Hello, yesterday the report of the Correspondence Group (CG) on the review of the CII was published and I would like to provide a short update. The report from the CG is not conclusive, as the final decision will depend on the approval of the MEPC, but it offers a strong indication of the likely outcome.
First of all, I would like to remind that the review of the CII will be carried out on two phases, with Phase 1 concluding by 1st January 2026, and Phase 2 starting afterwards. Urgent matters will be considered in Phase 1 such as the Z reduction factors for the period of 2027-2030 and whether the CII is a robust energy efficiency indicator. Phase 2 will consider all other challenges and gaps identified in the framework.
Noting the above, let’s see what was the outcome of the CG and in which topics discussion was focused.
Challenge #2: Z reduction factors for years 2027-2030
Starting with the urgent topic of the Z reduction factors, delegations suggested several values, with a median annual increase of 3% (currently it is 2%), as you can find on the table below.
| Reduction factors | Mean | Median | Extreme values |
|---|---|---|---|
| 2027 | -13.7% | -14.0% | -11% to -17% |
| 2028 | -16.6% | -17.0% | -12% to -23% |
| 2029 | -19.5% | -20.0% | -13% to -30% |
| 2030 | -22.5% | -23.0% | -14% to -38% |
It was also stated that these rates might have to be revised in light of changes to the CII (such as a change of metric). For phase 1, the coordinators suggested to consider if adjustments should be made to the reduction factors and/or to the reference lines to compensate for exclusion of emissions from the introduction of correction factors and voyage adjustments. MEPC 83 is expected to agree on the reduction factors.
On the rest challenges and gaps identified
Challenge #1: CII does not allow for robust individual ship-based assessment of operational energy efficiency performance: Six recommendations identified, such as to strengthen the annual audit requirement, to change the current focus on E and D ships to continuous incremental improvement to all ships. Member States are invited to submit concrete proposals to future sessions for consideration in Phase 2.
Challenge #3: CII calculation might penalize idle time and port waiting time: General support for metric change to be considered in Phase 2, considering only consumptions other than during anchorage/during port waiting/at berth e.t.c., recalculation of CII reference lines and dd vectors, identification of existing correction factors that could overlap, further consideration on what other measures can address emissions removed from the scope of the revised CII . No support for a correction factor.
Challenge #4: CII might penalize short voyages: No support for correction factor, possible benefit if metric changes (Challenge #3).
Challenge #5: CII might penalize cruise passenger ships: Several members supported metric change based on CLIA’s proposal (use cgHRS instead of cgDIST, cgHRS = ΣCO2/(GT x Hours)). Work will continue at Phase 2.
Challenge #6: CII enforcement does not provide sufficient incentive for behavior change: To be kept in abeyance until analysis of revised IMO DCS is completed.
Challenge #7: CII does not incentivize Just-in-Time (JIT) arrival: To be kept in abeyance.
Challenge #8: Accessibility to IMO DCS: Matter to be considered at ISWG-APEE 1 (prior to MEPC 83).
Challenge #9: CII might penalize self-unloading bulk carrier: To be kept in abeyance.
Challenge #10: CII might penalize geared bulk carriers: Will be considered under Challenge #3.
Challenge #11: CII might penalize ships operating in adverse weather: To be kept in abeyance.
Challenge #12: CII might penalize ships using bow thrusters: Will be considered under Challenge #3.
Challenge #13: CII might penalize ballast voyages: To be kept in abeyance.
Challenge #14: CII might penalize ships equipped with inert gas generator: To be kept in abeyance.
Challenge #15: CII might penalize ships carrying refrigerated cargo below deck: To be kept in abeyance.
Challenge #16: CII might penalize steam driven LNG carriers: To be kept in abeyance.
Challenge #17: CII might penalize ro-ro cargo and ro-ro passenger ships: To be kept in abeyance.
Challenge #18: CII reference lines does not accurately reflect smaller LNG carriers: To consider recalculation of the CII reference line in Phase 2.
Challenge #19: CII might overlap with MTM: A proposal to change the nominator of the CII from gCO2 to MJ (energy based). To be considered in Phase 2.
Challenge #20: CII does not address lifecycle emissions: To be considered along with Challenge #19.
Challenge #21: CII does not allow for pooling: To be kept in abeyance.