Discord, cacophony, intrigue – the debate surrounding the decarbonisation of the shipping industry is reminiscent of a disastrous theatre performance. The bone of controversy is CO₂ taxes on fuels. The crucial question of whether so much nonsense really needs to be shipped around the globe is completely overlooked.

The stage

The International Maritime Organisation (IMO) is a specialised body of the United Nations with 176 states as voting members. It defines international maritime rules in the form of conventions. These are formally decided jointly by the states. However, they only come into force after a sufficient number of countries have ratified the new convention. This is not determined by the number of countries, but by the total tonnage of ships registered in a country. This is why flags of convenience countries such as Panama and Liberia carry much more weight than the countries in which the shipping companies have their headquarters. For example, the world's largest container shipping company, Mediterranean Shipping Company MSC, with around 980 ships (February 2026), has its headquarters in Geneva. However, because all its ships sail under the flags of other states and only a dozen or so ships are registered in Switzerland, Switzerland is a lightweight in the IMO. This is despite the fact that Swiss shipowners operate the sixth largest tonnage in the world.

This mechanism means that often nothing happens for years after a convention is adopted. For example, the Hong Kong Convention on ship scrapping was adopted in May 2009. It did not come into force until 16 years later, in June 2025. Despite this cumbersome mechanism, some important IMO conventions regulate everyday life at sea, for example

• the Convention on the Prevention of Collisions.
• the Convention on the Training of Seafarers.
• the Convention on Safety at Sea (abbreviation SOLAS).
• the Convention for the Prevention of Marine Pollution by Ships (abbreviation MARPOL).

As maritime transport is constantly evolving technologically, the regulations must also be amended. To avoid having to wait for the parliaments of major flag states to approve each new rule, they are added to the annex of the existing convention.

There are permanent committees for important conventions. The IMO regulates the prevention of marine pollution in the Marine Environment Protection Committee (abbreviation MEPC). And there is a kind of subcommittee on climate, the “Intersessional Working Group on Greenhouse Gas Emissions from Ships” (ISWG-GHG). This working group prepares the decisions of the MEPC meetings.

Actors, singers and directors

Ships often belong to a company of anonymous investors. This company charters the freighter to a shipping company, the operator. However, the ship is then usually registered neither in the country of the owner nor the operator, but under a flag of convenience. Ownership, registration, financing, insurance, crew, management and classification of a ship are therefore usually spread across different countries. In addition, it sails in international waters. The shipping industry is as elusive as mercury when it comes to enforcing laws or environmental regulations or holding anyone accountable.

Flag states have often outsourced registry services, for example West African Liberia to the LISCR Trust Company in the USA. ‘The employees of private companies who represent member states at meetings can determine their government’s position.’ criticises the anti-corruption organisation Transparency International (Transparency International 2018).

In addition, there are representatives of NGOs and private companies acting as advisors and observers. Among others, the mining company Vale sends its people to IMO meetings with the Brazilian delegation. Vale operates the world's largest bulk carriers and fears disadvantages for its iron ore exports to China if fossil fuels become more expensive due to a CO₂ tax.

Among others, the oil companies ExxonMobil, Shell and Saudi Aramco were present at the ISWG-GHG preparatory meeting for a crucial MEPC meeting, alongside ship engine manufacturers Wärtsilä, MAN Energy Solutions, Rolls-Royce Power Systems and Winterthur Gas and Diesel (formerly Sulzer). Shipping companies such as MSC (Switzerland), CMA CGM (France), Cosco (China) and Maersk (Denmark), as well as shipping associations, were also present (IMO 2023 a).

A study published in 2017 concluded: ‘The IMO appears to be the only UN agency to allow such extensive corporate representation in the policy-making process.’ (InfluenceMap, 2017) Last but not least, the Deutsche Verkehrs-Zeitung, a trade journal for freight forwarders, commented: ‘The global shipping regulator suffers from its proximity to those it regulates and is a dysfunctional organisation due to a lack of internal power distribution.’

