Attachment withheld in full under sections 6(a) and 6(b)(ii) of the Act
From:
Michael Allan <[email address]>
Sent:
Wednesday, 8 October 2025 9:19 am
To:
Michaela Manley
Cc:
Scott Gulliver
Subject:
RE: EXTERNAL: RE: Specific proposal for how the IMO registry could be run - with comments on state Administration's role
Thanks for this background Michaela, that is useful to understand. I’d note that EPA doesn’t currently carry out life cycle certification of fuels so this
would be a new function if it came across to us.
From our side, we’d be happy to stay in touch as the IMO discussions 6(b)(ii), 6(a)
Thanks
Michael
From: Michaela Manley <[email address]>
Sent: Monday, 6 October 2025 2:47 pm
To: Michael Allan <[email address]>
Cc: Scott Gulliver <[email address]>
Subject: RE: EXTERNAL: RE: Specific proposal for how the IMO registry could be run - with comments on state Administration's role
Thanks Michael, 6(a), 6(b)(ii)
With these larger ships, we (MNZ) usually delegate functions to our Registered Organisations/ROs, who are the big companies that play a significant role in compliance with
international obligations, and they report up to IMO directly on our behalf. 6(a), 6(b)(ii)
From: Michael Allan <[email address]>
Sent: Monday, 6 October 2025 12:39 pm
To: Michaela Manley <[email address]>
Cc: Scott Gulliver <[email address]>
Subject: EXTERNAL: RE: Specific proposal for how the IMO registry could be run - with comments on state Administration's role
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.
Hi Michaela and Scott
Thanks for this, I don’t have any specific comments on the policy recommendations at this stage. However, I’d be keen to understand what thought has
been given to date on which NZ agency might be best placed to administer the GFI Registry in NZ? Would this sit with MNZ noting the requirements relate
to shipping?
Thanks
Michael
From:
Scott Gulliver <[email address]>
Sent:
Monday, 6 October 2025 4:39 pm
To:
[email address]; [email address]
Subject:
6(b)(ii)
RE: Specific proposal for how the IMO registry could be run - with comments on state Administration's role
Hi Michaela, I’ve glanced through the paper and your notes. Operationalising isn’t really my bread and butter. I was wondering where checking compliance with registering
would sit. Your notes cover the important parts of the paper.
Scott
From: Michaela Manley <[email address]>
Sent: Monday, 6 October 2025 10:49 am
To: Michael Allan <[email address]>
Attachment refused in full under section 18(d) of the Act as it is already publicly available at: https://docs.imo.org/Shared/Download.aspx?did=158261
Cc: Scott Gulliver <[email address]>
Subject: Specific proposal for how the IMO registry could be run - with comments on state Administration's role
Morena both, this one I’m hoping you could cast an eye over the below (and see attached paper). It’s a proposal that includes having State Administrations (this would be the
relevant agencies in NZ) play a role in management of a layer of a ‘two layer’ administrative structure for the Greenhouse gas Fuel Intensity (GFI) registry, instead of having it
all done by the IMO secretariat. I’ve summarised the paper and its proposals and added my initial comments underneath with some highlights.
Thanks if you can outline any concerns/caveats or embellish my thinking..
Michaela
Context
• supports the timely development of the Guidelines on the development, management and operation of the IMO GFI Registry, tentatively scheduled for adoption by
MEPC 85 in 2026.
Problem and evidence
• Discusses a few relevant matters including legal implications if the GFI is a constitutive record of transactions and Unit ownership information, account management,
and the GFI registry’s function as a comprehensive data management and verification system, as well as a reporting and public information tool.
• Also talks about IT security principles being like those of online banking, and that it could function as a compliance tool – this could be by providing national
Administrations with practical tools to oversee obligations under the IMO Net-Zero Framework. Eg in addition to recording holdings and unit submissions, the system
could be designed to facilitate automatic account restrictions – such as temporarily suspending transfers or issuances—when required data or unit submissions are
missing.
Proposes
• Makes a number of specific recommendations in para 17.1 – 17.7.
• IMO GFI Registry should follow established IT best practices in environmental registries, with features such as unique account identifiers, unit traceability, automatic
reporting functions and a level of IT security similar to those used for internet banking. In this context, EDF welcomes and supports the considerations raised by Canada
and the United Kingdom in document MEPC 83/7/25 regarding the further development of the IMO GFI Registry
• emphasizes the importance of building a public website for the IMO GFI Registry that is accessible to all types of users. A lack of transparency and accessibility will
place disproportionate burdens on smaller, less resourced actors, making this both a just and equitable transition issue and one of environmental integrity
• due to the complexity and scale of the registry it will likely require a hybrid administrative structure. As with the European Unionʹs ETS model, EDF recommends that
account verification and participant management be devolved to national administrators, while the IMO Secretariat retains responsibility for carrying out issuances and
the core technical platform. This arrangement is more scalable and ensures national accountability, while safeguarding system consistency and data integrity.
• Asks MEPC to clarify the legal status of the IMO GFI Registry records and recommends that the IMO GFI Registryʹs records have authoritative say on who holds which
units, regardless of any other agreements between parties.
