I. BACKGROUND
1. Decarbonization Progress
The decarbonization of shipping is an ongoing goal to reduce greenhouse gas emissions from shipping to net-zero by or around 2050. The IMO has an initial strategy which includes the practice of lowering or limiting the combustion of fossil fuels for power and propulsion to limit emission of carbon dioxide.[1] International trade is predominantly marine-based followed by pipeline, air, and then rail/truck. Most of the sea vessels that transport goods use diesel or fuel oil which emits a considerable amount of carbon dioxide.[2] In 2022 it was recorded that the maritime shipping industry transported almost 11 billion tonnes of cargo, causing nearly 3% of global carbon dioxide emissions.[3] These emissions and potential oil spills not only exacerbate global warming, but also harms coastal regions, marine life and biodiversity.[4]
2. Comparing Alternative Fuels
Each renewable energy fuel has different benefits and challenges. Which fuel shall be preferred is reliant on several factors such as the supply chain, engine model environmental impacts and production costs. The most suitable fuels are biofuels, e-fuels such as methanol and ammonia. Especially ammonia is featured as a suitable fuel due to the fact that it is less dangerous to living organisms.[5]
3. Problem of Culpability in Marine Decarbonization
Marine transport involves a number of actors playing different roles: fuel providers, shipowners, customers, investors, charterer, ship manager. Whom shall bear the liability of CO2 emission has been discussed in the literature. The culpable entity in this context is the one who must pay fines in case of infringement and is responsible to have increased CO2 emission.[6] A minority view suggests that fuel providers shall be liable. However, this approach is heavily criticised as it overlooks that fuel suppliers may carry out their actions outside the EU. Besides that, the causal link between CO2 emission and fuel suppliers’ action is not sufficient. The emission is not caused by the actions of fuel supplies, but by the ships.
The dominant view offers that the responsibility shall be attributed to shipowners. Since shipowners are in charge of structural changes to reduce CO2 emission and making investments in line with decarbonizations goal, it is more coherent to view them as liable.[7] The problem in this approach is that under some conditions, ship charterers may play a more active role in managing shipping activities. Therefore, it is proposed that ship charterers shall be liable can make decisions regarding emissive activities of ships. On the other hand, a charter’s link with the ship is temporary as it is restricted by chartering agreement.[8]
II. EU LEGAL FRAMEWORK ON MARITIME DECARBONIZATION
Maritime transport has been considered as a relatively eco-friendly way. Due to increasing trade activities, using larger ships and densified marine routes, it has become questionable whether maritime transport is still eco-friendly. EU has taken progressive steps to eliminate CO2 emissions produced by ships. What pushed the European Commission to take solid and relatively radical steps is the idea that international efforts do not suffice the need to reduce carbonization urgently.
1. The European Green Deal
The European Green Deal was presented in 2019 as the European Union’s agenda against global warming. The proposal was prepared by Frans Timmersmans (Executive Vice President). On 15 January 2020, it was presented to the European Parliament and adopted as a Joint Resolution by the majority votes. The Deal was supported by the parliamentary coalitions mainly comprised of European People’s Party (EPP) and center-right parties, the center-left and second majority party Socialists and Democrats (S&D), the center pro-European with the third majority party: on jobs, businesses and farms.[9] One of the most contested aspects of the proposal revolved around establishing binding national targets in future energy legislation, which received a narrow majority of 51% of members supporting the targets and exposing a divide between conservative and progressive camps
The main goals of EGD can be classified as: Climate ambition for 2030 and 2050, which focuses on carbon pricing; Clean, affordable and secure energy; Industrial strategy for a clean and circular economy; Sustainable and smart mobility; Greening the Common Agricultural Policy/“Farm to Fork strategy”; Preserving and protecting biodiversity; Zero pollution ambition for a toxic free environment; mainstreaming sustainability in all EU policies (including trade and foreign policy); positioning the EU as a global leader, and European Climate Pact.[10]
2. EU ETS
EU ETS is an unique system which aims to oversee carbon emission of companies by limiting them with “cap and trade system.” This system has found its legal base in ETS Directive (2003/87/EC). Emission from marine transport has been involved in list of sectors obligated to abide by EU ETS rules.[11] These rules apply to any large ship entering EU ports. depending on the inception port and destination, different ratios will be applied.[12] If a ship navigates between two EU ports, 100% of emissions will be covered by ETS rules. If a ship navigates between a non-EU port and a EU port, only 50% emission will be subjected to ETS.
