Jeanne M. Grasso and Holli B. Packer ●
The International Maritime Organization’s (“IMO”) Marine Environmental Protection Committee (“MEPC”) held its 84th session (“MEPC 84”) in London from April 27 to May 1, 2026. The session concluded with a commitment to rebuild consensus on global shipping emissions and proposed IMO Net-Zero Framework (“NZF”), even as the framework faced significant political opposition from the United States and several other Member States.
Background: The IMO Net-Zero Framework
The NZF is the centerpiece of the IMO’s medium-term greenhouse gas (“GHG”) reduction measure, which is intended to be formalized as a new Chapter 5 of MARPOL Annex VI. Its primary objective is to achieve net-zero GHG emissions from international shipping by 2050. The NZF was presented for adoption in October 2025, but the extraordinary session of the MEPC held that month was adjourned without action following significant opposition from several Member States. The IMO was then scheduled to reconvene in April 2026, at MEPC 84, to allow additional time for Member States to build consensus.
MEPC 84 Outcomes
Despite sustained pressure leading up to MEPC 84, the NZF ultimately survived the session unchanged. The MEPC agreed to establish an intersessional Working Group to resolve outstanding concerns on the NZF ahead of MEPC 85, which is scheduled to take place from November 30 to December 3, 2026. Notably, Member States will be permitted to submit new amendments and adjustments to the NZF draft that was previously approved.
Two intersessional meetings have also been scheduled, September 1–4 and November 23–27, ahead of MEPC 85, which are designed to track fuel origin and movement across the supply chain to ensure that emissions are properly traced and verified. The second extraordinary session of the MEPC is scheduled to resume on December 4, 2026, immediately following MEPC 85. Whether the NZF proceeds as-is is subject to discussions at the intersessional meetings and MEPC 85.
Opposition: A Call to End the NZF Entirely or to Find a Solution
MEPC 84 took place against the backdrop of a forceful submission from the United States in opposition to the NZF, filed on March 16, 2026, calling on the IMO to end consideration of the NZF entirely. The United States argued that the current NZF proposal would promote expensive and unavailable fuels while undermining the reliability of existing fleets and global trade.
Rather than the NZF, the United States called for an energy-all approach that does not restrict any fuel type, arguing that proposals should not limit conventional crude or diesel, liquefied natural gas, nuclear, biomass-based fuels, or any other type of marine propulsion technology. The United States also argued that regulations should avoid mandates and ensure the reliability of the existing fleet to prevent disruption to global trade.
The latest move follows early U.S. intervention at IMO talks in 2025, when a U.S.-led group pushed to delay adoption of the NZF and the Trump administration threatened retaliatory measures against countries supporting the proposal.
The United States was not alone in its opposition. A coalition of oil-producing nations (including Algeria, Saudi Arabia, Bahrain, Iraq, Kuwait, Russia, Somalia, and the United Arab Emirates) stressed that any framework should be consensus-based and rooted in multilateral deliberations while avoiding punitive measures. These countries stated that the current NZF does not reflect the core concerns of many Member States and therefore lacks the consensus needed for effective implementation.
The opposition group emphasized that timelines and trajectories must be realistic and pragmatic, taking into account the affordability, scalability, and global availability of fuels and technologies. They further urged that the framework should avoid widening inequalities and ensure benefits are shared fairly among nations.
On the other side is the “Getting to Zero Coalition,” comprising about 200 stakeholders from across the shipping and fuels value chain. Their aim is to commercialize zero-emission vessels by 2030, supported by the necessary infrastructure. The Coalition met recently to determine how to best move forward with decarbonization amidst the uncertainty.
Key MEPC 84 Decisions
While the NZF dominated the agenda, MEPC 84 advanced significant work across several other areas of environmental protection.
New Emission Control Area in the North-East Atlantic. MEPC 84 adopted a new Emission Control Area (“ECA”) in the North-East Atlantic, introducing stricter emission limits on NOx, SOx, and particulate matter. The entry into force date is set for September 1, 2027, with the ECA taking effect 12 months later in 2028. The ECA covers the exclusive economic zones and territorial seas extending up to 200 nautical miles from the baselines of Greenland, Iceland, the Faroe Islands, Ireland, the United Kingdom, France, Spain, and Portugal. Within ECAs, ships must use fuel with a sulphur content of no more than 0.10 percent or an alternative technology achieving the same result, e.g., exhaust gas cleaning systems (or scrubbers).
Marine Plastic Litter. MEPC 84 adopted the 2026 Strategy and Action Plan to Address Marine Plastic Litter from Ships, reaffirming the IMO’s goal of zero plastic waste discharges to sea from ships by 2030. MEPC agreed to develop a mandatory code governing the maritime transport of plastic pellets in freight containers under MARPOL Annex III and/or the SOLAS Convention.
Underwater Radiated Noise. On the issue of underwater radiated noise, MEPC 84 agreed in principle to extend the experience-building phase by two years, to the end of 2028, and to commission an IMO study on underwater noise emissions as an evidence base for possible future measures. Although these are guidelines and thus not mandatory, the goal of the two-year extension is to address the remaining barriers, cost trade-offs with energy efficiency, and capacity-building needs that stakeholders face before stricter policies are formulated.
Strait of Hormuz. MEPC 84 adopted a resolution condemning attacks on commercial shipping in the Strait of Hormuz region and the related risks to seafarers and of marine pollution, recognizing the vulnerability of the Persian Gulf and adjacent waters.
What This Means for the Industry
The regulatory landscape for international shipping remains uncertain. While the NZF survived MEPC 84, its path to formal adoption remains far from assured, given the significant opposition from the United States and a coalition of oil-producing nations.
The intersessional meetings in September and November 2026, followed by MEPC 85 in December, and the resumed extraordinary session in December, will be critical in determining whether sufficient consensus can be achieved to move some sort of NZF proposal forward. In the meantime, regional frameworks, including the European Union’s decarbonization regulations, remain in force, creating a patchwork of compliance obligations that maritime industry stakeholders must navigate.
This regulatory uncertainty highlights the importance of proactive engagement with policymakers and strategic planning across various potential compliance scenarios. Shipowners, operators, charterers, and other maritime stakeholders should closely monitor developments leading up to and at the IMO and be prepared to adapt to an evolving regulatory environment in the months ahead.
This article is one in a series of articles written for Blank Rome’s MAINBRACE: August 2026 edition.