Accordingly, the proposal was put forward before conducting an impact assessment, and under an unrelated piece of the legislation on the emissions monitoring system - the EU MRV.

The proposal has as a goal to pre-empt the conclusions of the European Commission’s impact assessment study and undermines the ongoing negotiations at the UN International Maritime Organisation. The move risks introducing sub-optimal environmental regulations at the EU level, contributing to a regulatory patchwork and an increased fragmentation at the international level.

Martin Dorsman, ECSA Secretary General commented that

In our opinion, imposing any regulatory measures without measuring the impact on shipping is not prudent. Regional measures have been criticised for undermining global negotiations at UN IMO level and may slow down or even reverse the progress that has already been made.

Moreover, he expressed his trust on the Council that it will put on hold any proposals until a thorough and comprehensive impact assessment is carried out. Any decision that will be taken has to truly work and actually deliver results.

To better explain, a recent study revealed the implications of the EU ETS on international shipping and found that such a measure would undermine the international negotiations to implement the IMO’s Initial Strategy on Reduction of GHG Emissions from Ships and would increase political tension with third countries, potentially leading to trade disputes.