Up-to-date ETS covers only CO2 emissions, but starting from 2026 CH4 and N2O will be monitored as well. Prior to the inclusion of shipping industry, aviation sector was involved in EU ETS scheme. Therefore, it is addressed that the commission is more prudent in drawing the necessary legal framework regarding the inclusion of shipping in ETS.[13] Similar to other sectors, shipping companies must acquire emission allowances through auctions or purchases. It is addressed that auction method is more suitable as it is transparent. To guarantee that the negative effects of transitioning to ETS is alleviated, only certain amount of emissions will be subjected to allowance system.[14]
Since EU ETS affects non-EU shipping companies as well, many businesses express that it would be more efficient that an internationally binding instrument was adopted instead of a regionally binding tool as EU ETS. It is more likely that shipowners will incur additional costs on their service instead of adapting their ships to low-emission technologies.[15] The problem lies in the difficulty of adapting ships to new technologies as ships have average service life of 30-40 years. Considering that adapting new technologies is a rather long-term decision, shipowners are not likely to opt for this choice. Adapting low-emission technologies may be costly, ships may be already old to adapt to these transitions. Therefore, instead of transforming to low-emission policies, shipowners incur costs on customers. This makes EU ETS’s efficiency questionable as shipowners may avoid the burden levied on them.[16]
As EU ETS applies to every ship visiting EU ports, it is debated whether this is in line with CBDR (Common but differentiated responsibilities). CBDR principle is explained in UNFCCC Treaty as taking the different capabilities and responsibilities of member states. From the perspective of developing countries, EU ETS may pose a threat to growing maritime trade. However, it is also supported that ETS has achieved to reconcile CBDR principle with decarbonization aims.[17] Cullinane defends that since revenues from emission allowances will be spend to create a fund for fostering research and development in the sector, this may grant effective solutions.[18]
It is pointed out that ships may circumvent these rules through taking different routes. One of these evasive behaviours might stopover at a non-EU port just before arriving at an EU port. On the other hand, the Commission is aware of the possible evasive behaviours and stipulate prevention mechanisms. What has been observed so far is that shipping companies benefit from charging EU ETS costs on service receivers. A study revealed that more than 90% of shpowners charge their customers higher than required to pay for EU ETS allowances.[19] Therefore, instead of evading EU ETS rules, shipowners has found the way to profit from it. Companies are encouraged to emit less CO2 as they are enabled to sell their remaining emission allowance in the carbon market. [20] Therefore, shipping companies which emit lower ratio of CO2 may gain economic advantages. As pointed out by scholars, the allowance price shall have the aptitude for encouraging shipowners to seek low-carbon emitting technologies. It is expected that the allowance price will increase gradually and will amount to 60-90 Euro.[21]
3. MRV
MRV regulation entered into force in 1st July 2015, but the first reporting activities began in 2015. It is crucial that MRV is introduced by a regulation instead of a directive. In EU law, regulations are directly applied without the need to be transformed in member states’ legal system. On the other hands, directives draw a general framework and must transposed into national legal system. Since MRV is based on a regulation, the EU commission provides a detailed guideline which does not allow nation states to act within their discretion.[22] To further support MRV Regulation, the Commission enacted Implementing Regulation to explain how the emission reposts shall be prepared, second Implementing Regulation, Delegated Regulation to elaborate on the methods for emission monitoring and second Delegated Regulation to share who are considered as accredited verifiers that will be responsible for assessing the reliability of reports produced by shipping companies.
Prior to EU ETS, maritime emission was monitored under MRV system. This regulation applies to ships of 5000 tonnage and above. MRV covers three greenhouse gases: Carbondioxide, methane and nitrousdioxide. The goal of MRV is to monitor ships’ fuel consumption, energy efficiency, distance travelled and ports they visit.[23]
MRV is solely reliant on emission information disclosure. Its scope is limited to submission of reports and publication of these reports. The reception of MRV changes from one actor to another actor. While NGOs are optimistic about MRV, many shipping companies express their concern over distortion of fair competition and burdensome paperworks. When a series of interviews were conducted with business owners, some of them pointed out that MRV is only about collecting data and submitting it, but also expressed that they resume to work on fuel efficiency.[24]
MRV foresees various steps to be completed by shipping companies: first the company forms a monitoring plan and submits this plan for review. If the plan is approved, the shipping company must record GHG emission in a compiled file. This file shall be assessed to determine whether it is reliable or not. After this final review, it is presented to the European Commission. The commission prepares a list of these submissions. The MRV report for 2018-2021 is available to public in order to promote transparency.[25]
If companies infringe their obligation of reporting, effective and proportionate sanctions may be applied. if the infringement is repeated, an expulsion order may be issued (ART 20.3). However, MRV does not provide any sanctions for uncomplying with transition to low-emission technologies. As long as business owners fulfill their obligation to monitor and submit their reports, they may continue using high-emission ships. Therefore, MRV by itself can only have limited effect in contributing decarbonization efforts. If a shipowner fails to submit the emission report, the only sanction foreseen is that the ship may be detained and it may only leave the port by paying a security.