In other words, formally, the member states of the IMO are the directors. But in practice, lobbyists from industries associated with the shipping industry are at least as influential.

Audience: The seats in the boxes

The box seats are reserved for the shipping industry's major customers. When companies have to question their core business model for the sake of the climate, they like to point to their efforts in logistics to boost their image. In doing so, they tend to “forget” that transport accounts for only a small proportion of their costs and emissions.

That is why referring to logistics is a preferred way of reaping the ‘low-hanging fruits’: in 2021, the platform ‘Cargo Owners for Zero Emission Vessels (coZEV)’ was founded. Dozens of shippers with significant freight volumes, such as Amazon, Michelin, Unilever, IKEA, Tchibo and Philips, want to decarbonise their own sea cargo traffic by 2040 and are calling for the complete decarbonisation of the "maritime transport sector by 2050 at the latest’. This is much more precise than the target set by the IMO.

‘Green’ transport is therefore becoming a marketing tool for shipowners. The promises made in sustainability reports, press releases and on shipping company websites often read like green party manifestos. This is particularly true of container lines, as they transport consumer-oriented products and therefore attract more public attention than bulk carriers, for example.

Audience: Seats in the stalls

MARPOL, MEPC, ISWG-GHG, NZF... these are just a few of the IMO abbreviations. Anyone unfamiliar with these insider acronyms will find it difficult to decipher IMO documents.

In addition, journalists attending a MEPC meeting, for example, are subject to severe restrictions on what they are allowed to report. The non-governmental organisation Green Transition Denmark therefore states: ‘Industry involvement atthe IMO is overwhelming, particularly from big oil and ship owners.Meanwhile civil society and especially media representation ismarginal.’ (Lo, 2023)

This means that the opera performed on stage takes place in front of largely empty seats. The citizens of the member states are absent – a massive deficit in democracy.

The libretto

The shipping industry operates largely in international waters and is extremely international in its organisation. For this reason, maritime transport is excluded from the Paris Climate Agreement, as this only applies to emissions generated within national borders. The responsibility for reducing shipping emissions has instead been transferred to the International Maritime Organisation (IMO).

Although ships emit the least greenhouse gases per tonne-kilometre compared to land and air transport, the huge volume of goods transported means that this adds up to 3 per cent of global emissions – equivalent to the emissions of Germany. The volume transported is therefore the most important cause, with emissions being a symptom. The climate questions should therefore be: WHAT is being transported and WHY?

Currently, goods that generate a few cents more profit are often shipped because they are produced in an even cheaper low-wage country. Overproduction is dumped as mountains of clothes on African beaches and in the Atacama Desert, North Sea fish is sent to China for filleting (under working conditions that violate human rights) and then returns to Europe, and so on and so forth... All by ship. Shipowners transport oil, gas, raw materials, containers, waste... Over 12 billion tonnes of sea freight per year. The volume of exports – 90 per cent of which is by ship – is growing faster than global economic output.

No one asks the questions WHAT and WHY. If you want to find the answers, you should only transport what is acceptable within planetary boundaries and satisfies legitimate human needs. Only then would the question arise: HOW is it transported?

This question of HOW should not be asked for the shipping industry alone, but with a view to the entire energy system. Since the production of green hydrogen as the basis for new fuels is unlikely to come close to meeting the needs of a climate-neutral economy in 2050, it would make sense not to waste such fuels on shipping. This is because ships are the only form of transport that can directly utilise the power of the wind. Thus, maritime transport, which is both greatly reduced and wind-powered, would save green hydrogen for other sectors such as land transport, steel, cement and fertiliser production, etc.

Addressing such issues comprehensively – i.e. across industries – would require an international organisation that would have the authority to enforce appropriate regulations in favour of planetary life support systems, climate justice and the UN's sustainability goals. We are a long way from that.

The opera that the states have put on stage at the IMO with the Paris Climate Agreement is therefore not about the causes of the climate crisis, but revolves around the symptoms – greenhouse gas emissions.

