Zero Carbon Desk

In April 2018 the International Maritime Organization (IMO) adopted its ‘initial strategy’ with the primary objective to achieve the reduction of the carbon intensity of shipping by 40% within 2030 (IMO 2030), while lowering the total GHG emissions from ships by at least 50% within 2050 (IMO 2050), both compared to 2008 levels.

At MEPC80, in July 2023, IMO delivered a revision of such strategy, which is intended to be more ambitious, as far as it sets the target of achieving net-zero emissions in 2050 (or close) with the following indicative checkpoint (compared to 2008 levels): a reduction in the total annual GHG emissions by at least 20%, but striving for 30%, by 2030,  and by at least 70%, but striving for 80%, by 2040.

In the meantime, In June 2021, MEPC-76 had approved the inclusion of specific technical and operational measures in Annex VI of MARPOL: namely, the Energy Efficiency Existing Ship Index (EEXI) and the Carbon Intensity Indicator (CII), both of which came into effect on 1 January 2023.

The EU has set its own targets for the decarbonisation of the shipping sector with the “Fit for 55” package, a set of proposals aimed at the revision and update of EU legislation to meet the EU’s target of climate neutrality by 2050. In this context, on 5 June 2023, with the entry into force of Directive (EU) 2023/959 and Regulation (EU) 2023/957 (MRV Regulation), the European Emission Trading Scheme was officially extended to the shipping sector.

The “Fit for 55” package also includes the FuelEu Maritime initiative, which will introduce limits on the greenhouse gas intensity of fuels used onboard also imposing zero-emissions at berth for certain types of vessels. The provisional political agreement reached at the UE level is now soon to be formally approved.

Thanks to our extensive expertise in the shipping and transport sectors, we are able to provide comprehensive assistance to our Clients on all emissions-related matters, including those concerning compliance with the IMO and EU measures in force, or due to be in force soon:

• EU Emission trading scheme (EU ETS)
• FuelEU Maritime
• CII / EEXI (IMO 2023)
• Contracts revision/drafting of new contracts
• Bunkering arrangements
• Emissions trading
• Green finance and sustainability linked loans

With the Zero Carbon Desk we wish to support our Clients in the transition towards decarbonisation, with a focus on all the legal issues and implications which may arise from the implementation of the mentioned measures, allowing them to keep up to date with the developments in the field, sharing regular updates on the governing regulations and providing legal analysis on the various topics.