OC260287
12 June 2026
Spencer Jones
[FYI request #34431 email]
Tēnā koe Spencer,
I refer to your email dated 8 April 2026, requesting the following under the Official Information Act
1982 (the Act):
“Copies of any documents held from 1 January 2015 to present that:
1. Assess or analyse the atmospheric impacts of shipping emissions, including:
•
sulphur dioxide (SO₂
)
•
sulphate aerosols
•
particulate matter
2. Evaluate or discuss:
•
aerosol–cloud interactions
•
cloud condensation nuclei (CCN)
•
cloud formation or reflectivity
•
rainfall or precipitation effects
3. Relate to implementation or impacts of:
•
MARPOL Annex VI
•
Marine Protection Rules Part 199
4. Include any modelling, monitoring, or scientific assessments of:
•
coastal air quality near ports
•
secondary sulphate formation
•
observable “ship track” phenomena”
On 29 May 2026 we issued you a decision letter and partial response in relation to your request
and advised we intended to release the other two documents to you in part, but that further
consultations were required on the papers before a decision could be communicated to you. We
advised we would provide this to you no later than 12 June 2026.
We have now completed the necessary consultations to make a decision on the remaining two
documents in scope of your request. The document schedule attached as Annex 1 outlines how
the have been treated under the Act. Certain information is withheld under the following sections of
the Act:
6(a)
as release would be likely to prejudice the security or defence of New Zealand or
the international relations of the New Zealand Government
9(2)(a)
to protect the privacy of natural persons
transport.govt.nz | hei-arataki.nz
HEAD OFFICE: PO Box 3175, Wellington 6140, New Zealand. PH: +64 4 439 9000
AUCKLAND OFFICE: NZ Government Auckland Policy Office, PO Box 106483, Auckland 1143, New Zealand. PH: +64 4 439 9000
9(2)(ba)(i) to protect information which is subject to an obligation of confidence or which any
person has been or could be compelled to provide under the authority of any
enactment, where the making available of the information would be likely to
prejudice the supply of similar information, or information from the same source,
and it is in the public interest that such information should continue to be supplied
9(2)(f)(iv)
to maintain the constitutional conventions for the time being which protect the
confidentiality of advice tendered by Ministers of the Crown and officials
9(2)(g)(i)
to maintain the effective conduct of public affairs through the free and frank
expression of opinions by or between or to Ministers of the Crown or members of
an organisation or officers and employees of any public service agency or
organisation in the course of their duty
9(2)(h)
to maintain legal professional privilege
9(2)(j)
to enable a Minister of the Crown or any public service agency or organisation
holding the information to carry on, without prejudice or disadvantage,
negotiations (including commercial and industrial negotiations)
With regard to the information that has been withheld under section 9 of the Act, I am satisfied that
the reasons for withholding the information at this time are not outweighed by public interest
considerations that would make it desirable to make the information available.
If you would like to discuss this decision with us, please do not hesitate to contact us at
[MOT request email].
You have the right to seek an investigation and review of this response by the Ombudsman, in
accordance with section 28(3) of the Act. The relevant details can be found on the Ombudsman’s
websit
e www.ombudsman.parliament.nz.
The Ministry publishes our Of icial Information Act responses and the information contained in our
reply to you may be published on the Ministry’s website. Before publishing we wil remove any
personal or identifiable information.
Nāku noa, nā
Mary Craythorne
Manager, Environment
Annex 1: Document Schedule
Doc Reference
#
number
Date
Document title
Decision on request
8. OC250051 12/03/2025 Briefing: International Maritime
Release with some information withheld under
Organisation: Approach to Upcoming
sections 6(a), 9(2)(a), 9(2)(f)(iv) and 9(2)(j).
Decarbonisation Negotiations
Annex 2 was treated in Document 7 in our partial
response of 29 May 2026.
9. OC250591 26/09/2025 Briefing: International Maritime
Release with some information withheld under
Organisation: Seeking Decisions on
sections 6(a), 9(2)(a), 9(2)(ba)(i), 9(2)(f)(iv),
Net-Zero Framework Negotiations
9(2)(g)(i), 9(2)(h) and 9(2)(j).
Annex 3 was treated above in Document 7 in our
partial response of 29 May 2026.
Document 8
12 March 2025
OC250051
Hon James Meager
Action required by:
Associate Minister of Transport
Tuesday, 18 March 2025
Relevant Ministers to consider by:
Tuesday, 25 March 2025
INTERNATIONAL MARITIME ORGANIZATION: APPROACH TO UPCOMING
DECARBONISATION NEGOTIATIONS
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Purpose
THE
The International Maritime Organization (IMO) is currently negotiating measures to lower the
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emissions from international shipping. This briefing outlines our proposed approach to these
negotiations using the Cabinet mandate agreed in September 2024.
Key points
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•
IMO member states are negotiating measures to meet the IMO targets agreed in the 2023
Strategy on the Reduction of Greenhouse Gas (GHG) Emissions from Ships. States have
agreed that the measures will include a global fuel standard (likely a sinking lid on the
emissions intensity of maritime fuels), and an emissions pricing mechanism – which could be
a compliance credit trading scheme or a per-tonne of emissions levy.