•
Of particular note: proposes that, as the IMO GFI Registry will probably have tens of thousands of accounts, their management will be a significant task, and one that
requires familiarity with many national contexts, EDF recommends that the GFI Registry adopt a two-level administrative structure similar to the one used in the EU
ETS. In the EU ETS Registry,
Member State Administrators oversee opening, closing accounts, updating account information, reviewing the personal documentation of
account and company representatives, and providing initial helpdesk services. The EUʹs Central Administrator, on the other hand, is in charge of maintaining, updating
the IT infrastructure, running the public website, creating reports, executing issuances, and it oversees second level helpdesk services. Thus, account holders receive a
better service from an entity that speaks their language and understands their documents, and at the same time, IMO does not have to build out a large account
management operation
9(2)(j)
From: Michael Allan <[email address]>
Sent: Tuesday, 30 September 2025 4:38 pm
To: Michaela Manley <[email address]>; Scott Gulliver <[email address]>; Ameera Clayton <[email address]>
Cc: [email address]; Bertrand Ngai <[email address]>; Paul Hawkes <[email address]>; Andrew Bell
<[email address]>
Subject: EXTERNAL: RE: Agency input on the IMO net zero ship emissions framework - establishing agency positions on relevant submissions
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Kia ora Michaela
Thanks for looping us in and for sharing the analysis – it looks like you’ve pulled together a significant amount of material.
From the EPA’s side, we’re not so closely involved in the broader climate policy space, as that sits primarily with MfE. Because of this, we don’t have much to add on
the submissions. That said, we’d be interested if you or MFE become aware of any particular matters where there may be any flow-on impacts for our operational
responsibilities in the day to day running of the NZ ETS.
All the best for the upcoming meetings!
Ngā mihi
Michael Allan
Principal Advisor, Emissions Trading Scheme Operations
9(2)(a)
| 9(2)(a)
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From: Michaela Manley <[email address]>
Sent: Tuesday, 30 September 2025 11:36 am
To: Scott Gulliver <[email address]>; Michael Allan <[email address]>; Ameera Clayton <[email address]>
Cc: [email address]; Bertrand Ngai <[email address]>; Paul Hawkes <[email address]>; Andrew Bell
<[email address]>
Subject: Agency input on the IMO net zero ship emissions framework - establishing agency positions on relevant submissions
Kia ora koutou,
I’m getting in touch regarding agency input to the International Maritime Organisation’s Net Zero ship emissions Framework. I’ve previously spoken to a few of you – thanks for
discussions and input to date on understanding interactions with the NZ ETS and some of the thinking around low or zero-emissions fuels.
Paul Hawkes and I are off to the IMO meetings shortly which run from
13-24 October where it is looking likely that the Net Zero framework requirements will be adopted, and
work on the associated guidelines will also get underway. As part of the preparation I’ve been working through various submissions to a working group which will consider
these during the meeting period.
The NZF implementation time frame will be 2027.
MBIE (Bertrand) and I have been looking at a large volume of these meeting submissions relating to fuels, and fuel life cycle certification matters. It looks like there are some
proposals that need assessment against NZ’s wider climate policy settings, which would be good to get MfE and EPA’s views on.
I’ve done initial summaries and draft analysis of the papers with highlighted sections for other agency views (attached) –
please note this is preliminary assessment and not
government policy, just working through where agencies stand on any key concerns or areas of interest so that we go into the meetings informed. You can see in the table
where I have noted initial views (including input to date from MBIE) and MNZ thinking.
It would be ideal to catch up on MfE views before we head over to the IMO, and I wondered if relevant people could take a look at the attached and perhaps we find a time
online to chat either this or next week? I can share specific papers of interest in the table on request.
Thanks very much and please do loop in anyone on your end you feel needs to be involved.
Ngā mihi nui
Michaela
Michaela Manley
(she / her / ia) | Senior Advisor – Regulatory Policy Design
Maritime New Zealand | Wellington
Nō te rere moana Aotearoa
E [email address] | W www.maritimenz.govt.nz
Attachment to email: Tuesday, 30 September 2025 11:36 am
Agenda item, paper, action Summary
MNZ notes and comments
Item 2: Development of new/revision of existing guidelines, provisions, guidance, and other docs for NZF implementation
SWG-GHG 20/2 (India):
6(a), 6(b)(ii), 9(2)(j)
Integrating the principles of
An approach to integrate the principle of common but differentiated
collective obligation to protect
responsibilities and respective capabilities (CBDR-RC) into the
the marine environment and
implementation phase of the IMO Net-Zero Framework. It advocates
their responsibilities into the
for differentiated emission trajectories, progressive revenue
IMO Net-Zero Framework.
generation and a fair and transparent distribution mechanism.
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/1 (India):
Based on the draft Revised MARPOL Annex VI 2025 related to the IMO
Amendments to the SEEMP
Net-Zero Framework, as presented in document
MEPC/ES.2/2
Guidelines based on draft
(Secretariat), this document proposes the amendments to the SEEMP
Revised MARPOL Annex VI 2025 Guidelines (2024 Guidelines for the development of a Ship Energy
6(a), 6(b)(ii), 9(2)(j)
Efficiency Management Plan (SEEMP) (resolution MEPC.395(82)).
