Herbert Briefing: MEPC ES2 Meeting 2025

International Maritime Organization - Marine Environment Protection Committee (MEPC)

MEPC ES2 Meeting Brief

Background Leading Up to the Meeting

The IMO’s Net Zero Framework (NZF) is a regulation developed over four years to reduce greenhouse gas (GHG) emissions from international maritime shipping to net-zero by 2050, using a combination of technical and economic measures. The NZF aligns with the Paris Accord targets and the IMO’s revised GHG reduction goals and strategy, as agreed upon in 2023.

After initial acceptance at the 83rd session of the Marine Environmental Protection Committee (MEPC 83) in April 2025, the NZF was scheduled for formal adoption during the recent Second Extraordinary Session (MEPC ES2). The session and the vote on NZF adoption were adjourned for one year.

The NZF was expected to pass with a roll-call vote of two-thirds of eligible countries, representing more than 50% of shipping tonnage, which would mean it would enter into force by January 2028. Support for the NZF included a consensus of European countries, most large flag states, Small Island Developing States (SIDS), many Least Developed Countries (LDCs), and the BRIC countries (except Russia). Shipping industry organizations (ICS, ECSA, ASA, WSC, IAPH, IBIA, and ITF) also supported NZF adoption. Many oil-producing countries opposed the NZF, primarily led by the US, Saudi Arabia, and Russia.

In the weeks leading up to MEPC ES2, there were signs of weakening in support for the NZF:

  • The US reiterated its position against the NZF and actively participated in the session, as well as through diplomatic efforts outside the session.

  • The American Bureau of Shipping (ABS) called for the IMO to reconsider, pause, and adjust the proposed NZF.

  • A group of top shipping companies, including several major Greek and tanker firms, changed their position from that of major ship operator organizations.

What Happened at the Meeting

The European Union indicated that it would review its existing regulations upon adoption of the NZF. A stronger statement from the EU indicating its intent to align its existing maritime regulations with the NZF to prevent double payments was anticipated but not forthcoming. The near-unanimous support from shipping interest organizations before the meeting was primarily based on the desire for consistent international regulations rather than a patchwork of national and regional GHG emission regulations.

On Friday, at the end of a week of discussions, Brazil proposed holding a roll-call vote on the adoption of NZF. The outcome of the vote was uncertain, with the opposition nearing the one-third level required to defeat the framework. Saudi Arabia put forward a suggestion originally made by Singapore to adjourn the meeting for one year. The motion to adjourn was put to a roll-call vote immediately, resulting in 57 votes for adjournment, 49 votes against, and 21 abstentions. The session was adjourned, and the NZF vote did not take place.

Some countries previously considered supporters of the NZF (Bahamas, China, Cyprus, Greece, India, Liberia, Malaysia, New Zealand, Panama, Philippines, Korea, and Thailand) either supported the adjournment or abstained. Some of these delegations indicated that concerns about adopting a GHG economic regulation, while guidelines for financial incentives, fuel factors, fuel certification, and bio-fuel guidelines remained incomplete, had influenced their vote. However, it is unknown what impact geopolitics had on the vote.

What Happens Now?

The NZF was the first attempt at regulating GHG emissions for an international industry sector and was considered by many to be a testbed for other mandatory international GHG regulations. The adjournment may impact international progress on other emission sectors and increase pressure on governments to act regionally. It may also slow investment in alternative fuel production and adaptation aboard ships.

Confirmed next steps:

  • The Intersessional Working Group continues to work on updating and completing the NZF draft guidelines.

  • The 84th session of the MEPC is scheduled to meet at the end of April 2026.

  • The Extraordinary Session will reconvene after a one-year adjournment in October 2026 to consider further delays or formal adoption of the NZF.

Options in the future for approving a global IMO GHG regulation include:

  • Repeating the motion and vote on adjournment at the October 2026 session, and if adjournment is defeated, proceeding with the NZF approval vote.

  • Modifying the NZF and progressing incomplete guidelines to broaden support for the framework.

  • Renegotiating a new GHG regulation, which could add several years to the IMO work plan and implementation schedule, and likely result in new national and regional regulations.

Our recommendation is to refine the NZF and its associated guidelines to foster broad alignment across the global maritime community, enabling meaningful progress well before the 2030s. Achieving this will require the adoption of consistent, practical, and transparent safety and environmental regulations that promote a level playing field. Regulatory clarity and stability are essential to support long-term investment and innovation across the shipping industry.

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See previous posts for an overview of the Net Zero Framework (NZF) regulations approved at the IMO’s MEPC 83 meeting. LINK TO PART 2 OF OUR BRIEF > | LINK TO PART 1 OF OUR BRIEF >