Liability on Emissions print

IMO has set specific co2 emissions goals. These are monitored for now but is there intention to bind contractually owners? Any clauses being drafted to make owners compensate for high emissions print? And when should we expect to see this? Thank you


According to the MEPC 78-346 regarding the CII and the SEEMP III “for ships rated as D for three consecutive years or rated as E, a plan of corrective actions to achieve the required annual operational CII.”
At the first step measures will be required to achieve the CII. This will affect at least the next three years.
Next there will probably be some kind of GHG market but for now there is no legal framework.


Thank you Iro! Very helpful and to the point :slightly_smiling_face:

1 Like

During MEPC 78, the Member States discussed the mid-term measures of the IMO GHG strategy, specifically the various economic and technical proposals. Some economical measures proposals include the

  • ETS Cap and Trade Schemes
  • Levy on all GHG emissions
  • International Maritime Sustainability Funding and Reward (IMSF&R)
  • Zero Emissions Vessels Incentive Mechanism

The proposals will be further discussed at the next MEPC 79 - December 2022.

In parallel, the European Parliament adopted its position on the revised EU Emissions Trading System (ETS) to be extended to maritime transport. At the beginning of February, EU ETS allowances were traded above USD 100.

BIMCO has published a clause on the ETS - EMISSION TRADING SCHEME ALLOWANCES CLAUSE FOR TIME CHARTER PARTIES 2022 , and the ETSA Clause follows the “polluter-pays” principle by ensuring the pass-through of ETS costs to the commercial operators of vessels – in this case, the time charterers.

The rhetorical question of all the CO2 schemes is who should be considered the polluter?


“The rhetorical question of all the CO2 schemes is who should be considered the polluter?” What is the up until now answer to this?

1 Like

I’m afraid that will end up to be you and me.

1 Like