ISWG-GHG 20/2/2 (Austria et al outlines key considerations for the continued development of the
including the EC and the UK):
governance structure of the IMO Net-Zero Fund, particularly in
Advancing the governance
relation to the Governing Board.
Agenda item, paper, action Summary MNZ notes and comments
framework for the IMO Net-
The co-sponsors underline the importance of adopting the IMO Net-
6(a), 6(b)(ii), 9(2)(j)
Zero Fund
Zero Fundʹs governing provisions well ahead of the expected
receipt
6(a), 6(b)(ii), 9(2)(j)
of contributions in 2029. The document emphasizes the need for a
resilient and efficient structure that ensures transparency, prevents
conflicts of interest, and supports accountability.
Furthermore, it presents considerations for the operation and
representative composition of the Governing Board.
The co-sponsors propose to request the Secretariat to prepare an
analysis of how the IMO Net-Zero Fund could be established under
the remit of IMO, and welcome contributions by other Member States
and stakeholders.
Agenda item, paper, action Summary MNZ notes and comments
ISWG-GHG 20/2/3 ((Austria et al The reward is a key element in the IMO Net-Zero Framework with the 6(a), 6(b)(ii), 9(2)(j)
including the EC and the UK):
aim of promoting the early uptake of zero and near-zero GHG
Design considerations on the
emission technologies, fuels and/or energy sources (ZNZs). This
reward for the use of zero or
submission is a document describing the main options, limitations and
near-zero GHG emission
considerations for designing an IMO reward laying out four possible
technologies, fuels and/or
concepts. The intention of the co-sponsors is to start considerations
energy sources (ZNZs)
on the design choices, which can inform the drafting of guidelines at a
6(a), 6(b)(ii), 9(2)(j)
later stage, while not ruling out any options or pointing to any specific
solution.
ISWG-GHG 20/2/4 (WSC): The
Comments on the allocation of rewards under regulation 39 of the
importance of ZNZs rewards
IMO Net-Zero Fund along with providing proposals for the
and applying a marginal
development of guidelines on the definition of zero and near-zero
abatement cost methodology to GHG emission technologies, fuels and/or energy sources (ZNZs)
determine such rewards under
rewards and the methodology to determine such rewards.
the IMO Net-Zero Framework
After careful consideration of possible methodologies, it is proposed
that the reward should be based on CO2eq to a reference GFI for
fossil-fuel, while meeting the ZNZ threshold multiplied by a MAC
(marginal abatement cost) price based on the cost to achieve that
reduction. The purpose of the reward is to enable ships to use ZNZ
fuels to compete in the market and to meet the ZNZ thresholds
provided in the IMO Net-Zero Framework. As such, the reward should
substantially narrow or come close to bridging the price gap to enable
commercial operation with ZNZ fuels
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/5 (CESA):
CESA welcomes the political agreement reached on the draft Revised
Proposals and reflections
MARPOL Annex VI 2025, set out in the annex to document
supporting the effective
MEPC/ES.2/2. Furthermore, it emphasizes the importance of its
implementation of the IMO
adoption during 2025 and the detailed, associated implementation
Net-Zero Framework
guidelines as soon as possible thereafter.
In line with the GHG workstreams presented in the draft work plan,
set out in document MEPC/ES.2/3, in this document CESA outlines
various reflections and proposals for the implementation guidelines.
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/6 (Norway):
discusses key principles and elements for the guidelines for the
Proposal for guidelines for the
calculation of the attained annual GHG fuel intensity (GFI). This
calculation of the attained
includes consideration of energy provided from zero-emission energy
annual GHG fuel intensity (GFI)
sources, inclusion of any reward factors in the calculations, and other
key aspects.
6(a), 6(b)(ii), 9(2)(j)
Draft guidelines are included in the annex to this document
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/7 (Norway):
discusses key principles and elements for the guidelines on the
Consideration of options for the definition of zero or near-zero GHG emission technologies, fuels
guidelines on the definition of
and/or energy sources (ZNZs), of ZNZs rewards and the methodology
zero or near-zero GHG emission to determine such rewards. A draft outline of the guidelines is
technologies, fuels and/or
included in the annex to this document
energy sources (ZNZs), of ZNZs
rewards and the methodology
to determine such rewards.
6(a), 6(b)(ii), 9(2)(j)
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/8 (Mexico):
In support of document MEPC 83/7/5, this document emphasises the
Ensuring deployment of ZNZ
importance of designing suitable incentives for the use of zero- or
fuels and technologies in
near-zero emissions technologies, fuels and/or energy sources (ZNZs).
developing countries:
Comments on the Reward
It stresses the need to deploy them swiftly in developing countries,
Guidelines
while maintaining high ambition for GHG emissions reduction by using
ZNZs. It also highlights the importance of avoiding unintended
consequences, such as a shift in emissions to other sectors, changes in
soil use that could negatively impact food security, and restrictions on
the availability of funds for developing countries
ISWG-GHG 20/2/9 (Mexico):
As a comment on the balance of the compliance deficit regulation
Ensuring a just and equitable
approved in the IMO Net-Zero Framework and the use of surplus units
transition in annual GFI
(SUs), this document emphasises the need to limit these compliance
compliance approaches for
mechanisms.
small and medium fleets of
developing countries
They should not divert necessary revenue away from a just and
equitable transition, particularly for small and medium fleets in
6(a), 6(b)(ii), 9(2)(j)
developing countries. It also highlights the importance of preventing
these mechanisms from reinforcing geographical concentration and
market oligopolistic practices during the energy transition in shipping.