The effectiveness of MRV is not sufficiently analyzed, the existing literature is rather limited. It is pointed out that it is difficult to determine whether the decrease in GHG emission is due to MRV or external factors especially COVID-19 crisis. Luo et. al. address that annual average CO2 emission is lower in 2021 in comparison to 2018-2019, but concluding whether MRV is a feasible remedy or not is strenuous as the surge of the global COVID-19 crisis disrupted the global supply chain.
4. FuelEU Maritime
The Regulation 2023/1805 was adopted to further implement the Commission’s Fit for 55 Legislative Package. The regulation advocates sustainable and low-carbon emitting use of fuels. The regulation has not entered into force yet; it will be implemented in 1 January 2025. What sets this regulation apart lies in the fact it is adopted specifically in the shipping industry.[26] The other decarbonization tools are adopted for a wide array of sectors. The example of subsequent involvement of the aviation and marine industry in EU MRV shows that different sectors require diversified regulations. In order to adapt to these requirements, the regulations had to be reviewed.[27] On the other hand, FuelEU is solely dedicated to marine industry and was adopted by considering the necessities of shipping industry. Since FuelEU has not entered into force yet, its effectiveness is not widely discussed in the literature.[28]
The FuelEU Maritime regulation applies to vessels of 5,000 tonnage and above. Similar to EU ETS, 100% of emissions on navigation between EU ports, and 50% of emissions on navigations between an EU port and a non-EU port are in the scope of the regulation.[29] The main provisions of the FuelEU Maritime agreement may be listed as: lowering GHG concentration of the fuels used by ships and mandating ships to use SSE (short-side electricity) or similar low-emission fuels.[30] Similar to EU MRV, shipping companies must monitor and submit emission data to be reviewed by verifiers. Shipowners had to submit a reporting plan to their verifier by the end August 2024. The report must present how they plan to monitor and report the amount, type and emission factor of energy used in ships.[31]
EU MRV has crucial weaknesses that impact its efficiency. The regulation leaves out a crucial portion of GHG emissions as it does not apply to vessels under 5,000 tonnage, offshore vessels, fishing and other non-cargo ships. It is presumed that the emission out of the scope drawn by FuelEU reaches approximately 20% of shipping emission.[32] Even though the regulations set remarkable goals, when the urgent need to reduce decarbonization is taken into account, the regulation fails to suffice the ultimate aim. When the weaknesses of sanctions are added to these pitfalls, the effectiveness of FuelEU does not seem so promising. What worries NGOs is that ship owners may evade to comply with FuelEU by utilizing similar methods in EU ETS.[33]
Efficient use of energy needs to be promoted and effectively implemented. This results in an immediate reduction of carbon emissions, and increasing monetary revenue for shipowners and operators by it can potentially help reduce an important portion of energy.[34] Costs of renewable fuels follow a decreasing trend at an accelerated rate. However, cost declines should be encouraged more in order to promote wider use of renewable fuels. It is proposed that investing in producing larger amount of renewable fuels is a sensible step to accelerate decarbonization.[35] Therefore, regulation MRV shall not be limited to shipping companies, but should also concern fuel suppliers and fuel producers in petrochemical industry.[36]
III. IMO
The shipping industry presents various challenges while transitioning to low-carbon fuels. One of these challenges is the lack of a recognized proper fuel. It is true that a large number of fuels are developed, but shipowners do not have to capacity to weigh which one is the most suitable fuel choice. In other words, there is almost no universally accepted fuel that can be utilized by every shipowner. As renewable fuels are relatively new, the existing knowledge of shipping companies on them is limited. Additionally, buying new ships or adapting the existing ships to new technologies are onerous as they require large number of investments.
