ICC Document & publication

ICC recommendations on vessel air emissions (2011)

ICC calls upon governments to formally adopt a draft package of technical and operational measures proposed by the International Maritime Organization (IMO) that will improve energy efficiency and reduce shipping‟s CO2 emissions.

Only agreements by governments developed at the IMO can ensure that any measures adopted are applied on a uniform and global basis for all international shipping thus avoiding the possibility of “carbon leakage” that could occur if CO2 emissions from shipping are regulated nationally and/or regionally. This is particularly critical as most shipping companies have the freedom to register their ships with the nation of their choice.

Shipping as a global industry requires global rules. Regulations governing the environmental performance of ships, including CO2 emissions, need to be the same at both ends and throughout the voyage. Otherwise, there is a great risk of market distortion and serious inefficiencies in an industry that is responsible for the transport of about 90% of all world trade.

International shipping does not lend itself to inclusion as part of national or regional emission reduction targets as most shipping companies have the freedom to register their ships with the nation of their choice. For example: A ship may be registered in one country while the beneficial owner of the ship may be located in another; The cargo carried by the ship will be of economic benefit to a variety of different importing and exporting nations; Fuels may be purchased from any of a variety of potential sites.

This is why the achievement of meaningful CO2 reductions by shipping can only be achieved if nations agree that the measures for doing so should be directed on a uniform global basis by governments at the IMO. Any regulation that is only applied to ships registered in some nations and not others would result in gross market distortions and the hemorrhaging of vast amounts of tonnage to the flags of those nations not affected.

As a global, multi-sectoral business organisation, ICC believes that a comprehensive and global agreement on shipping at the IMO is of utmost importance. Otherwise CO2 emissions from ships could be dealt with in a differentiated and ultimately environmentally ineffective manner by either the UNFCCC as part of future international agreement on climate change, or through other differing regional approaches. Adoption of a package on CO2 emissions by the IMO will also be necessary to prevent unilateral regional measures affecting shipping.