Otherwise, they risk deepening existing structural inequalities in the
sector.
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/10
In support of document ISWG-GHG 18/2/6 (Belize et al.), the co-
(Guatemala, Mexico and
sponsors comment on the disbursement purposes outlined in this
Honduras): Governing
option.
provisions of the IMO Net-Zero
The guidelines for these purposes must achieve the goals and
Fund: comments in support of a objectives of the 2023 IMO GHG Strategy, including ensuring a just
just and equitable transition
and equitable transition (JET) that leaves no Member State and no
seafarer behind. T
6(a), 6(b)(ii), 9(2)(j)
he co-sponsors give particular attention to capacity development, the
renewal of small and medium-sized fleets, environmental protection,
the strengthening of maritime administrations, the deployment of
zero or near-zero GHG emission technologies, fuels and/or energy
sources (ZNZs) and the development of National Action Plans (NAPs).
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/11 (RINA):
Drawing on the experience from a voluntary book and claim platform
Considerations for the
for transferring emission reductions from sustainable maritime fuel
development of the GFI Registry use – much like the purpose of the GFI Registry – this document
outlines several lessons learnt that may advance the development of
6(a), 6(b)(ii), 9(2)(j)
the GFI Registry.
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/12 ( Fiji,
proposes a specific composition for the Governing Board of the IMO
Marshall Islands, Palau, Tuvalu
Net-Zero Fund, emphasizing equitable representation that prioritizes
and Vanuatu): Provisions,
small island developing States (SIDS) and least developed countries
guidance and other documents,
(LDCs) while balancing interests and geographic distribution across
as appropriate, for supporting
regions.
the uniform and effective
implementation of the IMO
Drawing on precedents from international climate funds and IMO
Net-Zero Framework – guidance governance structures, and
recent advisory opinions from
in relation to the representation international courts and tribunals, this proposal
ensures the Fund's
of SIDS and LDCs on the
alignment with principles of international environmental law, and
Board(s) of the Fund
advances a just and equitable transition in the decarbonization of
6(a), 6(b)(ii), 9(2)(j)
international shipping.
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/13 ( Fiji,
proposes a detailed timeline for the establishment of the IMO Net-
Kiribati, Marshall Islands, Palau,
Zero Fund, interim arrangements to bridge the period until revenue
Seychelles, Tuvalu and
inflows commence, and core provisions for the Fund's governing
Vanuatu): Development of a
instrument.
timeline, interim arrangements,
and core provisions for the IMO
These proposals are designed to operationalize the Fund promptly,
Net-Zero Fund to ensure a just
ensuring it can support the implementation of the IMO Net-Zero
and equitable transition
Framework under the draft Revised MARPOL Annex VI 2025, while
6(a), 6(b)(ii), 9(2)(j)
prioritizing a just and equitable transition for vulnerable States,
particularly small island developing States (SIDS) and least developed
countries (LDCs)
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/14 ( Fiji,
Marshall Islands, Tuvalu and
Vanuatu): The ZNZs definition
and reward mechanism
6(a), 6(b)(ii), 9(2)(j)
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/15 (ICS and
sets out in its annex 1 suggested draft guidelines on ZNZ rewards and
IBIA): Draft Guidelines on ZNZ
methodology to determine such rewards using an energy-based
rewards and methodology to
approach.
determine such rewards.
To expedite the work to clarify ZNZ rewards and methodology, the
6(a), 6(b)(ii), 9(2)(j)
Working Group is requested to consider annex 1 to this document and
recommend to MEPC 84 a simple, practicable and effective approach
whereby a reward rate is fixed for ships using ZNZs meeting the GFI
threshold in calendar years 2028 to 2032 at a US$ rate per tonne of
CO2eq avoided.
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/16(ICS):
Annex to document MEPC/ES.2/3 (Secretariat) proposes the
Guidelines on the
development of "Guidelines on the determination of the annual IMO
determination of the annual
GFI Registry administration fee (regulation 38.3)" to be paid by ships
IMO GFI Registry administration from 2028.
fee
This annual administration fee will be payable in addition to the GHG
emissions pricing contributions which the vast majority of ships, of
5,000 GT and above, will have to pay to the IMO Net-Zero Fund to
ensure compliance with the regulations of the IMO Net-Zero
Framework.
ICS acknowledges the possible need to support the establishment and
initial operation of the GFI Registry by the Organization in advance of
substantial revenue being received by the IMO Net-Zero Fund in 2029,
but suggests that these guidelines should clarify that GFI Registry
annual administration fee should
be minimal/nominal or zero and
that a cap should be placed on the maximum annual fee at no more
than US$ 500 per ship
ISWG-GHG 20/2/17 (IWSA):
Aims to help clarify the key elements of the IMO Net-Zero Framework
Consistent treatment of wind
as it relates to direct wind propulsion energy, in an effort to align
propulsion in the IMO Net-Zero
those provisions with the core technology and energy pathway
Framework
neutrality principles.