IMO as the main overseeing body is comprised of members state who have the right to vote on policies. Since decarbonization as a sub-topic of climate change is a controversial problem, it is difficult to unite on stringently environment-friendly policies. The ultimate goal of reducing GHG emission is often ignored amidst the member states’ conflicting interests. While some member states are more willing to take action against carbonization, the others may be reluctant to sacrifice their trade volume. Since IMO is not independent from the governments of member states, its hands are tied. Especially when it is taken into consideration that global trade leans on shipping, and increasing international trade is an indispensable goal for every nation. States’ with highest number of ship registries are involuntary to prioritize environmental concerns over expanding their export. Countries with the highest ship registries can be listed as Panama, Malta, Marshall Islands. The common element for these states is that they have more power in decision-making processes in IMO, but they are also reliant on shipping industry. It is also highlighted that the small island states with high number of ship registries are fragile at the hands of climate change as the rising sea levels threaten their territories more severely.[37]
The principle of CBDR-RC (Common but Differentiated Responsibilities and Respective Capabilities) is sometimes used as an excuse to evade some universal responsibilities. This principle aims to ensure equity by treating developing and vulnerable member states differently. Some member states such as Argentina, Brazil, Saudi Arabia, South Africa and India plead this principle to prevent the implementation of GHG measures. This argument is refuted by referring to the principle of “no more favorable treatment.” Since IMO aims at ships’ actions, not state policies; the measures taken against GHG are concern for shipowners, not for member states.
1. Data Collection System (DCS)
Data Collection System DCS is enshrined in Resolution MEPC.278 (70). In brief, DCS requires ships to record and report their GHG emission. The report is first presented to the flag state acting as the verifier in this monitoring cycle. Upon the submission of this report, the flag state must decide whether the report complies with the requirements of the resolution. The approved reports are sent to the IMO Database. IMO compiles these reports and forms an annual document.[38]
Due to the fact that both objectifies monitoring and publishing emission data, EU MRV and DCS are often contrasted. Unlike EU MRV, the data shared by IMO is only available for member states’ concerned administrations. Therefore, transparency is relatively less prioritized in comparison to the EU reporting systems. On the other hand, the scope of DCS is more comprehensive than EU MRV as the latter only applies to transport of goods and persons navigation to and from an EU port.[39]
2. Ship Energy Efficiency Management Plan (SEEMP)
The Ship Energy Efficiency Management Plan (SEEMP) is a management plan that maintains fuel efficiency through operational developments, and it is applicable to new and existing ships. SEEMP for existing ships is a mandatory requirement.[40] The improvements required by SEEMP are an optimized vessel speed, increased frequency of hull or propeller cleaning, or even by having different route choices to reach a destination (which includes avoiding heavy weather). It should also be mentioned that SEEMP management plan is specific to each ship because as it considers the unique factors, such as cargo, routes, dry docking schedule. SEEMP propels ship-owners to consider low-emission technologies thoroughly.[41]
3. Energy Efficiency Design Index (EEDI)
In 2001, Energy Efficiency Design Index (EEDI) was annexed to MARPOL. The EEDI acts as a monitoring tool that informs ship-owners and stakeholders. Through technical efficiency improvements, the EEDI reduces the CO2 emissions. It is vital to mention that EEDI is the first internationally binding regulation to determine CO2 emissions standards across every sea. the International Council of Clean Transportation (ICCT) estimates that it is not probable for all ships to be compliant with the EEDI regulations by the period 2050.
4. Energy Efficiency Operational Index (EEOI)
The Energy Efficiency Operational Indicator (EEOI) was proposed by IMO in 2009. This regulation intended to measure the energy efficiency of existing ships. Unlike EEDI, EEOI is not a binding instrument and IMO aims to encourage ships to use EEOI on a voluntary basis.
The EEOI index can be shown as: Mass of CO2 emitted/ capacity mile. The index takes into account the fuel consumption (and the corresponding CO2 emissions) as all fuel consumed at sea and in port during the time period, which refers to, by main and auxiliary engines, including boilers and incinerators[42]
5. New Short-Term Measures (2018–2023)
The IMO has developed new short-term measures (the Energy Efficiency Existing Ship Index (EEXI), which is promoted by Japan to meet the IMO 2030 targets, and the Carbon Intensity Index (CII). These measures were an outcome of the ISWG-GHG 7 meeting and effectively developed new measures from different groups of countries under the two categories: Technical: For existing ships EEXI, taking EEDI and applying to existing ships.
