IBIA at MEPC 79: Preview

New ECA and BDN requirements, discussions on GHG, biofuels, black carbon and EGCS are on the agenda at the IMO this week.

IBIA will be at the IMO for the 79th session of the Marine Environment Protection Committee (MEPC 79) at the IMO from 12-16 December 2022, which has a packed agenda. The following is an overview of the subjects most relevant to IBIA members.

GHG discussions

We expect some progress in discussions on the revision of the IMO’s GHG strategy following the 13th session of the Intersessional Working Group on GHG Emissions (ISWG-GHG 13) in the week preceding MEPC 79, but not any firm decisions.

IBIA was at ISWG-GHG 13 observing discussions and we see strong signs that the revised IMO GHG Strategy, due to be adopted at MEPC 80 in July next year, will boost the level of ambition for 2050 GHG emission reductions, and possibly introduce interim targets between 2030 and 2050 to ensure we’re on the right trajectory. Many member states want GHG emissions from shipping to be phased out by 2050, a big ask compared to the current goal of halving overall GHG emission from shipping by 2050. Others are concerned this is not realistic and could have disproportionately negative impacts on developing countries.

IBIA was pleased, during ISWG-GHG 13, to see growing support for measures that can support the fuel transition that will be needed to eliminate GHG from shipping, including a gradual introduction of a GHG limit for fuels, putting a price on carbon to narrow the price gap between fossil fuels and alternative fuels, and finding ways of rewarding early adopters.

Moreover, as seen during ISWG-GHG 13, there appears to be majority support for taking well to wake emissions into account, which IBIA supports, even though working out how to do it is complex. The interim report to MEPC 79 from the Correspondence Group on Marine Fuel Life Cycle GHG Analysis has identified 14 types of fuels that have the potential to be used, and a staggering 103 well to wake “pathways” for these fuels, so as not to discriminate against any fuel or fuel pathway. It is expected that this has to be narrowed down in order to agree on guidelines within a reasonable timeframe, and ideally by MEPC 80.

MEPC 79 will also consider proposals related to onboard CO2 capture, and various proposals related to the energy efficiency of ships.

Adoption of new ECA and BDN requirements

MEPC 79 is expected to adopt amendments to designate the Mediterranean Sea, as a whole, as an emission control area (ECA) for sulphur oxides under MARPOL Annex VI.

The new ECA limit of 0.10% for ships operating within the ECA is expected to take effect from 1 May 2025, unless MEPC 79 decided otherwise.

An amendment to MARPOL Annex VI regarding information to be included in the Bunker Delivery Note (BDN) is also up for adoption. This will bring in a new requirement to document flashpoint on the BDN; either the flashpoint temperature measured in Celsius, or a statement that flashpoint has been measured at or above 70° C. This is linked to work at the IMO’s Maritime Safety Committee, which adopted similar amendments to SOLAS Chapter II-2 (in force 2026) in November. For more information, please refer to this link.

Biofuels, NOx emissions, black carbon and EGCS matters

There are several documents on biofuels and biofuel blends for MEPC 79 to consider, including documents submitted to earlier sessions which have yet to be discussed. These look at NOx emissions as well as the potential for biofuels to be a viable GHG reduction alternative by taking lifecycle emissions into account.

MEPC will also discuss a proposal for amendments to the Unified Interpretation to MARPOL Annex VI (more info on this link) set out in circular MEPC.1/Circ.795/Rev.6, to include synthetic drop-in fuels, belonging to the group of RFNBOs (renewable fuels of non-biological origin).

Four papers on matters relating to exhaust gas cleaning systems (EGCS) are up for discussion, focusing on the impact of discharge water from scrubbers and how these should be regulated.

Black carbon emissions will also be discussed as a group of environmental NGOs are proposing to amend MARPOL Annex VI to incorporate a requirement for ships to only use marine distillate fuel or other cleaner alternative fuels when operating in or near to the Arctic, IBIA has been active in discussions about black carbon emission and supportive of measures to reduce such emissions in the Arctic region.

Working and Drafting groups

MEPC 79 is expected to establish four working groups (WGs) and one drafting group that will meet and work at the same time, in parallel with plenary. IBIA will take part in three of them as much as possible.

Drafting Group on Amendments to Mandatory Instruments;

This group will discuss and polish the final text of various MARPOL amendments that are up for adoption, taking into account any instructions from the Committee which will agree the terms of reference in plenary.

There are a number of amendments to MARPOL up for adoption, however IBIA’s attention will be focused on amendments to information to be included in the bunker delivery note (BDN), information to be submitted to the IMO Ship Fuel Oil Consumption Database and adoption of the Mediterranean ECA.

Working Group on Air Pollution and Energy Efficiency;

This WG is expected to deal with a variety of subjects. Among these, IBIA’s focus will be on promoting licensing schemes for bunker suppliers (more detail on this link), matters relating to biofuels and biofuel blends, black carbon emissions in the Arctic, and extension of the scope of the Unified Interpretation of regulation 18.3 of MARPOL Annex VI concerning the use of biofuels set out in MEPC.1/Circ.795/Rev.6 (more info on this link) to include synthetic drop-in fuels.

Working Group on Reduction of GHG Emissions from Ships

The task for this WG will be to further develop the draft Revised IMO Strategy on reduction of GHG emissions from ships. There are still many different views on what the new level of ambition should be, how to ensure an equitable transition and – once the new targets have been agreed – the exact nature of the measures to adopted to drive the necessary changes. As mentioned above, it seems unlikely that any firm decisions will be made at this session.