The “Extraordinary Session” of IMO’s Marine Environment Protection Committee was indeed extraordinary and unprecedented! The outcome has been widely reported already but in summary there were three key issues that became points of contention and significant uncertainty leading to the adjournment. These were as follows:
1. as proposed by some Member States, once adopted the procedure for legal acceptance of the regulations should be by “explicit acceptance” rather than the usual “tacit acceptance” procedure;
2. confirmation that the IMO Net-Zero Framework, once it came into effect, would supersede any regional or national measures for controlling GHG emissions from international shipping e.g., EU-ETS; and
3. based on interventions made, would there be a sufficient majority of Parties to MARPOL Annex VI wanting to adopt the IMO Net-Zero Framework as it required a two-thirds majority.
On the first point, if it was agreed, by a simple majority of the Member States, to use the “explicit acceptance” procedure then the requirements, rather than coming into force 16 months following adoption, would probably not come into effect until the next decade, if at all. As the IMO itself observes on its website: “This process is very time consuming and most of the amendments adopted this way never entered into force”!
The second point was addressed, in part, with a draft clause included in the draft resolution for adopting the IMO Net-Zero Framework that seemed to be agreed.
However, all the above issues amplified uncertainty for Member States when considering their position and how to move the meeting to a point a decision or decisions could be made. This led to a majority of Member States considering it would be better to adjourn the meeting rather than push to make those decision(s) especially where they could not clearly judge the outcome of those decisions.
It is important to note that following the meeting, work has continued at ISWG-GHG 20 to prepare the important implementation guidelines, with a view to achieving greater understanding of the implications of the draft provisions so building confidence in the framework. At the start of the meeting many delegates called for a constructive dialogue to gain insight and to begin to address concerns expressed during MEPC/ES.2, indeed some expressed the view that the adjournment presented an opportunity to make important progress.
More details will be provided in the Members Meeting on 30 October 2025.