Find the latest publications from the Clean Shipping Coalition

This document provides comments on the work on fishing gear, including comments on document MEPC 84/8 (Australia), and the outcomes of PPR 13. It provides recommendations for the next steps for work on abandoned, lost and otherwise discarded fishing gear (ALDFG) under MEPC and PPR.

This document comments on document MEPC 84/10 and the ongoing work to develop mandatory measures for plastic pellets. It provides comments on the development of a dedicated plastics code under MARPOL Annex III as the preferred instrument to effectively reduce the environmental risk associated with the maritime transport of plastic pellets.

This document comments on the report of the third meeting of the GESAMP-LCA Working Group, highlighting the need for a robust, regular, and evidence-based assessment of the global ILUC risk for crop feedstocks used in the production of maritime biofuels.

This document comments on the report of the third meeting of GESAMP-LCA WG, regarding the development of a default well-to-tank (WtT) emission factor for fossil LNG. It highlights systematic underestimation of upstream emissions in life cycle assessments, cautions against adoption of non-representative or supplier-specific factors, and calls for a conservative, globally representative default value consistent with established benchmarks. It also provides alternative emission factors.

This document comments on the report of the third meeting of GESAMP-LCA WG (MEPC 84/7/16) and invites the Committee to instruct GESAMP-LCA WG to conduct an initial classification of fuel feedstocks into high-, medium-, or low-ILUC-risk categories at the global level, and to submit a report to MEPC 85 for consideration.

This document comments on the report of the third meeting of the GESAMP Working Group on Life Cycle GHG Intensity of Marine Fuels (GESAMP-LCA WG) (MEPC 84/7/16) and highlights the potential issues arising from the possible methodological refinements to the 2024 LCA Guidelines identified by GESAMP-LCA WG with respect to finding ways forward for addressing the default well-to-tank (WtT) GHG intensity of fossil LNG.

This document draws attention to the need to address the enforcement of MARPOL Annex V along with the need to consider mechanisms to enhance the enforcement of MARPOL Annex V requirements for the delivery of garbage to port reception facilities.

This document comments on the latest polar fuel concept discussions and highlights ongoing research and a number of recent initiatives focused on reducing Black Carbon emissions from a variety of sources, because of the impact on climate, the environment, communities and on the Arctic.

This document highlights additional considerations to support effective implementation, including the practical implications of BBNJ environmental impact assessments and area-based management tools for shipping regulation, the need to address cumulative impacts and data considerations, and the relevance of Member States’ BBNJ obligations when negotiating within IMO, including in the context of the IMO Net-Zero Framework and related decarbonization measures.

The document provides comments in support of document MEPC 84/14/2, which proposes a new output to support the implementation of the Agreement under the United Nations Convention on the Law of the Sea on the Conservation and Sustainable Use of Marine Biological Diversity of Areas beyond National Jurisdiction (BBNJ Agreement), and offers additional considerations to the proposed terms of reference for the proposed output.

This document proposes that the Working Group recommend the Committee to re-establish the correspondence group on other social and economic sustainability themes/aspects of marine fuels at MEPC 84. It provides potential terms of reference for the same.

This document comments on the GESAMP-Ballast Water Working Group report by sharing a new study on ballast water operations, discharges and their impacts in the Gulf of California (GoC) from future liquefied natural gas (LNG) tanker traffic.

This document comments on term of reference (ToR) 2 contained in the report of the Correspondence Group on Measurement and Verification of Non-CO2 GHG Emissions and Onboard Carbon Capture and Storage (MEPC 84/6/6)

This document highlights the need for a 20-year review of the Particularly Sensitive Sea Areas framework to align with global biodiversity and climate targets and the recently ratified Agreement under the United Nations Convention on the Law of the Sea on the Conservation and Sustainable Use of Marine Biological Diversity of Areas beyond National Jurisdiction.

This document urges the Committee to expedite phase 2 of the review of the carbon-intensity indicator (CII), ensuring that the CII remains at full scope and that future improvements in energy efficiency are guaranteed and in line with the goals of the 2023 IMO GHG Strategy. In particular it calls for a proper discussion of the enforcement options that are available for the CII to ensure this happens.

This document comments on document PPR 13/17/1 and highlights that development of guidelines for managing ammonia effluent generated from ammonia-fuelled ships must account not only for the acute and short-term toxicity of ammonia effluent, but also the wider impacts of reactive nitrogen release, including impacts to marine organisms from chronic, long-term ammonia effluent release, and disturbance to the nitrogen cycle. Prohibiting discharge of ammonia effluent to the marine environment is the management measure best aligned with the precautionary principle.

This document provides comments on the report of the Correspondence Group on Underwater Radiated Noise, supporting the proposed establishment of a working group at this session and providing input on next steps under the proposed terms of reference for this group.