To ensure consistent treatment of wind propulsion, the substantial
losses sustained through the use of fuel oil/alternative fuel energy
pathways should be considered in the
attained GFI calculations so as
to avoid overvaluing these energy sources within the formula and
subsequently undervaluing the wind component.
An approach to address this issue has been outlined in document
MEPC 82/7/9 (ISWA). This submission also brings forward a series of
pertinent issues relating to the same level-playing field principle to be
considered when assessing and applying criteria for the issuance of
IMO Net-Zero Fund reward allocations and the inclusive and balanced
treatment of all energy sources based on their direct and indirect
decarbonisation impact, co-benefits and other merits.
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/18 (Republic of sets out considerations for the governance, oversight arrangements
Korea): Considerations for the
and the Governing Board composition of the IMO Net-Zero Fund,
governance and board
informed by an analysis of other international funds.
composition of the IMO Net-
Zero Fund
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/19 (Republic of proposes considerations to be taken into account, based on technical,
Korea): Considerations of the
administrative, and financial realities, in developing guidelines on the
annual administrative fee for
annual administrative fee of the IMO GFI Registry, in accordance with
the IMO GFI Registry
draft regulation 38.3 of the IMO Net-Zero Framework and the
6(a), 6(b)(ii), 9(2)(j)
Secretariat's draft work plan
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/20: (Norway
This document aims to facilitate institutional participation by ships in
and Republic of Korea):
voluntary emissions reductions under the IMO mid-term measures. by
Expanding the IMO Net-Zero
explicitly stating in the guidelines that the voluntary cancellation of
Fund through incentive
surplus units (SUs) may be used for decarbonization initiatives led by
mechanisms for ships that
relevant industries beyond IMO regulations.
voluntarily cancel SUs
6(a), 6(b)(ii), 9(2)(j)
Ultimately, this approach is intended to contribute to strengthening
the financial resources of the IMO Net-Zero Fund
Agenda item, paper, action Summary 6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/2 (EDF):
provides recommendations to support the Committeeʹs work on
Ensuring transparency, integrity developing the Guidelines for the IMO GFI Registry, as referenced by
and usability: key
draft regulation 38 of the Revised MARPOL Annex VI and the draft
considerations for the
work plan to prepare for the entry into force of the IMO Net-Zero
development and operation of
Framework.
the IMO GFI Registry
6(a), 6(b)(ii), 9(2)(j)
Building on established best practices for environmental registries,
the document outlines key considerations for transparency,
governance, account management, compliance functions and IT
security. By clarifying the IMO GFI Registryʹs role as the authoritative
record of unit ownership and proposing a scalable administrative
structure, these recommendations aim to ensure the IMO GFI
Registryʹs effectiveness, integrity and usability, thereby strengthening
the overall compliance architecture.
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/22 (RoK):
outlines key elements for the design of a reward mechanism for ZNZs
Further considerations on the
under the IMO Net-Zero Framework. It aims to present practical policy
development of guidelines
considerations that should be taken into account in the development
under the IMO Net-Zero
of relevant IMO guidelines by 1 March 2027.
Framework for ZNZs
ISWG-GHG 20/2/23 (RoK): The
Re the development of guidelines on the certification of sustainable
need for preliminary
fuels is under consideration. Within this context, the policy
exploration on the policy
acceptability of chain of custody (CoC) approaches, in particular the
acceptability of chain of custody book-and-claim model, has been identified as an issue requiring
(CoC) approaches under the
further examination.
IMO LCA Framework
This document proposes that, given the growing demand from
industry and the practical constraints of global supply chains for
sustainable marine fuels, a preliminary policy exploration should be
undertaken to enhance understanding and provide a basis for future
regulatory consideration of book-andclaim approaches.
ISWG-GHG 20/2/24 (IPIECA,
Discusses the urgent need to clarify the chain of custody models for
RINA, IBIA): Chain of custody
fuel certification to support the implementation of the IMO Net-Zero
models for IMO Net-Zero
Framework.
Framework implementation
6(a), 6(b)(ii), 9(2)(j)
It highlights three main approaches: physical segregation, mass
balance, and book-and-claim, and emphasizes the importance of
aligning these models with international standards. The document
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
also includes a case study on bio-LNG to illustrate the necessity of a
mass balance approach.
ISWG 20/2/25 (Pacific
Californiaʹs Low Carbon Fuel Standard (LCFS) is a 14-year programme
Environment): Experience of
designed to lower the stateʹs transportation fuelsʹ carbon intensity
Californiaʹs Low Carbon Fuel
through issuance of fuel credits and deficits based on a yearly
Standard and credit
threshold. It generates approximately $3 billion per annum and
mechanisms
provides key incentives for alternative fuel providers to reduce GHG
6(a), 6(b)(ii), 9(2)(j)
emissions.
