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International Chamber of Shipping

ICS

The aim of ICS is to act as an advocate for the industry on issues of maritime affairs, shipping policy and technical matters, including ship construction, operation, safety and management, and to develop best practice in the industry.

Lobbying Activity

Response to Evaluation on the operation of the Innovation Fund - 2025

8 Jul 2025

The detailed comments attached from ICS are limited to the EUs unilateral extension of the application of the EU ETS to international shipping which also applies to CO2 emitted by non-EU flag ships under the sovereign jurisdiction of third country flag State Administrations during commercial voyages to and from European ports, including CO2 emissions which occur outside of the territorial waters of EU Member States, plus those of Norway and Iceland, as defined by the United Nations Convention on the Law of the Sea (UNCLOS). ICS fully supports the implementation of a global GHG emission pricing mechanism for international shipping, as provided by the IMO NZF. However, ICS continues to oppose the unilateral application of any emissions trading systems to international shipping, whether national, local or regional. This includes the extension of the EU ETS by Directive (EU) 2023/959 to international shipping which is especially inappropriate for a global sector that largely comprises SMEs, many of which are located outside of the EU, as opposed to large land-based sectors within the EU, such as energy, steel and cement producers for which the EU ETS was originally designed and whose companies individually generate significant GHG emissions. In summary, therefore, ICS continues to regard the extension of the EU ETS to international shipping as an extraterritorial burden on global and EU maritime trade, which hampers and unnecessarily complicates the efforts of all IMO Member States (including EU States) to decarbonise the entre global shipping sector, a view shared by the EUs third country trading partners. It is essential that internationally trading ships should not be charged twice for the same GHG emissions under both the IMO NZF and a separate regional EU emissions charging regime for which, following adoption of the IMO NZF, there will no longer be any environmental justification, and which should therefore be replaced with the new IMO text before the MARPOL Annex VI amendments enter into force globally in March 2027.
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