What's more, the discussion revolves around the climate targets defined in the Paris Agreement. However, scientists have found that tipping points can be crossed even with less than 1.5 degrees of warming (Armstrong et al., 2022). On the other hand, the 1.5-degree limit was already exceeded in 2024. Even if this only affects a single year for the time being and climate science calculates with a ten-year average, the warming limit set in Paris, which was already too high, can no longer be met.

And there's more: the International Tribunal for the Law of the Sea in Hamburg has unanimously ruled that, according to the international convention on the law of the sea, the emission of greenhouse gases is prohibited as ocean pollution. Prohibited! End of story! Yet there are no plans for a proper discussion of this issue on the IMO stage.

Curtain up!

• Act 1: In 2015, the states gathered in Paris decided that the IMO should take on the task of making the shipping industry climate neutral. In itself, the Paris climate target is no guarantee that we will be able to avoid tipping points. But we have nothing better. In concrete terms, this means that the ISWG-GHG is to address a global problem in such a way that the MEPC can present a solution, which the states can then adopt at the IMO Assembly. For a body that has previously regulated technical and operational requirements – such as the permissible sulphur content of fuels or the distance from the shore at which kitchen waste may be thrown overboard – in the annex to the MARPOL Convention, this is a big ask.
  So the focus is on greenhouse gas emissions – the symptom. In 2018, the IMO sets an initial target: emissions from ship funnels are to be halved by 2050.
  
   
• Act 2: The end of the first act was, of course, insufficient from the perspective of the Paris Agreement. In July 2023, at the 80th session of its Marine Environment Protection Committee (MEPC 80), the IMO tightened this target against the opposition of at least 18 states, including China, Brazil and India (Gabbatiss, 2023). The new target is now ‘to reach net-zero greenhouse gas emissions around 2050, i.e. close to 2050, taking into account different national circumstances’. (IMO, 2023 b) The interim target for 2030 is formulated in a slightly more binding manner: By then, the aim is to avoid 20 to, if possible, 30 per cent of emissions. Among others, the NGO Oceancare criticises the decision as ‘insufficient and deliberately ambiguous’: ‘It is therefore extremely unlikely that shipping will be able to make a significant contribution to limiting global temperature rise to 1.5°C.’
   
• Act 3: So the second act ended with a vaguely worded goal, but at least it was something... However, as long as no concrete measures are formulated that can be written into the MARPOL Annex as technically binding regulations, the goal will remain ineffective. The shipping industry is singing its praises, claiming that it is the only industry to have adopted a globally valid climate target. This is what the big customers in the box seats like to hear.
  But on stage, there is infighting, and cacophony echoes from the orchestra pit. On the one hand, there are the small island states, mainly in the Pacific, which are threatened with a miserable demise due to climate change and rising sea levels. They are calling not only for technical regulations, but also for fossil fuels to be made so expensive with a CO₂ tax that it becomes worthwhile to use alternative fuels. In addition, substantial amounts from this tax should be transferred to developing countries to finance their efforts to tackle climate problems.
  These small states are opposed by large corporations and powerful states that do not want their business to be made more expensive by a few have-nots. For its part, the shipping industry would like clarity. What new refuelling infrastructure should be installed in ports? Which propulsion systems should shipowners invest in? After all, the ships ordered today will still be at sea in 2050. And a patchwork of regional climate regulations – such as those from the EU – means additional workload for shipping companies and on board.
  Even at the preparatory meeting for the historic MEPC 80, despite the virtually empty auditorium, the action shifted behind the scenes: intrigue, discord... John Kautoke, Embassy Secretary of the Kingdom of Tonga, is so angry that he has posted his criticism on the internet, which is unusual for a diplomat: ‘After the Chair had ended the penultimate day early, a small group was to meet in order to come up with alternative text to the Working Paper 2 which the Secretariat had produced. The makeup, constitution, location and nature of the small group was unknown to most Member States. The Pacific was therefore not part of the Small Group and so many of our proposals did not make it into the text drafted by the small group. The resulting text was not 1.5-degree-aligned, and yet it was subsequently carried forward as the basis for discussions at MEPC80 the following week.’ Finally, in MEPC 80 adopted the new climate target without a concrete plan for how to achieve it. 
  