The programme utilizes a system of accounting for "avoided
methane" emissions in addition to crediting avoided fossil fuel
volumes; this in effect acts as a multiplier that increases the value of
specific fuels produced from dairy methane, specifically livestock
biomethane. This fuel type averages a negative carbon intensity score
much lower than other credited fuels thanks to this system of
inaccurate emissions accounting.
This document provides further information on the outcomes of the
programme design with a credit multiplier (in effect through the
double-counted avoided emission credits) and outcomes of a similar
framework under the LCFS and encourages exploration of other
market design components first.
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/26 (IPIECA):
It highlights the importance of certification for GHG emission factors
Developing fuel certification
and sustainability aspects of fuels, addressing potential barriers for
guidelines to support the IMO
investments in lower GHG emissions technologies.
Net-Zero Framework
This document also recommends
interim solutions to ensure
compliance with IMO certification requirements until the recognition
of Sustainable Fuels Certification Schemes (SFCS) is achieved.
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/27 (IMarEST):
Provisions, guidance and other
Dicusses various evidence that is relevant to the development of
documents, as appropriate, for
guidelines for ZNZs definition and ZNZs reward mechanism. Draws on
supporting the uniform and
both analysis used in IMO's Comprehensive impact assessment (CIA)
effective implementation of the of the basket of candidate GHG reduction mid-term measures
IMO Net-Zero Framework –
(particularly Task 2 – Impacts on the fleet), the data IMO is collecting
ZNZs definitions
on fuel prices, and wider literature and analysis used for the work on
6(a), 6(b)(ii), 9(2)(j)
the IMO Net-Zero Framework.
Key findings are that effective ZNZs definition and reward are crucial
enablers of the 2023 IMO GHG Strategy objective to "effectively
promote shipping's energy transition". To accomplish that objective
efficiently, the findings recommend that a definition of rewarded ZNZs
should be given to specific feedstocks and production pathways, as
linked to the 2024 IMO LCA Guidelines.
To ensure an effective ZNZ reward mechanism, although a "flat rate"
reward has been the primary focus of considerations to date, an
auction mechanism would offer several advantages to this
mechanism, not least the ability to limit the reward liability for the
IMO Net-Zero Fund and to use the auction to discover the prices for
reward, with the potential to also improve cost-effectiveness (relative
to a flat rate reward).
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/28 (CLIA): The
highlights the critical role of Mass Balance and Book and Claim chain
importance of enabling verified
of custody models in enabling the global fleet to successfully
GHG reductions through Mass
decarbonize in line with the 2023 IMO GHG Strategy
Balance and Book and Claim
chain of custody models
ISWG-GHG 20/2/29 ( Norway,
• proposes the operationalization of the Fuel Life Cycle Label
IPIECA, RINA, IBIA and WSC):
(FLL) within the IMO Net-Zero Framework and its integration
Proposal for operationalizing
into the GFI Registry. The proposal aims to streamline the
the fuel life cycle label in the
certification and reporting processes for marine fuels,
Agenda item, paper, action Summary MNZ notes and comments
context of the IMO Net-Zero
ensuring traceability and accuracy in GHG emissions data. The 6(a), 6(b)(ii), 9(2)(j)
framework
FLL will cover the well-to-tank (WtT) portion, while the tank-
to-wake (TtW) emissions will be verified by Administrations
and recognized organizations. The document outlines the
need for amendments to the LCA Guidelines and the
development of a standardized template for the FLL. It also
addresses the treatment of last-mile emissions and the
assurance process for non-fuel energy source
Agenda item, paper, action Summary 6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/2/30 (Brazil,
provides draft guidelines on requirements and procedures for the
Canada, Norway, Republic of
recognition of SFCS and reporting of certification activities. The
Singapore, United Kingdom,
guidelines aim to establish a robust certification system for
IPIECA, RINA and WSC): Draft
sustainable marine fuels, ensuring transparency, traceability, and
guidelines on requirements and
environmental integrity.
procedures for the recognition
of Sustainable Fuel Certification
Key elements include the system description, core principles,
Schemes and reporting of
requirements for recognition, application procedures, and annual
certification activities
reporting requirements. The guidelines are designed to align with the
6(a), 6(b)(ii), 9(2)(j)
IMO Life Cycle Assessment (LCA) framework and support the
implementation of the IMO Net-Zero Framework.
Further work is needed to finalize specific elements, including
methodological guidance on LCA, chain of custody models, and
eligibility requirements for sustainable marine fuels. The cosponsors
invite guidance on how to further progress this matter.
ISWG-GHG 20/2/31 (CSC):
Highlights the lack of strong signals from the IMO Net-Zero
Amplifying the policy signal for
Framework for e-fuels in shipping's transition.
the production and uptake of e-
This is demonstrated through modelling potential future fuel uptake
fuels through the IMO Net-Zero
behaviour based on compliance-cost optimization of the global fleet
Framework Guidelines
and insights from e-fuel producers.
To address this gap, this document explores the introduction of an e-
fuels multiplier within the relevant guidelines as a strategic tool to
amplify the IMO Net-Zero Framework's signals and support the timely
scale-up of e-fuels production and use. The document models the
potential impact of this e-fuels multiplier and sets out several
advantages.
