitats; and
• Decide, in more concrete terms, priorities and possible timelines for the completion of the points
above.
Additionally, submissions addressing the Action Plan were invited to MEPC 82, whilst noting that no further
revisions to the URN Guidelines will be undertaken until the EBP has been completed.
HTW-9 - Training provisions for seafarers related to the BWM Convention

MEPC 80 considered and agreed with the decision of the Human Element Training and Watchkeeping (HTW) 9
sub-committee, that as part of the “Comprehensive review of the 1978 STCW Convention and Code”, work on
the "Development of training provisions for seafarers related to the BWM Convention" should also be
considered.
III-9 - Revision of the Guidelines for port State control (PSC) under the Ballast Water
Management (BWM) Convention
MEPC agreed with the decision of the Implementation of IMO Instruments (III) 9 sub-committee to only
consider a revision of MEPC.252(67) Guidelines for port State control (PSC) under the Ballast Water Management
(BWM) Convention, once the revision of the BWM Convention has been concluded, given the nature, the
number and the complexity of the issues involved.
Special Areas Emission Control Areas (ECAs) and

Particularly Sensitive Sea Areas (PSSAs)
Canadian Arctic ECA

MEPC approved an ECA in the Canadian Arctic for NOx and SOx with a view to adoption at MEPC 82.
This ECA comprises of two segments starting at the Yukon mainland at 68.900° North 137.000° West; and
ending at the north coast of Hans Island at 80.83183° North 66.45667° West and continuing from the south
coast of Hans Island at 80.82144° North 66.45067° West, and ending at the coast of Newfoundland and
Labrador at 60.000° North, 64.160° West.
The ECA will require NOx Tier III compliance for ships constructed (keel of which has been laid or is at a similar
stage of construction) on or after 1 January 2025 and which are operating in the ECA. The ECA will introduce
the requirement for fuel Sulphur content to be no more than 0.10% m/m for ships operating within the ECA 12
months after the regulations enter into force, expected 1 March 2026 for entry into force and to be in effect
from March 2027.

ECA in Norwegian Sea
MEPC approved an ECA in the Norwegian Sea with a view to adoption at MEPC 82.
This ECA is defined as the same area specified in MARPOL Annex II regulation 13.9.4.
The ECA will require NOx Tier III compliance for ships constructed on or after 1 March 2026 and operating
within it. In the context of this ECA, constructed on or after 1 April 2026 will mean:
• For which the building contract is placed on or after 1 March 2026;

• In the absence of a building contract, the keel of which is laid or which is at a similar stage of
construction on or after 1 September 2026; or
• The delivery of which is on or after 1 March 2030.
The ECA will introduce the requirement for fuel Sulphur content to be no more than 0.10% m/m for ships
operating within the ECA 12 months after the regulations enter into force, expected 1 March 2026 for entry
into force and to be in effect from March 2027.
Any other business
Hong Kong Convention

New draft reporting formats and GISIS for implementation of the Hong Kong Convention for the safe
and environmentally sound recycling of ships
The 2009 Hong Kong International Convention for the Safe and Environmentally Sound Ship Recycling (HKC)
will enter into force on 26 June 2026. Under the requirements of the HKC parties to the Convention are
required to report a variety information to the IMO. Following discussion MEPC:
• Instructed the Secretariat to develop a new GISIS module for parties to fulfil their reporting obligations
on ship recycling.
• Approved MEPC.1/Circ.910 Formats for mandatory reports under article 12 of the Hong Kong Convention
for use in the interim pending development of the GISIS module.
• Request the Secretariat to submit an annual report to MEPC, starting in 2026, a document outlining the
number of ship recycling facilities authorised, number of ships issued with an International Ready for
Recycling Certificate, the number of ships recycled, as well as the corresponding gross tonnage, during
the preceding calendar year.
Alignment of Basel Convention and Hong Kong Convention
Once the HKC enters into force, (June 2025) the global legal framework for ship recycling will change. At that
point when a ship has received an International Ready for Recycling Certificate (IRRC) under the HKC, it may
concurrently be considered a hazardous waste under the provisions of the Basel Convention (BC). During the
entire validity period of the IRRC (up to three months), the ship could therefore be at risk of being arrested for
being in breach of the BC requirements while still trading.
MEPC discussed this regulatory challenge and agreed the legal inconsistencies should be clarified with BC
through communication between the IMO and BC via both Member States, Secretariats and by reporting of
the outcomes of MEPC 81 to the next Basel Convention COP. In addition, the Secretariat was requested to

develop guidance on the two conventions for consideration at MEPC 82, alongside any other submissions on
the interplay of both HKC and the BC.
Port Reception Facilities

MEPC discussed the requirement of parties to the MARPOL convention to notify the IMO and its members, of
their national regulations for discharging treated sewage/grey water discharge from ships. It was proposed that
the Organisation should develop a database of local/regional regulations on treated sewage/grey water
discharges within the public area of the port reception facilities as a matter of priority. MEPC referred the paper
to PPR 12, to be considered as part of the work under Agenda Item 4, looking at Amendments to MARPOL Annex
II.
Marine environmental pollution response

National Meteorological and Hydrological Services (NMHSs) play an important role in the provision of marine
meteorological and specialised services for marine emergency response, including in support of marine
pollution emergency response and search and rescue operations. The World Meteorological Organization
proposes to expand the marine meteorological support for marine environmental pollution response through
the establishment of World Meteorological Organization (WMO) Regional Specialised Meteorological Centres
(RSMCs) for marine emergency response.
MEPC supported the establishment of RSMCs and encouraged national engagement with these centres and
agreed that once established the RSMCs will support in MARPOL related responses. The proposed
amendments to the manual on the global forecasting system should be developed locally at the Member
State level.
Oil tanker slop tank use

MEPC noted a proposal to clarify if a slop tank can be designated to carry cargo oil and forwarded this to PPR
12 for further consideration and to advise the Committee on a way forward.