This document shares the findings of a study on the potential underwater radiated noise (URN) impacts of LNG development on marine mammals in the Gulf of California. The report examines the effects of URN from LNG tanker traffic on migratory and resident whales, as well as related impacts on air quality and greenhouse gas (GHG) emissions.

This document highlights the lack of strong signals from the IMO Net-Zero Framework for e-fuels in shipping’s transition.

This document encourages the re-establishment of the correspondence group looking at “other social and economic sustainability themes/aspects of marine fuels” for potential inclusion in the 2024 Guidelines on life cycle GHG intensity of marine fuels (2024 LCA Guidelines).

This document reviews the treatment of indirect land use change (ILUC) within the 2024 Guidelines on life cycle GHG intensity of marine fuels (2024 LCA Guidelines) (resolution MEPC.391(81)).

This document shares the findings of a literature review and summary report on the well-to-tank (WtT) GHG intensity of liquefied natural gas(LNG).

This document presents the rationale for ensuring that the Fifth IMO GHG Study properly captures historic trends and the future potential of improvements in energy efficiency, as distinct from carbon intensity, and further argues for greater transparency and data granularity. It makes suggestions for changes to the draft terms of reference contained in document MEPC 83/7/2 (Secretariat) to those ends.

This document comments on documents MEPC/ES.2/2 and MEPC/ES.2/3 and describes recent international legal developments that Member States must take into account when considering the adoption of the IMO Net-Zero Framework (MEPC/ES.2/2) and the draft work plan to prepare for its entry into force (MEPC/ES.2/3).

Following the report of the thirtieth session of the technical group on the evaluation of safety and pollution hazards of chemicals (ESPH 30) and the approval of interim guidelines for the safety of ships using ammonia as fuel which were approved at MSC 109 in December 2024, the co-sponsors of this submission wish to bring to the Committee’s attention concerns around the use of ammonia (NH3) as an energy carrier, which will increase its transport by ship both as fuel and as cargo.

Dear OSPAR Secretariat, We deeply value the crucial role that OSPAR plays in driving ambitious and science-based regional marine protection efforts. OSPAR’s long-standing commitment to safeguarding marine ecosystems serves as a model for regional cooperation.

This document presents evidence for the high potential of energy efficiency to contribute to the achievement of the 2023 IMO GHG Strategy, and includes new calculations that show this would require a supply-based carbon intensity reduction factor of 55% by 2030, compared to 2008, equivalent to a reduction factor of 41% by 2030 compared to 2019.

This document builds on document ISWG-GHG 17/3 (CSC) to complement the extensive literature review on the well-to-tank (WtT) GHG intensity of liquified natural gas (LNG) imports in the European Union, including information and literature to determine a WtT value for a global default emission factor.

This document presents information on the current literature about tank-to-wake (TtW) nitrous oxide (N2O) emissions from ammonia dual-fuel engines. Recent studies indicate significant variability in N₂O emissions across engine types, operating conditions, and testing methodologies. This document compiles emission data and findings from the most up-to-date laboratory tests and modeling efforts. The summarized results are presented in g N2O/g NH3 units, without normalization of scenario parameters across studies. The co-sponsors propose that the Committee agree to forward these results to the GESAMP-LCA Working Group to be used as part of their mandate to improve the robustness of GHG accounting for ammonia-fueled ships.

Document MEPC 82/7/10 proposed a new approach to address shipping within the triple planetary crisis of climate, biodiversity and pollution, in order to prioritize solutions with co-benefits to address these crises. This document updates the Committee on relevant research and initiatives and recommends establishing an ad hoc working group to make progress on reversing biodiversity loss and reducing pollution which supports climate action and vice versa.

This document provides an overview of issues stemming from the production of food and feed crop-based biofuels spanning from environmental risks to uncertain GHG emission savings and negative consequences on food security. This document highlights historical experiences with biofuels across various jurisdictions. It demonstrates that food and feed-based biofuels cannot be considered sustainable fuel options.

This document examines the implications of incorporating an 𝑓 𝑣𝑜𝑦 correction factor and adopting the adjusted tank-to-wake (TtW) GHG accounting methodology under the Global Fuel Standard (GFS) as proposed in document ISWG-GHG 17/2/7 (Angola et al.)

This document proposes to designate the North-East Atlantic Ocean as an Emission Control Area for sulphur oxides, particulate matter and nitrogen oxides, pursuant to MARPOL Annex VI.

As delegates meet at the International Maritime Organization in London this week, Seas At Risk has released the following infographic to push for a strong Carbon Intensity Indicator (CII), a global greenhouse gas fuel standard and an ambitious levy.

This document provides comments on document MEPC 82/6/1 (Austria et al.) concerning GHG emissions data quality and integrity as a basis for current and future IMO GHG regulatory measures, as well as document MEPC 82/6/17 (Austria et al.) on the possible two-step approach for the review and revision of the short-term measures.