6. Energy Efficiency Existing Ship Index (EEXI)
In November 2020, the IMO approved amendments to MARPOL Annex VI, which introduced a new measure for existing ships, called the Energy Efficiency Existing Ship Index (EEXI). The EEXI will be enforced in 2023 and will be applicable for vessels above 400 tonnage, falling under MARPOL Annex VI. Effectively, the EEXI is considered to be an extension of the EEDI, and in brief, the required EEXI measures are in harmony with requirements for newly built ships.[43]
The EEXI describes the CO2 emissions per cargo ton and mile and “determines the standardized CO2 emissions related to installed engine power, transport capacity and ship speed.” In other words, the EEXI limits the amount of CO2 emitted per unit of transport supply. It shall be noted that the EEXI is a technical (or design) index rather than an operational index. Therefore, there are no measured values of previous years and no on-voyage measurements are required. In brief, the EEXI merely refers to the ship’s design. Except for existing ships built in accordance with the EEDI Phase 2 or 3 requirements, a technical file that includes a technical calculation of the attained EEXI of a given ship must show that it is lower than the required EEXI value. Rutherford, Mao and Comer mention that, as proposed, the EEXI will only make a minor contribution to the CO2 emissions reduction targets set by the IMO. Although the studies conducted on the effect of EEXI is limited, the existing research purports that EEXI is not very promising as it can only reduce up to 1.3% of CO2 emission.[44]
7. Carbon Intensity Index (CII)
CII was adopted with an amendment in MARPOL. CII entered into force in 2022 which mandates ship-owners to submit their first report by the end of 2023. IMO plans that ship greater than 5000 tonnages shall be obliged to submit their required annual operational carbon intensity indicator (CII). Ships will be assigned ratings in accordance with their overall CO2 emission data. Unlike EEXI, the CII is a short-term measure.[45]
A ship’s carbon intensity will be rated A, B, C, D or E. The rating indicates a major superior, minor superior, moderate, minor inferior, or inferior performance level. The rating will be recorded in a “Statement of Compliance” to be monitor the ship’s compliance with SEEMP. If a ship is rated D for more than 3 consecutive years or it is rated E for only one year, the ship will be obliged to submit a corrective action plan to show how it plans to reach a better rating. A ship may opt for using low-carbon fuel or it may ameliorate its overall emission performance by using speed/ routing optimization plan or hull cleaning.[46]
8. Market-Based Measures (MBM)
When the size and structure of the shipping industry are taken into consideration, researches have almost reached a consensus on the insufficiency of relying on technical measures in reducing GHG at the desired rate. Therefore, market-based measures shall be added in the existing decarbonization tools. MBM, discussed in the Marine Environment Protection Committee (MEPC), are expected to be over the medium term. However, just like CO2 emission reduction measures, the discussions during IMO negotiations have been blocked due to different opinions proposed by different stakeholders.[47] MBM discussions begun at MEPC 56 in 2006 but could not show a remarkable progress up to date. MBM measures are based on economic factors and tax levies which serve for the purpose of creating economic incentives for investing in low-emission ships.
There are several proposed MBMs schemes, but they are still nascent. Although there is no purely market based measure, some of the existing regulations involve market based elements. The discussion of MBMs at the IMO seems to be stagnant, but the EU under the European Green Deal finds it rational to apply MBMs. EU MRV can be put into this category as it utilizes the income generated from CO2 emission purchases to create a fund for developing low-emission technologies.[48] On the other hand, IMO plans cannot be said to flourish from MBM plans. However, it is expected that IMO will give weight to create market-based measures. As discussed by Jorgensen, the market-based measures levying taxes on CO2 emissions must be internationally decided to avoid the risk of double taxation. Another issue with MBMs is that the available models in the literature are based on the short-term period (i.e., are not based on an optimal control approach). Therefore, it is inherently difficult for a shipping company to estimate the reduction of CO2 emissions, since the available models cannot analyse how much investment in capacity and how much effort is required to improve fuel efficiency.[49]
IMO is in tight collaboration with governments to adopt market-based schemes. Approximately ten countries came up with a MBM scheme. Some of these schemes are: Emission Trading Scheme (France, Norway), Vessel Efficiency Scheme (World Shipping Council), Ship Efficiency and Credit Trading (United States), International Fund for GHG emissions from ships/ GHG Fund (Cyprus, the Marshall Islands, Nigeria, Denmark), Leveraged Incentive Scheme (Japan).[50] IMO conducted a series of meetings to discuss the viable MBM scheme, but could not reach a final decision.[51]
CONCLUSION
Even though shipping is internationally regulated by a single body, IMO fails to adopt satisfying decarbonization precautions. It is also underlined that many of IMO’s plans are incoherent and inconsistent. Moreover, the wide array of existing legal frameworks on marine decarbonization has essential legal gaps and uncertainties. Especially, the obligations and sanctions in cases of non-compliance are not lucidly indicated. Since the number of stakeholders in shipping industry is considerably high, the roles and responsibilities are very much intertwined with each other.