•
We propose to approach these negotiations utilising the existing negotiating mandate
INFORMATION
approved by Cabinet (CBC-24-MIN-0088, attached). This mandate gives the Ministers of
Trade, Climate Change, Foreign Affairs and yourself the power to make decisions on
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negotiations that are within the mandate’s policy settings.
•
An agreement on the global fuel standard is close, and we do not require Ministerial
direction on progressing this. Member states’ positions around the emissions pricing
mechanism are less clear, and this briefing seeks Ministerial direction on how to approach
the April negotiations.
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•
s 9(2)(j)
•
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9(2)(j)
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s 9(2)(f)(iv)
If a pricing mechanism is agreed to in April, states will meet again in October 2025
We will provide you with advice prior to this on the forecasted impact on
New Zealand’s economy.
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Recommendations
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We recommend you:
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s 9(2)(j)
1
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Yes / No
3
Yes / No
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4
agree to forward this briefing to the Ministers of Trade, Foreign Affairs, and Climate
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Change for their consideration by Tuesday 18 March 2025 and to seek their feedback by
Tuesday 25 March 2025, to ensure officials receive guidance prior to meetings beginning
30 March.
Yes / No
5
agree to forward this briefing to the Prime Minister and Minister of Finance for their
information.
Yes / No
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THE
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APPROACH TO UPCOMING DECARBONISATION NEGOTIATIONS
New Zealand and The International Maritime Organization (IMO)’s Strategy on the Reduction of
Greenhouse Gas Emissions (GHG) from ships
1
The International Maritime Organization (IMO) is the United Nation’s (UN) specialised agency
with responsibility for the safety and security of shipping and the prevention of marine and
atmospheric pollution by ships. International shipping transports more than 80 percent of
global trade to peoples and communities all over the world.
2
New Zealand and other IMO member states are negotiating measures to meet the IMO
targets agreed in the 2023 Strategy on the Reduction of GHG Emissions from Ships. The
Strategy targets net-zero GHG emissions for international shipping by 2050. It sets 2030
progress targets to reduce total emissions by a minimum of 20%; carbon intensity by at least
40%, and to achieve at least 5% uptake of zero emissions fuels. The measures will be finalised
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in 2025 with entry into force by 2027.
s 9(2)(j)
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3
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4
The Strategy aims to enhance the IMO’s contribution to global decarbonisation efforts like
the Paris Agreement. It also emphasises addressing the potential impacts of these efforts on
UNDER
states and recognising the importance of shipping in supporting global trade.
Agreement to date and focus of upcoming negotiations in April
5
All member states, including New Zealand, agreed in October 2023 that the measures will
include a global fuel intensity measure1. Negotiations in early April will focus on finalising the
fuel intensity measure and an emissions pricing mechanism.
Agreement on the fuel intensity measure is close
INFORMATION
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6
A consensus is emerging over the fuel intensity measure and the complex mechanisms by
which it is defined, therefore negotiations around a global fuel intensity measure do not
require additional Ministerial decisions.
7
There may be disagreements at the April negotiations about whether this fuel intensity
measure should also feature financial incentives and disincentives. For example, where low
or zero emissions shipping is financially rewarded by penalising those above an agreed level
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of emissions.
s 9(2)(j)
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1 Expected to set a sinking lid on the emissions intensity of maritime fuels and potentially create a scheme
where shipping operators are rewarded for using low or zero emissions fuel, while financially penalising those
emitting above an allowed level.
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Agreement on an emissions pricing mechanism is less clear, and we are seeking your direction
9
An emissions pricing mechanism is more contentious than the fuel intensity measure and
other member state’s positions are evolving2.
10
Therefore, we require guidance from Ministers on what New Zealand’s position should be
ahead of the negotiations in April.
s 9(2)(j)
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THE
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A lack of an overarching emissions pricing mechanism could lead to businesses having to expensively
comply with multiple individual mechanisms
15
We note that having an agreed IMO emissions pricing mechanism would avoid the risk of
New Zealand businesses needing to comply with an increasing number of individual country
regimes.4
INFORMATION
Next steps and further advice to Ministers
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16
If consensus is reached on an emissions pricing mechanism, we will have until October 2025
to consider it and raise any concerns on how it may disproportionately impact New Zealand.
We will provide you with further advice, including a briefing on the forecasted impacts on
New Zealand’s economy.