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
6(a), 6(b)(ii), 9(2)(j)
Item 3: Further development of the LCA framework
ISWG-GHG 20/3 (Marshall
Islands and Mexico): Comments Provides a series of comments regarding the sustainability criteria in
on the sustainability criteria in
the LCA Guidelines, including the need to consider the land rights of
the LCA Guidelines to safeguard Indigenous and rural communities in relation to indirect land-use
social and environmental
change (ILUC).
integrity
Also calls for robust carbon emission tracking and measures to
6(a), 6(b)(ii), 9(2)(j)
mitigate adverse impacts on biodiversity, water availability and food
security.
Also emphasises the importance of incorporating a qualitative focus,
supported by national documentation, to prevent disproportionate
technical and economic burdens on producers in developing States.
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/3/1 (Australia,
submission aims to support a globally consistent application of
Austria, Belgium, Bulgaria,
sustainability themes/aspects of the LCA Guidelines, focusing on
Canada, Croatia, Cyprus,
requirements of Sustainable Fuels Certification Scheme (SFCS), and
Czechia, Denmark, Estonia,
provides one illustrative theme/aspect, namely water quality and
Finland, France, Germany,
availability.
Greece, Hungary, Ireland, Italy,
Latvia, Lithuania, Luxembourg,
To minimize duplications and maximize synergies while preserving the
Malta, Netherlands (Kingdom of international shipping sector's specificities, the co-sponsors consider
Agenda item, paper, action Summary MNZ notes and comments
the), Norway, Poland, Portugal,
that building on the common elements shared with existing
6(a), 6(b)(ii), 9(2)(j)
Romania, Slovakia, Slovenia,
sustainability certification systems is expected to result in the lowest
South Africa, Spain, Sweden,
additional administrative burden. The document outlines a
United Kingdom, European
transparent working method that avoids ambiguities, supports
Commission, ICS, IPIECA, RINA,
robustness, credibility and accountability of the certified fuels claimed
IBIA, WSC and SGMF)
as contributing to the IMO Net-Zero Framework while ensuring the
Supporting the uniform
required adaptability to widely varying sustainability themes/aspects
implementation of
sustainability themes in the
2024 LCA Guidelines: water as
an Illustrative case
ISWG-GHG 20/3/2 (Norway):
Describes a novel fuel pathway for LNG (natural gas feedstock) with
Proposed amendment to
the use of carbon capture and storage (CCS) in the upstream process.
appendix 1 of the 2024 LCA
The document also proposes a new fuel pathway code to be included
Guidelines and proposed new
in appendix 1 of the 2024 LCA Guidelines to accommodate the
fuel pathway for LNG with the
verification and certification of the actual well-to tank (WtT) emission
use of carbon capture and
factors of the fuel.
Agenda item, paper, action Summary MNZ notes and comments
storage (CCS) in the upstream
6(a), 6(b)(ii), 9(2)(j)
process
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/3/3 ( ICS,
presents recommendations to refine the 2024 Guidelines on life cycle
INTERTANKO, SIGTTO, CLIA,
GHG intensity of marine fuels (2024 LCA Guidelines) (resolution
IHMA and SGMF):
MEPC.391(81)), addressing key methodological challenges. It calls for
Amendments to the 2024 LCA
enhanced data quality standards, ensuring studies used to calculate
Guidelines and implementation
default GHG emission factors are relevant, complete, consistent,
of the IMO Net-Zero
reliable, transparent, and aligned with ISO 14040, ISO 14044:2006,
Framework: proposals for
and ISO/TS 14071. The current approach of selecting the upper
enhanced emission factor
emission value as default should be replaced with a scientifically
methodology
representative method, such as a weighted average, to ensure
6(a), 6(b)(ii), 9(2)(j)
credible, up-to-date factors across the industry. The document also
proposes a biennial review to update default emission factors while
avoiding retroactive impacts on the GFI calculations. For purely fossil
fuel pathways lacking robust data, temporary use of credible
alternative data sets is recommended until sufficient representative
studies exist. Standardized methodologies for calculating emission
credits should be adopted, following approaches like Directive (EU)
2018/2001 (RED II). Finally, specific fuel pathway variants for ships
using part of their cargo as fuel are recommended to reflect their
unique well-to-tank (WtT) emissions.
ISWG-GHG 20/3/4 (IPIECA and
proposes amendments to the 2024 LCA Guidelines to 1) clarify
SGMF): Proposal to modify the
inclusion of the International Organization for Standardization (ISO)
Agenda item, paper, action Summary MNZ notes and comments
2024 Guidelines on Life Cycle
life cycle assessment (LCA) standards when calculating actual well-to- 6(a), 6(b)(ii), 9(2)(j)
GHG Intensity of Marine Fuels
tank (WtT) emission factors; and 2) expand power purchase
(2024 LCA Guidelines)
agreements (PPAs) for the well-to-wake (WtW) marine fuel life cycle.
ISWG-GHG 20/3/5: (IPIECA and
proposes the incorporation of underground carbon capture and
RINA ( Recommendations for
storage (CCS) provisions into the 2024 LCA Guidelines to ensure the
developing a methodological
environmentally safe and secure long-term containment of carbon
guidance for life cycle GHG
dioxide via geological storage.
assessment framework on
carbon capture and storage)
These provisions aim to support the consistent application of CCS
6(a), 6(b)(ii), 9(2)(j)
technology for marine fuels regulated under the purview of IMO. The
document also invites consideration for additional guidance to be
developed by the Organization as deemed appropriate.
