Japan has submitted revised draft amendments to MARPOL Annex VI to support discussions on the IMO Net-Zero Framework, arguing that proposed greenhouse gas fuel intensity (GFI) targets can align with the 2023 IMO GHG Strategy without requiring rapid fleet replacement or major ship conversions.
The proposal, submitted ahead of MEPC 85 (30 November to 3 December), revises annual reduction factors for GFI targets and seeks to address concerns over feasibility, fuel availability and the pace of change in international shipping. Japan’s assessment takes into account transport demand, fleet development, energy efficiency, ship replacement rates and future fuel specifications.
Japan estimates that energy efficiency across international shipping could improve by 45% by 2030 and 70% by 2050 compared with 2008 levels. The analysis also notes that 95% of merchant ships at the end of 2025 were HFO-fuelled, while 4% were LNG and HFO dual-fuelled, supporting a gradual approach based on existing fleet replacement rates.
Under the main scenario, total shipping GHG emissions in 2030 are estimated at 81% of 2008 levels, while biodiesel, biomethane, methanol, ethanol and ammonia would account for 5.8% of total fuel use. Japan said the results are broadly aligned with the 2023 IMO GHG Strategy without assuming early replacement or major conversion of existing ships.
Japan concluded that the proposed GFI targets could help reach the ambition and indicative checkpoints of the 2023 IMO GHG Strategy without requiring rapid and significant changes to the international fleet. It called for continued review and discussion following implementation of the framework.