MEPC 85: Tuvalu proposes stricter net-zero rules with higher compliance costs

Tuvalu has proposed the most stringent of the amendments eligible for adoption at the Marine Environment Protection Committee (MEPC 85) meeting in November.

IMAGE: Opening of the IMO Marine Environment Protection Committee 2nd extraordinary session (April 2026) in London. Flickr of IMO

The Net-Zero Framework (NZF) approved at MEPC 83 in April 2025 introduced a two-tier GHG fuel intensity (GFI) standard requiring ships of 5,000 GT and above to progressively reduce well-to-wake GHG emissions from 2028 onwards, benchmarked against a 2008 baseline of 93.30 grams of CO2-equivalent per megajoule (gCO2e/MJ).

Reduction targets comprise a base target and a direct compliance target, ranging from 4-17% in 2028 and tightening to 30-43% by 2035.

Tuvalu has suggested keeping the base targets unchanged but dropping the 2028 step, starting at 6% in 2029 instead of 4% in 2028.

The direct compliance target should be set at 100% from 2029 through 2035. This would mean that no ship could reach direct compliance and that every tonne of emissions is priced, turning the framework into a levy in all but name.

The recommendations are consistent with the proposal submitted by Fiji, Kiribati, Nauru, Palau, Tuvalu and Vanuatu to MEPC 84 in April.

Tuvalu also proposes increasing the Tier 1 remedial unit price to $300/mtCO2e, three times the $100/mtCO2e agreed in principle at MEPC 83. The Tier 2 remedial unit price for emissions exceeding the base target would remain unchanged at $380/mtCO2e.

The proposal also eliminates the surplus unit mechanism entirely, which means that ships exceeding the required GFI targets will not receive surplus units that could be sold to under-complying vessels.

Instead, ships would balance any deficit solely through direct payments into the IMO Net-Zero Fund.

The proposal will be discussed during the intersessional Working Group on Reduction of Greenhouse Gas Emissions from Ships (ISWG-GHG) meetings scheduled for September and November, before delegates consider the framework at MEPC 85 from 30 November to 3 December.

If member states agree on a final text, the amendments could then be formally adopted at the second extraordinary session of the MEPC (MEPC ES.2). This session was adjourned in October 2025 and is expected to reconvene on 4 December.

By Konica Bhatt

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