Operational Guide · Registers & Logbooks

# IMO Net-Zero Framework

Not just an update to CII/EEXI, but a structurally new economic mechanism: a fuel intensity standard combined with a price on excess emissions.

Net-Zero Framework IMO GHG pricing fuel standard

## Operational Explanation

The IMO Net-Zero Framework represents a change in kind, not just in degree, compared with EEXI/CII: it introduces a binding global fuel intensity standard (Global Fuel Standard), which decreases progressively over the years, combined with an economic mechanism that puts a price on greenhouse gas emissions exceeding the permitted threshold, generating tradeable "compliance units" between ships.

The framework was approved in principle at MEPC 83 (April 2025); the extraordinary session of October 2025 convened for formal adoption closed without agreement, amid strong international political pressure. The adoption attempt was therefore postponed by a year: MEPC 84 (April 2026) focused on approving detailed implementation guidelines (LCA emission factors, the structure of the ZNZ reward mechanism, fuel certification), while final formal adoption is now expected at MEPC 85 (October 2026), with entry into force anticipated from 1 March 2027. Meanwhile, compliance unit (remedial unit) prices for the 2028-2030 period have been set: USD 380 for Tier 1 units and USD 100 for Tier 2 units; the price revision mechanism for reporting periods from 2031 onward will be defined by the MEPC at a later stage.

## Regulatory Reference

MARPOL Annex VI (new chapter under development): framework approved in principle at MEPC 83 (April 2025); extraordinary session of October 2025 closed without agreement; MEPC 84 (April 2026) approved detailed implementation guidelines; formal adoption now expected at MEPC 85 (October 2026); entry into force anticipated 1 March 2027. Remedial unit prices 2028-2030: USD 380 (Tier 1), USD 100 (Tier 2).

## Scope of Application

Expected to apply to ships subject to MARPOL Annex VI Chapter 4 (size thresholds to be confirmed upon final adoption), with a direct economic impact on operating costs tied to the type of fuel used.

## Procedure / How to Complete It

1. Actively monitor developments in the Net-Zero Framework through subsequent MEPC sessions, given the not-yet-final status of the framework.
2. Assess the fleet's prospective economic exposure to the pricing mechanism, based on the fuel mix currently in use.
3. Consider the impact of the future fuel intensity standard in investment decisions on alternative fuels or efficiency technologies.
4. Coordinate with charterers on the contractual allocation of costs related to the mechanism, once operational details are defined.
5. Follow regulatory updates (Regulatory Updates section) to avoid being caught unprepared for final adoption.

## Practical Example

Prospective planning example: a Company, pending final definition of the Net-Zero Framework, launches a preliminary assessment of its fleet's economic exposure based on the current fuel mix, to guide investment decisions for upcoming fleet renewals.

## Real Cases

The failure of the October 2025 extraordinary session, which closed without agreement despite MEPC 83's approval in principle, reflects the negotiating difficulties typical of a mechanism with a direct and significant economic impact: unlike traditional technical MARPOL amendments, an emissions pricing mechanism directly affects the relative competitiveness between fleets with different fuel mixes, making the approval process politically more complex and subject to delay.

## Common Mistakes Mistake Library

Mistake | Consequence | How to avoid it
--- | --- | ---
Passively waiting for the final definition of the framework, with no preliminary assessment of economic exposure | Unpreparedness for entry into force, with unanticipated economic impacts | Start a preliminary exposure assessment now, despite uncertainty over the final details
Charter agreements that do not provide for clauses allocating costs related to a not-yet-defined mechanism | Commercial disputes once the mechanism enters into force | Start considering flexible contractual clauses that can absorb regulatory developments
No systematic monitoring of developments at subsequent MEPC sessions | Late discovery of operational details relevant to your fleet | Systematically monitor updates via official IMO sources

## PSC Observations

The Net-Zero Framework is not yet in force and is therefore not subject to direct PSC verification; its future implementation will likely require new documentary verification elements once formally adopted.

## Operational Tips

- Do not wait for final adoption to start assessing your fleet's economic exposure to the mechanism.
- Systematically monitor developments at subsequent MEPC sessions, since operational details are still evolving.
- Start considering, in new charter agreements, clauses that can manage regulatory uncertainty during this transition phase.

## Checklist

- Developments in the Net-Zero Framework systematically monitored
- Fleet's prospective economic exposure preliminarily assessed
- Impact of the future fuel intensity standard considered in investment decisions
- Coordination with charterers started on future cost allocation
- Regulatory updates followed via official IMO sources

## FAQ

What is the Global Fuel Standard under the Net-Zero Framework?
It is the binding fuel intensity standard (greenhouse gas content per unit of energy) that decreases progressively over the years, the central technical element of the framework, distinct from but complementary to the economic pricing mechanism.
When will the Net-Zero Framework enter into force?
Not yet definitively: approved in principle at MEPC 83 (April 2025), with the October 2025 extraordinary session closing without agreement; formal adoption is now expected at MEPC 85 (October 2026), with entry into force anticipated from 1 March 2027, subject to confirmation.
What are the expected prices for compliance units (remedial units)?
For the 2028-2030 period, USD 380 has been set for Tier 1 units and USD 100 for Tier 2 units; the price revision mechanism for periods after 2031 will be defined by the MEPC at a later stage.
How does the Net-Zero Framework differ from CII and EEXI?
CII and EEXI are efficiency measurement indices, without a direct emissions pricing mechanism; the Net-Zero Framework instead introduces a fuel intensity standard combined with an economic mechanism that generates a direct cost on excess emissions, with tradeable compliance units.
🎬 Additional photos, videos and interactive diagrams for this topic will be available in a future version of the platform.

## Related Topics

MARPOL Annex VI — Prevention of Air Pollution EU ETS and FuelEU Maritime

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