   
• Act 4: In April 2025, the decisive package of measures is back on the table. This time, a breakthrough seems to have been achieved: for the first time, a majority votes in favour of an emissions tax and associated standards for fuels. The rules are very technical and complex, making them difficult to understand for the absent audience, the citizens of the member states. Put simply: The measures are intended to financially reward the use of green fuels and penalise emissions from fossil fuels. The revenue from the emissions tax is also to be made available to developing countries to finance climate adaptation measures.
  Happy ending? No. The Pacific island states had fought for years to have a penalty tax imposed on greenhouse gas emissions. But in April 2025, they abstained from the final vote. "Let us be clear about who has abandoned 1.5°C. Saudi Arabia, the US and fossil fuel allies pushed down the numbers to an untenable level and blocked progress at every turn", said Ralph Regenvanu, Vanuatu's Minister for Climate Change Adaptation. Hilton Kendall, Minister of Transport for the Marshall Islands, added: "We were fighting not only for our countries’ economic interests, but also for the safety of our people and our homes. We couldn’t take home the outcome that was given to us as a take-or-leave option – with rich countries asking us to pay for their technological transition while leaving us behind.”‘ (MCST, 2025) At least there is a package of measures at the end of the fourth act. The final decision on this ’IMO Net-Zero Framework" (NZF) will be made at an extraordinary MEPC meeting in October 2025. 
   

• Act 5: Anyone who believed that the decision on the package developed in April as part of the IMO Net-Zero Framework was a mere formality was proven wrong in October: in the newly reignited dispute over details, the only agreement that could be reached was to postpone the decision by one year to autumn 2026.
  A factor in this was that the US government under Donald Trump threatened all flag states that voted in favour of a CO₂ tax on fuels with harsh sanctions: Ships registered in these countries would be barred from US ports, additional port fees would be imposed, and sanctions would be levied against officials ‘who support activist climate policy’ (Office of the Spokesperson, 2025 / Safety4sea, 2025). For its part, the EU had spoken out in favour of the package of measures.
  If, in a sixth act, the IMO's ‘net-zero framework’ were to be adopted in autumn 2026 after all, the measures would come into force in 2029 – one year before the interim target for 2030 formulated in 2023. This would thus become an illusion. 

   

Theatre review

If, despite the restrictions imposed on journalists at the IMO, a theatre critic were to find their way into the empty auditorium, they might come to the following conclusion: the play being performed on stage is not about the root causes of the climate crisis, but deals with replacing fossil fuels with green alternatives. These alternatives do not (yet) exist. But even then, the actors are unable to come up with a solution.

Only when the IMO decides on concrete measures will “net zero by 2050” become international law. It will then be up to the flag states and port authorities worldwide to enforce this. The latter can often be appeased with a few cartons of cigarettes, a few bottles of whisky or some cash... Theatre critics could also point this out.

If it weren't for the survival and cultural foundations of the planet, a critic might scoff: ‘Franz Kafka couldn't have made it more absurd.’ But the dangers are all too real. And the criticism is perhaps somewhat unfair: the IMO is quite capable of regulating important details such as safety at sea, ballast water management, collision avoidance, etc. But when it comes to global problems such as climate change and planetary boundaries, it was already dysfunctional at a time when the Earth's system was still stable. Now that the era of global warming has begun, it is even more overwhelmed when it comes to finding viable solutions. This is not least the consequence of increasing national egoism, which leaves no room for supranational solutions. The IMO cannot be better than its member states, which are themselves not on track to achieve their climate targets. This is true even without Donald Trump threatening sanctions from the White House.

This brings us to the national level. This is where civil society can exert influence, at least in democracies: this is a call to action! The least we can do is go into the auditorium and shout ‘Boo!’ But it would be better to commit the actors of our own state to a consistent climate  policy within the planetary boundaries: WHAT is being transported at sea and WHY?