Regulatory Affairs
Lloyd’s Register Global Technology Centre,
Hampshire House, Hampshire Corporate Park,
Southampton
SO53 3RY, UK
Lloyd’s Register EMEA
e: RegulatoryAffairs@lr.org
w: www.lr.org/imo
To find previous material and to register to receive regular updates on IMO meetings and
developments, please visit https://www.lr.org/imo
This report has been produced and disseminated immediately after the closure of the meeting
in order to provide timely advice to the reader. Subsequently we apologise if it has not been
fully proof read to remove grammatical errors. New circular and resolution numbers given
here may be subject to change when IMO publish the final versions.
Lloyd’s Register and variants of it are trading names of Lloyd’s Register Group Limited, its subsidiaries and affiliates.
Copyright © 2024 Lloyd’s Register EMEA (Reg. no. 29592R) is a registered society under the Co-operative and Community
Benefit Societies Act 2014 in England and Wales. Registered office; 71 Fenchurch Street, London, EC3M 4BS, UK. A member
of the Lloyd’s Register group.
Lloyd’s Register Group Limited, its subsidiaries and affiliates and their respective officers, employees or agents are,
individually and collectively, referred to in this clause as ‘Lloyd’s Register’. Lloyd’s Register assumes no responsibility and
shall not be liable to any person for any loss, damage or expense caused by reliance on the information or advice in this
document or howsoever provided, unless that person has signed a contract with the relevant Lloyd’s Register entity for the
provision of this information or advice and in that case any responsibility or liability is exclusively on the terms and
conditions set out in that contract.

MEPC 81 Summary Report

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

MEPC 81 Summary Report

Uploaded by

Copyright:

Available Formats

IMO Marine Environment and Pollution

Committee Eighty-First session (MEPC 81)

Lloyd’s Register Briefing Note – Summary Report MEPC 81 Page 2

Decisions of Other Bodies

MSC 107 Electronic certificates

Lloyd’s Register Briefing Note – Summary Report MEPC 81 Page 3

Amendments to the International Ballast Water Management Convention

Amendments to Protocol I of MARPOL Article V

Amendments to MARPOL Annex VI

These amendments are expected to enter force on 1 August 2025.

Guidelines required by regulation 13.2.2 of MARPOL Annex VI

Lloyd’s Register Briefing Note – Summary Report MEPC 81 Page 4

Harmful aquatic organisms in ballast water

• A definition for the “Electronic Record Book”.

These amendments will enter into force on 1 October 2025.

Approval of Ballast Water Management Systems (BWMS)

Lloyd’s Register Briefing Note – Summary Report MEPC 81 Page 5

Modifications to BWMS with existing type approval

Ports with challenging water quality

This guidance is applicable to:

Lloyd’s Register Briefing Note – Summary Report MEPC 81 Page 6

Amendments to BWM convention

Air Pollution Prevention

Engine Air Pollution Prevention (EIAPP) Certification

Lloyd’s Register Briefing Note – Summary Report MEPC 81 Page 7

Exhaust Gas Cleaning System wash water effluent discharges

Black Carbon Emissions in and near the Arctic

Lloyd’s Register Briefing Note – Summary Report MEPC 81 Page 8

Review of the short-term measures (CII and EEXI)

In reviewing existing instruments supporting Chapter 4 of MARPOL Annex VI, MEPC:

Lloyd’s Register Briefing Note – Summary Report MEPC 81 Page 9

Review of the data within the DCS database

Unified Interpretations of MARPOL Annex VI

Lloyd’s Register Briefing Note – Summary Report MEPC 81 Page 10

• (Heavy load) Deck carriers;

These interpretations will be issued in a revision to Unified Interpretations of MARPOL Annex VI

Reduction of GHG emissions from ships

Development of Mid-term measures

Name and Sponsor Key features

Flexible compliance: ability to ‘bank’ ‘over compliance’ for use in future

Ability for purchase of remedial credits to make up deficiencies in

Lloyd’s Register Briefing Note – Summary Report MEPC 81 Page 11

Flexible compliance: None.

Financial contribution: A concept in which ships not meeting the required

Further schedules would be set at least 5 years before their application.

The emissions to which are accounted are:

Flexible compliance: None.

Lloyd’s Register Briefing Note – Summary Report MEPC 81 Page 12

Flexible compliance: Allowance for ‘banking’ of ‘overcompliance’ for use in

Allowance for Purchasing compliance credits to make up any deficit in

Over compliance can also be financially rewarded instead of saved or

Financial contribution: Would be set by MEPC ahead of the relevant

Flexible compliance: None.

Flexible compliance: None.

Lloyd’s Register Briefing Note – Summary Report MEPC 81 Page 13

MEPC 81 noted the following considerations of ISWG-GHG 16:

• MEPC 81 noted the following considerations of ISWG-GHG 16:

Lloyd’s Register Briefing Note – Summary Report MEPC 81 Page 14

MEPC 81 noted the following considerations of ISWG-GHG 16:

Method to progress the development of mid-term measures

MEPC 81 endorsed the proposed way forward developed by ISWG-GHG 16 as follows:

Lloyd’s Register Briefing Note – Summary Report MEPC 81 Page 15

Life-Cycle Assessment of GHG emissions