Ship Managers Propose Key Changes to IMO’s Net-Zero Framework

Ship managers have raised concerns about the International Maritime Organization’s future net-zero framework and have proposed concrete changes to enhance its effectiveness. Representing the global ship management sector, InterManager has submitted a proposal to the IMO’s Marine Environment Protection Committee (MEPC83) for essential modifications. The submission highlights the current greenhouse gas (GHG) proposal’s lack of consideration for the involvement of a third-party International Safety Management (ISM) Manager, who operates approximately 20% of the global fleet.

The submission emphasizes that ship managers have limited influence over a ship’s GHG intensity compared to charterers and shipowners. They do not have a say in the choice of engine or alternative installations like sails or fuel cells, which are decided by the shipowner. Despite this, proposed amendments to MARPOL Annex VI suggest holding ship managers accountable for GHG emissions penalties, which InterManager argues misidentifies them as the polluter and could lead to legal challenges.

Assigning liability for compliance fees to ship managers could also have financial implications, as they may need to request upfront financial security from shipowners to cover potential insolvency risks or defaults. This requirement ties up significant equity in security, limiting cash flow for growth or investment in new ships. InterManager warns that these changes could hinder the industry’s development and create unnecessary legal disputes.

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