17
If no progress is made in April, negotiations will likely be shelved until October. It is possible
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that additional intersessional negotiations may be established.
s 6(a)
4 New Zealand exporters already face charges for international shipping emissions on goods exported to the
EU. s 6(a)
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ANNEX 2 – CABINET MINUTE ON NEGOTIATING MANDATE
Annex 2 is treated in document 7 of our partial response of 29 May 2026 and was refused as it is publicly
available on the Ministry's website here: https://www.transport.govt.nz/assets/Uploads/Proactive-release-IMO-
Minute-of-Decision-and-Cabinet-Report.pdf
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s 9(2)(j)
•
s 9(2)(h)
Recommendations
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1 s 9(2)(j)
THE
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2
Yes / No
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3
agree to forward this briefing to the Prime Minister and Minister of Finance for their
information
Yes / No
INFORMATION
Nick Paterson
Manager,
Alice Revell
RELEASED
Environment, Acting Deputy
Hon James
Ministry of
Secretary,
Rt Hon
Hon Todd
Hon Simon
Meager
Transport
Winston Peters McClay
Watts
MLG, Ministry Minister of
Minister for
of Foreign
Associate
Foreign Affairs Trade and
Minister of
Affairs and
Minister of
Investment
Climate
Trade
Change
Transport
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26/09/2025
26 / 09 / 2025
..... / ...... / ...... ..... / ...... / ...... ..... / ...... /
..... / ...... /
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s 9(2)(f)(iv)
15.
s 9(2)(f)(iv)
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THE
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Industry is generally supportive of the Net-Zero Framework
19.
The New Zealand Shipping Federation (NZSF) are supportive of the Framework but share
global industry concerns about the availability of low or zero emissions fuel. The Framework
should over time significantly increase the availability of these fuels. Financial incentives
placed on the market will spur considerable development of alternative fuels to help shipping
INFORMATION
operators avoid penalties.
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20.
Representatives from Maersk (one of the largest shipping companies in the world) have
informed us that industry orders for new ships are already switching to low or zero carbon
based engines.
21.
Zespri have informed officials that they are supportive of the Net-Zero Framework. In their
view, a single, global framework that applies financial incentives and penalties to shipping
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emissions is easier to comply with than the possibility of multiple, different systems.
22.
The Council of Cargo Owners which is comprised of largescale exporters (including Zespri)
have also indicated to us support for the Framework.
1 This analysis is based on a model where the shipping fleet slowly decarbonises over time in response to the
Net-Zero Framework, as wel as reflecting that ships do not always carry the maximum possible cargo (which
corresponds to lower fuel burn).
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23. s 9(2)(ba)(i)
note that New Zealand is generally served by
older, less efficient vessels, which will be relatively penalised in comparison. This issue is
longstanding (New Zealand port infrastructure cannot serve the significantly larger and more
environmentally friendly ships coming on stream) and not directly a result of the Framework.
24.
s 9(2)(ba)(i)
acknowledges that a single, global framework is preferable to a situation in which
multiple, regional frameworks develop.
s 6(a)
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s 6(a)
31.
s 9(2)(j)
Additional matters and next steps
s 9(2)(f)(iv)
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Additional considerations – impacts on ferries and inspections
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36.
Current and future Interislander ferries are flagged to New Zealand and at times may be
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required to sail overseas for specialised repairs. During these voyages they will be subject to
the Net-Zero Framework, but the rarity of such trips means the overall cost impact will be
low.
37. s 9(2)(f)(iv)
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38.
Without implementing the Net-Zero Framework, Maritime New Zealand would not be able to
undertake similar checks on visiting ships. While New Zealand currently receives relatively
2New Zealand’s FTAs with the EU and the UK both include references to committing to support the
development and adoption of ambitious and effective GHG emissions reductions measures by the IMO.
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older ships in terms of the global fleet, this could increase if we do not implement the Net-
Zero Framework.
s 9(2)(h)
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Negotiations are likely to require a vote
s 9(2)(j)
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Next steps – a programme of implementation
44.
Following conclusion of negotiations, IMO member states will have until February 2027 to
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implement the Net-Zero Framework. This will progress as a package of rules and regulatory
changes. Relevant Ministers will be briefed as and when appropriate. Further details on
implementation are attached to this briefing in an annex.
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IN-CONFIDENCE
IN CONFIDENCE
ANNEX 1 – OUTLINE OF IMPLEMENTATION REQUIREMENTS AND DRAFT
TIMELINE
Key implementation tasks
Staged process requiring 8- 12 months overall (policy to rules in force), mapping out the points at
which Ministerial input will be required, along with key tasks.
Implementation calendar
Task
Indication of decisions
Indicative dates
needed
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Policy assessment of any
Direction from Ministers on
At MEPC ES and ISWG-GHG-20,
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discretionary measures or
any key policy or discretionary and in the immediate period after
flexibility mechanisms in the
matters for NZ
(October – December 2025)
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IMO framework details.
Policy development for any
January – April 2026
discretionary matters for
implementation
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Interagency consultation (eg
with MBIE on any fuel
regulation elements)
Policy decisions and
Testing of final policy
April – May 2026
rules/regulations and drafting recommendations with
Ministers
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Agreement to consult on
Decision from Minister/s to
June – July 2026
implementation rules package release consultation
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Public consultation
Feedback on proposals
August - September 2026
Rules finalisation
October 2026
Signing of rules –
Relevant Minister signs rules
November 2026
and agrees in-force date
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Rules in force
February 2027
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ANNEX 3 – CABINET MINUTE ON NEGOTIATING MANDATE
Annex 3 was treated in document 7 of our partial response of 29 May 2026 and was refused as it is publicly
available on the Ministry's website here: https://www.transport.govt.nz/assets/Uploads/Proactive-release-IMO-
Minute-of-Decision-and-Cabinet-Report.pdf
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Document Outline