Although IMO adopted the GHG Strategy in 2018, the enforcement of certain legal instruments on reducing GHG emission is stagnant. The current situation reveals that the shipping industry has fallen behind the Paris Agreement’s principles. Especially NGOs share that marine decarbonization is not indeed in the agenda, reducing air pollution is prioritized over decarbonization goals. The existing regulations such as EEXI and CII are still not finalized as they have essential weaknesses that must be handled by IMO. Therefore, EU can be said to have taken more solid steps in handling marine carbonization. With the use of market-based measures, ship-owners feel the urge to align themselves with the environmental agenda.
[1] ‘Maritime Decarbonization’ https://www.pnnl.gov/explainer-articles/maritime-decarbonization accessed 16.11.2024
[2] ‘Decarbonizing Maritime’ https://www.dnv.com/expert-story/maritime-impact/decarbonizing-maritime-overcoming-challenges-with-innovation-and-ingenuity/ accessed 15.11.2024
[3] ‘Decarbonizing Shipping’ https://unctad.org/system/files/official-document/rmt2023ch3_en.pdf accessed 11.11.2024
[4] ‘2023 IMO Strategy’ https://www.imo.org/en/OurWork/Environment/Pages/2023-IMO-Strategy-on-Reduction-of-GHG-Emissions-from-Ships.aspx accessed 12.11.2024
[5] Giorgio Zambani, “Comparative analysis among different alternative fuels for ship propulsion in a well-to-wake perspective” (2024) Heliyon
[6] Fadiga et. al., “Decarbonising maritime ports: A systematic review of the literature and insights for new research opportunities” (2024) Journal of Clearner Production
[7] ‘EU ETS: Who is Liable’ https://www.wfw.com/articles/eu-ets-who-is-liable-to-the-authorities-shipowners-or-managers/ s.e.t. 12.11.2024
[8] https://www.transportenvironment.org/uploads/files/2021_07_Integration-of-maritime-transport-in-EU-ETS.pdf
[9] ‘European Green Deal’ https://www.ab.gov.tr/european-green-deal_53729_en.html s.e.t. 13.11.2024
[10] Almedia, https://www.sciencedirect.com/science/article/pii/S0962629823001038, s.e.t. 8 December 2024
[11] ‘EU ETS and Shipping’
[12] https://www.nortonrosefulbright.com/en/knowledge/publications/f5c8d3fa/eu-ets-and-shipping accessed 12.11.2024
[13] CE Delft et.al. ‘The aviaiton and maritime sectors and the EU ETS: challenges and impacts’ (2021) European Parliament, Policy Department for Structural and Cohesion Policies
[14] Dimitrios Dalaklis et.al. ‘Inclusion of Shipping in the EU-ETS: Assessing the Direct Costs for the Maritime Sector Using the MRV Data’ (2021) Journal of Climate Change and Low-Carbon Economy
[15] Lars Zetterberg et.al. ‘Shipping in the EU emissions trading system: implications for mitigation, costs and modal split’ (2023) Climate Policy
[16] ‘Shipping majors profiteering from EU carbon emissions charge’ https://www.transportenvironment.org/articles/shipping-majors-profiteering-from-eu-carbon-emissions-charge-study accessed 17.11.2024
[17] Goran Dominioni, ‘Towards an equitable transition in the decarbonization of international maritime transport: Exemptions or carbon revenues?’ (2023) Marine Policy
[18] Cullinane et.al. ‘Potential alternative fuel pathways for compliance with the ‘FuelEU Maritime Initiative’ (2022) Transport and Environment
[19]‘Shipping majors profiting from EU Carbon Emission Charge’ https://www.transportenvironment.org/articles/shipping-majors-profiteering-from-eu-carbon-emissions-charge-study accessed 13.11.2024
[20]Christodoulou, A., Cullinane, K. The prospects for, and implications of, emissions trading in shipping. Marit Econ Logist 26, 168–184 (2024). https://doi.org/10.1057/s41278-023-00261-1
[21] https://www.mdpi.com/1996-1073/14/13/3915
[22] Xi Luo et.al. ‘After five years’ application of the European Union monitoring, reporting, and verification (MRV) mechanism: Review and prospectives’ (2024) Journal of Cleaner Production
[23] Ibid.
