IMO MEPC 82: Key outcomes

According to DNV, a crucial element was the negotiation of GHG fuel intensity requirements, potentially in combination with a GHG pricing mechanism, as part of a new net-zero framework addressing GHG emissions. Other important decisions include the adoption of regulations to designate the Canadian Arctic and the Norwegian Sea as NOx, SOx and PM ECAs. Furthermore, DNV provides the following summary: 

Adoption of amendments to mandatory instruments

Amendments to MARPOL Annex VI were adopted, introducing the Norwegian Sea and the Canadian Arctic as ECAs for nitrogen oxides (NOx), sulphur oxides (SOx), and particulate matter (PM). The amendments will enter into force on 1 March 2026.

For the Canadian Arctic, the requirements take effect as follows:

• The 0.10% fuel sulphur content requirement takes effect from 1 March 2027.
• Tier III NOx requirements will apply to ships constructed (keel-laid) on or after 1 January 2025, although the requirements will enter into force on 1 March 2026.

For the Norwegian Sea, the requirements take effect as follows:

• The 0.10% fuel sulphur content requirement takes effect from 1 March 2027.
• Tier III NOx requirements will apply to ships contracted on or after 1 March 2026; or, in the absence of a contract, keel-laid on or after 1 September 2026; or delivered on or after 1 March 2030.

As a consequence of introducing contract and delivery dates as application dates for the Norwegian Sea ECA, the format of the supplement to the IAPP certificate was updated to include contract and delivery dates in addition to the keel-laid date.

Harmful aquatic organisms in ballast water: Ballast Water Management (BWM) Convention review

MEPC 82 continued discussing topics raised in the experience-building phase (EBP) to facilitate the review of the BWM Convention. The topics discussed include:

• Exceptional discharges on the high seas or in other designated areas
• Inclusion of maintenance instructions and schedules in mandatory Section B of the BWM Convention, requiring this to be described in the BWM Plan and Ballast Water Record Book
• BWM system testing parameters and test conditions for type approval testing
• Details of biological compliance testing for ships at intermediate and renewal surveys
• Standardization of data recordings

The review will continue in a Correspondence Group reporting to MEPC 83 in April 2025.

Modification of type-approved BWM systems

MPEC 82 updated BWM.Circ.43, “Guidance for Administrations on the Type Approval Process for BWM Systems,” to include guidance on modifications to type-approved BWM systems.

Ballast water record book

Following the finalization of the “Guidance on Operation in Challenging Water Qualities (CWQ)” at MEPC 81, the “Guidance on Ballast Water Record Book,” BWM.2/Circ.80, was amended to include an example of logging for ships encountering challenging water qualities.

Air pollution: NOx Technical Code

MEPC 82 approved amendments to MARPOL Annex VI and the NOx Technical Code to allow for the use of multiple engine operational profiles for marine diesel engines. The new requirements will also apply to already approved engine types retroactively, which can be verified based on documentation.

Furthermore, MEPC 82 approved amendments to the NOx Technical Code concerning the certification of an existing engine subject to substantial modification or to a higher NOx requirement tier. These amendments describe a process for re-certification of engines retrofitted onboard. The amendments are subject to adoption by MEPC 83 in April 2025.

Exhaust gas cleaning systems (EGCSs)

Proposed terms of reference for the re-establishment of a group of experts to draft guidelines for risk and impact assessments of discharge water from EGCSs were reviewed and sent to PPR 12 in January 2025 for further consideration.