Uncomfortable – but necessary.

References

David I. Armstrong Mckay, Arie Staal, Jesse F. Abrams, Ricarda Winkelmann, Boris Sakschewski, Sina Loriani, Ingo Fetzer, Sarah E. Cornell, Johan Rockström, Timothy M. Lenton (2022): Exceeding 1.5°C global warming could trigger multiple climate tip- ping points. https://www.science.org/doi/10.1126/science.abn7950 

Josh Gabbatiss (2023): UN CLIMATE TALKS, In-depth Q&A: Will the new global shipping deal help deliver climate goals? https://www.carbonbrief.org/in-depth-qa-will-the-new-global-shipping-deal-help-deliver-climate-goals/ 

InfluenceMap (2017): Corporate capture of the International Maritime Organization. How the shipping sector lobbies to stay out of the Paris Agreement. October 2017, https://influencemap.org/report/Corporate-capture-of-the-IMO-902bf81c05a0591c551f965020623fda 

International Maritime Organisation IMO (2023 a): 15th Meeting of the Intersessional Working Group On Reduction of GHG Emissions from Ships, 15th Session, List of Participants.

International Maritime Organisation IMO (2023 b): Revised GHG reduction strategy for global shipping adopted. https://www.imo.org/en/mediacentre/pressbriefings/pages/revised-ghg-reduction-strategy-for-global-shipping-adopted-.aspx 

Joe Lo (2023), Dozens of oil & industry lobbyists attended secretive shipping emissions talks. in Climate Home News, 20.7.2023, https://www.climatechangenews.com/2023/07/20/imo-shipping-climate-talks-emissions-oil-fossil-fuels/ 

Micronesian Center for Sustainable Transport MCST (2025): Island Ministers abstain in vote on weak deal on emissions pricing at International Maritime Organization, https://mcstrmi.org/making-waves/island-ministers-abstain-in-vote-on-weak-deal-on-emissions-pricing-at-international-maritime-organization/?utm_source=MoEngage&utm_medium=EMAIL&mktcid=nled&mktcval=191&kid=nl191&ga=1 

Ocean Care (2023): Kritik und Fortschritt bei entscheidenden Fragen zur Dekarbonisierung der Schifffahrt und dem Schutz von Walen vor Kollisionen. Medienmitteilung, https://www.oceancare.org/wp-content/uploads/2023/07/PR-OceanCares-assessment-of-the-IMO-MEPC80-outcome-DE.pdf 

Office of the Spokesperson (2025): Taking Action to Defend America from the UN’s First Global Carbon Tax – the International Maritime Organization’s (IMO) “Net-Zero Framework” (NZF). Media Note, October 10, 2025, https://www.state.gov/releases/office-of-the-spokesperson/2025/10/taking-action-to-defend-america-from-the-uns-first-global-carbon-tax-the-international-maritime-organizations-imo-net-zero-framework-nzf

Johan Rockström, Louis Kotzéd, Svetlana Milutinovića, Frank Biermann, Victor Brovkinh, Jonathan Dongesa, Jonas Ebbessoni, Duncan French, Joyeeta Guptak, Rakhyun Kimg, Timothy Lentonm, Dominic Lenzin, Nebojsa Nakicenovico, Barbara Neumann, Fabian Schuppert, Ricarda Winkelmanna, Klaus Bosselmann, Carl Folkec, Wolfgang Luchta, David Schlosberg, Katherine Richardson, Will Steffen (2024): The planetary commons: A new paradigm for safeguarding Earth-regulating systems in the Anthropocene. https://www.pnas.org/doi/pdf/10.1073/pnas.2301531121 

Safety4sea (2025): US threatens sanctions as EU backs IMO Net-Zero Framework. https://safety4sea.com/us-threatens-sanctions-as-eu-backs-imo-net-zero-framework/ 

Transparency International (2018), Governance at the International Maritime Organisation: The case for reform. https://files.transparencycdn.org/images/2018_IMO_Governance_Report_EN.pdf