[24] Laurent Fedi, ‘The European ships’ Monitoring, Reporting and Verification (MRV): Pre-evaluation of a Regional Regulation on Carbon Dioxide Inventory’ (2016)
[25] Ibid.
[26] Alex Sprinnger, ‘The impact of FuelEU Maritime on EU shipping’ (2023) Transport and Environment
[27] Ibid.
[28] Cullinane et.al. ‘Potential alternative fuel pathways for compliance with the ‘FuelEU Maritime Initiative’ (2022) Transport and Environment
[29] Fredik Malmborg, ‘Advocacy coalitions and policy change for decarbonisation of international maritime transport: The case of FuelEU maritime’ (2023) Maritime Transport Research
[30] Ibid.
[31] Ibid.
[32] ‘FuelEU Maritime’ https://www.nortonrosefulbright.com/en/knowledge/publications/6f98bf8f/fueleu-maritime accessed 17.11.2024
[33] https://www.transportenvironment.org/uploads/files/FuelEU-Maritime-Impact-Assessment.pdf
[34] Levent Bilgili, ‘IMO 2023 strategy-Where are we and what’s next?’ (2024) Marine Policy
[35] Kubilay Bayramoğlu, ‘Evaluation of Decarbonization Methods on Ships’ (2023) Journal of Marine and Engineering Technology
[36] Ibid.
[37] Harilaous Psaraftis et.al., ‘Decarbonization of Maritime Transport: Is There Light at the End of the Tunnel?’ (2021) Sustainable and Green Maritime Transportation
[38]‘Data Collection System’ https://www.imo.org/en/ourwork/environment/pages/data-collection-system.aspx accessed 12.11.2024
[39]‘Shipping in Transition’ https://www.iddri.org/en/publications-and-events/blog-post/shipping-transition-imos-timely-negotiations-net-zero-future accessed 18.11.2024
[40] ‘EEXI and CII’ https://www.imo.org/en/MediaCentre/HotTopics/Pages/EEXI-CII-FAQ.aspx accessed 20.11.2024
[41]Rules on ship carbon intensity and rating system enter into force’ https://www.imo.org/en/MediaCentre/PressBriefings/pages/CII-and-EEXI-entry-into-force.aspx accessed 12.11.2024
[42] ‘EEIO’ https://www-imo-org.translate.goog/en/OurWork/Environment/Pages/Improving%20the%20energy%20efficiency%20of%20ships.aspx?_x_tr_sl=en&_x_tr_tl=tr&_x_tr_hl=tr&_x_tr_pto=tc accessed 27.11.2024
[43] Bouman et.al., ‘State-of-the-art technologies, measures, and potential for reducing GHG emissions from shipping – A review’ (2017) Transport and Environment
[44] Dan Rutherford et.al., ‘Potential Co2 reductions under the Energy Efficiency Existing Ship Index’ (2020), International Council of Clean Transport
[45] Ibid.
[46]‘ Rules on ship carbon intensity and rating system enter into force’ https://www.imo.org/en/MediaCentre/PressBriefings/pages/CII-and-EEXI-entry-into-force.aspx accessed 6.12.2024
[47] Chen et.al. ‘Policies focusing on market-based measures towards shipping decarbonization: Designs, impacts and avenues for future research’ (2023) Transport Policy
[48] ‘Market-based Measures’ https://www.imo.org/en/OurWork/Environment/Pages/Market-Based-Measures.aspx accessed 24.11.2024
[49] Ibid.
[50] Ibid.
[51] ‘Market-based Measures’ https://unfccc.int/topics/what-are-market-and-non-market-mechanisms accessed 28.11.2024