Energy efficiency Review of the Carbon Intensity Indicator (CII)

MEPC 82 commenced a review of the short-term GHG measures (CII, SEEMP, and EEXI), considering gaps and challenges. No gaps were identified regarding the EEXI. MEPC 82 agreed to address the gaps and challenges related to CII and SEEMP in a two-stage approach:

First phase (before 1 January 2026):

• CII reduction (Z) factors for 2027–2030
• Enhancement of the SEEMP framework
• Idle time and port waiting time
• Short voyages
• Improvement of the CII metric for cruise ships
• Enforcement of the CII
• Port call efficiency
• Accessibility of DCS data

Second phase (after 1 January 2026):

• Self-unloading and geared bulk carriers
• Adverse weather
• Use of bow thrusters
• Ballast voyages
• Inert gas generators
• Refrigerated cargo below deck
• Steam-driven LNG carriers
• Smaller LNG carriers
• Ro-ro cargo and ro-ro passenger ships
• Overlap with mid-term GHG measures (net-zero framework)
• Life-cycle GHG emissions
• Pooling/fleet balancing

The review will continue in a Correspondence Group and an intersessional Working Group reporting to MEPC 83 in April 2025.

Data collection system (DCS)

MEPC 82 approved a circular providing guidance related to the application of amendments to Appendix IX (information to be submitted as part of the DCS) of MARPOL Annex VI, which enter into force on 1 August 2025. All data for the same calendar year are to be collected and reported with the same level of granularity. The amended data set should be reported from 1 January 2026, or from 1 January 2025 if the flag administration has agreed to early implementation.

Reduction of GHG emissions: Mid-term measures to reduce GHG emissions

MEPC 80 in 2023 decided to implement a basket of measures to achieve the 2023 IMO GHG Strategy ambitions. These measures consist of:

• A technical element: a goal-based marine fuel standard regulating the phased reduction of marine fuel GHG intensity
• An economic element: a GHG emissions pricing mechanism linked directly to the GHG intensity mechanism or as a standalone mechanism

The measures are scheduled to be adopted in 2025 and enter into force around mid-2027.

At MEPC 82, the IMO net-zero framework was further developed to include consolidated legal text for future work. The text includes design options for both technical and economic elements. Although no agreement was reached on the package of measures, further convergence between member states occurred. A GHG fund and potential revenue distribution from an economic element were discussed, though with limited alignment.

A comprehensive impact assessment of the basket of GHG reduction mid-term measures was completed. However, due to concerns raised, additional work will be done before MEPC 83, including assessing the potential impact of GHG regulations on food security.

As significant work remains before the adoption of the basket of measures, it was agreed that intersessional work is needed prior to MEPC 83.

Marine plastic litter

MEPC 82 approved guidelines on good practices related to the clean-up of plastic pellets from ship-source releases. Additionally, a specific action was added to the current action plan to address marine plastic litter from ships: introducing requirements for the transport of plastic pellets by sea in freight containers.

Identification and protection of special areas

MEPC 82 designated Nusa Penida Island and Gili Matra Island in the Lombok Strait as Particularly Sensitive Sea Areas (PSSAs).

Underwater radiated noise (URN)

MEPC 82 agreed to continue work on reducing URN from ships by introducing an experience-building phase (EBP) and extended the target completion year to 2026. MEPC.1/Circ.906, “Revised Guidelines for the Reduction of Underwater Radiated Noise from Shipping to Address Adverse Impact on Marine Life,” was amended to include a URN management planning reference chart.

Any other business

Use of HFO as fuel by ships in Arctic waters

MEPC 82 approved guidelines on mitigation measures to reduce risks associated with the use and carriage of heavy fuel oil (HFO) by ships in Arctic waters. It was also clarified that Regulation 43A.2 of MARPOL Annex I, which postpones the ban on using and carrying HFO as fuel in Arctic waters to 1 July 2029, applies only to ships required to have fuel oil tank protection under Regulation 12A of MARPOL Annex I or Regulation 1.2.1 of Chapter 1 of Part II-A of the Polar Code. Older ships not subject to these requirements must comply with the HFO ban from 1 July 2024, even if fuel oil tank protection standards are voluntarily met.

Ship recycling

To prevent potential legal ambiguity concerning the relationship between the Hong Kong Convention and the Basel Convention, with respect to the transboundary movement of ships intended for recycling, MEPC 82 decided to seek advice from the Basel Convention Secretariat on common guidelines. Acknowledging that the Basel Convention Secretariat could not contribute to the guidelines before the Hong Kong Convention enters into force in June 2025, it was agreed to approve provisional guidance as a temporary measure.

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