Maritime Safety and Protection of the Marine Environment

Climate change mitigation is an international challenge and, as such, it requires an international response. The UGS welcomes the adoption by IMO in October 2016 of a mandatory global data collection system for fuel consumption of ships. This is the first step of the IMO’s “Three Step Approach”, to which the UGS is committed and continuously supports.

This paves the way for the EU to align the EU Monitoring, Reporting and Verification (EU MRV) Regulation with the global system, as already stipulated in the Regulation, in order to have global regulatory uniformity and avoid unnecessary burden and complications for ships. It is worth noting in this respect that the EU MRV Regulation is not better or more advanced than the IMO system but has an entirely different intention namely the energy indexing of individual ships which is a highly problematic concept with potentially many arbitrary inequities and distortions especially for ships engaged in bulk / tramp shipping. The UGS actively supports the recent IMO decision on a Roadmap for a comprehensive CO2 reduction strategy that includes defined tasks and timelines to reduce greenhouse gas (GHG) emissions from ships as a further concrete step of the “Three Step Approach”. The first significant phase for the development of the IMO Roadmap will be the adoption in 2018 of an initial strategy for the shipping sector, with reduction objectives, candidate measures and target dates.

IMO member states and the shipping industry alike are determined and committed to delivering tangible results consistent with the spirit of the Paris Agreement and the IMO “Three-Step Approach”.

European shipping associations, including the UGS, are strongly opposed to the proposal of the European Parliament to include global shipping in the EU Emissions Trading System (EU ETS) Directive, as this is a regional measure which simply risks polarizing and unnecessarily complicating the debate among IMO member states at a crucial stage. The UGS welcomes the continued support of the EU member states and of the European Commission in not including shipping in the EU ETS Directive, which has not taken place so far and with good reason.

Shipping is one of the most energy efficient transport modes and therefore there is limited margin for further substantial improvement, especially as it is essentially fossil-fuel captive. In the absence of a major technological breakthrough using equivalent non-fossil fuels globally, Market Based Measures (MBMs) cannot be regarded as viable long term measures addressing the decarbonisation of the ocean-going transport sector. If an MBM will be required to mitigate CO2 reductions in the short or medium term, the clear preference of the international shipping industry is for a bunker fuel levy administered by the IMO.