How IMO and EU regulations align on shipping decarbonisation

With IMO’s Net-Zero Framework approved in draft form at MEPC 83, and the EU’s FuelEU Maritime Regulation scheduled to come into force in 2025, both systems pursue reductions in GHG intensity using closely aligned methodologies.

Both frameworks introduce a well-to-wake fuel GHG intensity metric, measured in grams of CO2-equivalent per megajoule (gCO2eq/MJ).

As Lloyd’s Register lead regulatory specialist Andy Wibroe explained during a post-MEPC 83 webinar, "The scope of the regulation will be covering both the onboard emissions as well as the upstream emissions associated with the fuel".

Crucially, both IMO and FuelEU methodologies account for carbon dioxide, methane and nitrous oxide emissions, referencing the 100-year global warming potential factors from the IPCC’s Fifth Assessment Report.

Both frameworks extend regulatory reach beyond the traditional tank-to-wake emissions models.

"This is a major step change for IMO," noted Mr Wibroe. "Traditionally, IMO regulated only tank-to-wake emissions. Now it regulates the whole well-to-wake pathway."

The two regimes share other similarities, such as frameworks introducing an annual ship-level GHG intensity score; both systems envisage the certification of fuel pathways to verify sustainability and carbon content; and both adopt monitoring, reporting and verification obligations that require careful shipboard data collection and third-party validation.

IMO plans to publish a list of recognised Sustainable Fuel Certification Schemes by 2027, while FuelEU already requires fuels to comply with RED II and ISO 14067 standards.

This parallel structure means "both regimes are converging on comparable sustainability standards," according to one webinar panellist.

Overlapping goals, different terminology
While IMO applies a two-tier compliance system – Base and Direct targets – and FuelEU applies a single progressively tightening target, both structures aim to drive significant reductions in GHG intensity.

LR global head of energy transition advisory Jack Pringle summarised the intent, "GFI [Global Fuel Intensity] is very much designed to drive the uptake of low GHG intensity fuels".

Methane slip considerations
Both IMO and FuelEU also now offer pathways for LNG-fuelled ships to report measured methane slip rather than default factors, an important harmonisation.

MEPC 83 adopted guidelines allowing LNG operators to substitute default slip values with actual onboard measurements, mirroring the approach already available under FuelEU.

Although originating from different political and legal systems, the IMO Net-Zero Framework and FuelEU Maritime are structurally aligned in their core metrics, scope and intent.

Their technical convergence suggests compliance solutions developed for one regime will often be transferable to the other, providing a measure of efficiency for owners and operators navigating both systems.