USA's official submission to IMO on the Mid-Term Net Zero Proposals
The USA has made an Official submission, MEPC/ES.2/2/8, to the IMO objecting the Mid-Term Net Zero proposals, attached below.
The USA particularly objects to the associated risks with regard to the economic impact and the perceived inability to meet emissions reductions targets without considering the availability of qualifying ZNZ fuels. They also question how the disbursement of funds collected will
support the emissions reduction goals.
Specifically, the United States comments that :-
1) The proposed measures risk imposing significant economic burdens on the shipping industry and its customers, driving inflation for consumers.
2) Affordable and proven transitional fuels like liquefied natural gas (LNG) and biofuels are unfairly penalised under the measures, especially given the lack of clear existing alternatives.
3) Rapid Greenhouse Gas Fuel Intensity (GFI) reduction targets could lead to excessive revenue accumulation without achieving meaningful environmental goals.
4) The management and disbursement of revenues under the framework, which must be within the legal purpose of reducing air pollution from ships, is ill-defined and insufficient to ensure the efficacy of any emissions reduction framework.
The United States seeks the following :-
1) Invites Member States to oppose the proposed measures on the IMO Mid Term Net-Zero Framework (MEPC/ES.2/2).
2) States that the approved MARPOL Annex VI amendments are a product of compromise among diverse Member State positions. The approved framework is far from consensus, and the implications of adopting the amendments will continue to generate persistent concerns, and undermine efficacy, all while placing unnecessary burdens on the shipping industry.
3) Reiterates its strong objection to the proposed measures on the IMO Mid- Term Net-Zero Framework and invites MEPC to oppose the adoption of the amendments. It is essential that the Committee take sufficient time to fully analyze the economic ramifications of the proposed framework measures.
The IMO has arranged an extraordinary session, from 14 to 17 October 2025 to review and approve MEPCES/2. The draft submission is also attached below.
To date the United States is the only country to officially appose approval of the Mid-Term Net Zero Measures.
MEPC-ES.2-2 – Draft Revised MARPOL Annex VI 2025 (Secretariat) (1)