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/3/6 (Malaysia):
proposes the recognition of pre-combustion captured inherent CO2
Low-carbon e-methanol as a
arising from natural gas processing, as a carbon neutral feedstock for
key decarbonization lever
the production of low-carbon e-fuels, i.e. e-methanol. At the same
time, it effectively translates the CO2 emission credit from pre-
combustion captured carbon to onboard fuel users accordingly. This
document also looks into low-carbon e-methanol fuel serving as a
large-scale and immediate GHG reductions potential solution for the
maritime industry.
ISWG-GHG 20/3/7 (CSC): Re-
encourages the re-establishment of the correspondence group
establishment of the
looking at "other social and economic sustainability themes/aspects of
correspondence group on other marine fuels" for potential inclusion in the 2024 Guidelines on life
social and economic
cycle GHG intensity of marine fuels (2024 LCA Guidelines).
sustainability aspects of marine
fuels to safeguard net-zero
By focusing on LNG, bio-LNG, and e-LNG as an example in this
goals
document, it is evident that without a comprehensive assessment of
6(a), 6(b)(ii), 9(2)(j)
existing and emerging fuels, IMO's net-zero goals and the
implementation of the IMO Net-Zero Framework could be under
threat.
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/3/8 ( WWF,
reviews the treatment of indirect land use change (ILUC) within the
Pacific Environment, CSC and
2024 Guidelines on life cycle GHG intensity of marine fuels (2024 LCA
EDF): Developing a quantitative Guidelines) (resolution MEPC.391(81)).
risk-based approach to manage
indirect land use change
Drawing on examples from other regulatory frameworks such as the
emissions under the IMO Net-
EU's Renewable Energy Directive (RED) and ICAO's CORSIA
Zero Framework
programme, this document highlights the significant risk that high
ILUC emissions from food and feed-based marine fuels could
undermine intended GHG savings under the IMO Net-Zero
Framework.
Argues that a purely qualitative approach cannot prevent the use of
high-ILUC risk biofuels under the IMO Net-Zero Framework.
Consequently, this document proposes that the Working Group
encourage interested Member States and international organizations
to provide concrete proposals to MEPC 84 on: 1) how to incorporate
quantitative metrics into a risk-based ILUC framework in the 2024 LCA
Guidelines; and 2) how to safeguard against the use of fuels made
from identified high-ILUC risk feedstocks to ensure the environmental
integrity of the IMO Net-Zero Framework.
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/3/9
Context
Problem and evidence
Proposes
Comments/questions/policy considerations
ISWG-GHG 20/3/10
Context
Problem and evidence
Proposes
Comments/questions/policy considerations
ISWG-GHG 20/3/11 ( Argentina, presents an updated review of the scientific literature, providing
Context
Brazil, Indonesia and Malaysia): evidence that sustainable biofuel production can coexist with
A science-based assessment of
sustainable food systems and environmental protection. It highlights
Problem and evidence
the contribution of sustainable
techniques that minimize the risk of land use change and can
biofuel in developing countries
contribute to broader benefits, including improved energy access,
Proposes
emissions reductions, enhanced soil quality, strengthened agricultural 6(a), 6(b)(ii), 9(2)(j)
infrastructure and modernization, and rural development – all of
which support food security in emerging economies. This document
outlines the necessary conditions for expanding biofuels supply in
developing countries. Effective and well-established certification
schemes, traceability mechanisms, and supportive public policies have
been critical in controlling deforestation and promoting sustainable
agricultural practices.
ISWG-GHG 20/3/12
Context
Problem and evidence
Proposes
Comments/questions/policy considerations
ISWG-GHG 20/INF.2
Context
Problem and evidence
Proposes
Comments/questions/policy considerations
ISWG-GHG 20/INF.3 (RINA):
contains an overview of a low ILUC risk certification approach to
Context
Applying a low ILUC risk
IMO's global fuel standard developed by the Roundtable on
certification approach to IMO's
Sustainable Biomaterials (RSB).
Problem and evidence
global fuel standard
Proposes
Agenda item, paper, action Summary MNZ notes and comments
6(a), 6(b)(ii), 9(2)(j)
6(a), 6(b)(ii), 9(2)(j)
ISWG-GHG 20/INF.4 (RINA):
Applying a sustainability approach to certification for IMOʹs global fuel
Context
applying a sustainability
standard
approach to certification for
Problem and evidence
IMOʹs global fuel standard
Proposes
6(a), 6(b)(ii), 9(2)(j)
Context
Problem and evidence
Proposes
Comments/questions/policy considerations
•
Item 4: 5th IMO GHG study Terms of Reference
Context
Problem and evidence
Proposes
Comments/questions/policy considerations
•
Context
Problem and evidence
Proposes
Comments/questions/policy considerations
Item 5: Any other business
Context
Agenda item, paper, action Summary MNZ notes and comments
Problem and evidence
Proposes
Comments/questions/policy considerations
