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Submissions

In 1961 ICS was the first shipping industry association to be granted consultative status at the UN International Maritime Organization (IMO). Since then, our secretariat has been regularly attending – and contributing to – the technical meetings. Our national association membership structure enables us to provide a well-balanced industry view, which we express through submissions.

 

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MEPC-ES 2-2-3 – Support for adoption of IMO Net Zero Framework

ICS urges the Committee to adopt the draft Revised MARPOL Annex VI 2025, as set out in the annex to document MEPC/ES.2/2 (Secretariat), including the new draft Chapter 5 Regulations on the IMO Net-Zero Framework (NZF), so that these amendments can enter into force in March 2027. ICS also has comments, especially with respect to the vital importance of rewards to ships to incentivize the uptake of ZNZs, as provided for by the NZF, and unhelpful unilateral GHG measures applicable to international shipping, which should be replaced by the IMO NZF once adopted.

17 July 2025 Submission

MEPC-ES 2-2-2 – Suggested amendment to draft regulation 39.2 of MARPOL Annex VI

ICS comments on document MEPC/ES.2/2 (Secretariat). Whilst ICS urges the Committee to adopt draft Revised MARPOL Annex VI 2025, as set out in the annex to document MEPC/ES.2/2, ICS suggests a single amendment, of essential importance to shipowners, to draft regulation 39.2 of MARPOL Annex VI concerning rewards to ships using zero/near-zero GHG fuels and technologies (ZNZs), which, with the Committee’s agreement, needs to be given careful attention by the Drafting Group that is expected to be established by the Committee at this session.

17 July 2025 Submission

ICS Comments to DG CLIMA on EU ETS – 8 July 2025

The International Chamber of Shipping (ICS) appreciates this opportunity to provide input to the European Commission (EC) “Review of the EU ETS for maritime, aviation and stationary installations, and of the Market Stability Reserve” (Ref. Ares(2025)3030455 - 14/04/2025).

9 July 2025 Submission