This document comments on documents MEPC 81/16 and MEPC 81/16/Add.1, annex 12 and invites the Working Group to ensure an inclusive, deliberative and transparent process for the further development of the basket of candidate mid-term measures during working groups at ISWG-GHG 17, MEPC 82 and at any other formal and informal sessions that might happen in between.

This document shares the findings of an extensive literature review on the well-to-tank (WtW) GHG intensity of liquified natural gas(LNG) imports to the European Union. The review aggregates data from 130 references from eight LNG-exporting nations, covering 92.6% of EU imports in 2023. The study concludes that the overallWtT GHG intensity of LNG in Europe […]

This document sets out key legal obligations relevant to the international shipping sector as explained by the International Tribunal for the Law of the Sea (ITLOS) in its advisory opinion of 21 May 2024 in case number 31 and puts forward policy recommendations that will assist States in complying with such obligations. Download: ISWG-GHG 17/2/17: […]

This document comments on document MEPC 82/16 (Secretariat) and invites the Committee to consider proposals for ensuring an efficient and streamlined simultaneous enforcement of both the Basel and Hong Kong Conventions. The document outlines why, in accordance with the Vienna Convention on the Law of Treaties and the text of the Basel Convention itself, it […]

This document comments on document MEPC 82/9/2 and summarizes available resources and information to assist the shipping industry with uptake of the Revised guidelines for the reduction of underwater radiated noise from shipping to address adverse impacts on marine life (MEPC.1/Circ.906) and is also submitted as a contribution to the EBP for the Revised Guidelines. […]

This document refers to document MEPC 81/8/1 (FOEI and CSC) submitted to MEPC 81 and deferred to MEPC 82. It provides additional information from a new study which identifies a further source of microplastics from shipping which are entering the ocean and the marine and human food chain. Download: MEPC 82/8/4: Improving the understanding of […]

This document provides comments on the status of actions in the Organization’s Action Plan to address marine plastic litter from ships and information relating to illegal discharges of marine plastic litter. Download: MEPC 82/8/3: IMO’s Action Plan: illegal discharge of marine plastic litter from ships

This document comments on the work concerning plastic pellets and the possible options to facilitate future deliberations at the PPR Sub-Committee proposed by the Secretariat in document MEPC 82/8. It also provides recommendations on the development of amendments to appropriate mandatory instruments to effectively reduce the environmental risk associated with the maritime transport of plastic […]

This document provides new information on planetary tipping points and introduces the concept of positive tipping points or sources of hope, in support of proposals contained in document MEPC 82/7/10 (FOEI et al.). Download: MEPC 82/7/17: Global Tipping Points – Reduction of Greenhouse Gas Emissions from Ships

A sustainable fuel sub target, and associated proposed amendments to documents ISWG-GHG 15/3/1 and ISWG-GHG 16/2/7 This document provides elements to consider in designing the GHG Fuel Standard (GFS), especially in relation to the GHG Fuel Intensity (GFI) targets, the competitiveness of alternative fuels and non-fuel technologies, and what constitutes a sustainable zero and near-zero […]

This document situates the shipping sector within the triple planetary crisis of climate, biodiversity, and pollution, and prioritizes solutions with co-benefits to address these crises. By focusing on these solutions, action on reversing biodiversity loss and reducing pollution can support climate action and vice versa. The co-sponsors recommend an IMO framework be developed, similar to […]

Information and summary of an ongoing process with the Commission for Environmental Cooperation on Exhaust Gas Cleaning Systems. Download: MEPC 82/5/4: Air Pollution Prevention: EGCS pollution in Pacific Canada: investigation of Canada

This submission develops the concept of “polar fuels” discussed at PPR 11. It seeks to set out the fuel characteristics that would distinguish polar fuels from residual fuels and thus lead to fuel-based reductions in ship Black Carbon (BC) emissions if mandated for use in an near the Arctic. It also proposes the drafting of […]

This document sets out a legal analysis on the use of exhaust gas cleaning systems as an alternative compliance mechanism under MARPOL Annex VI from an air quality impact perspective. Download: MEPC 82/5: Legal analysis on exhaust gas cleaning systems as an alternative compliance mechanism under MARPOL Annex VI from an air quality impact perspective

The CII is key to creating more energy efficient ships and cutting emissions in the short-term. Currently, the CII is not realising its full potential! The revision of the CII, due to start at MEPC82 and conclude by 2025, is a key opportunity to bring it up to date with the revised GHG Strategy and […]

The International Convention for the Prevention of Pollution from Ships (MARPOL), the principal international legal agreement regulating the environmental harm done by shipping, is 50 years old this year. In this report, we look into the widely-held assumption that shipping is an environmentally friendly means of transport and take heed of shipping’s contribution to climate change, pollution and biodiversity loss.