What Global Carbon Pricing Does to Voyage Economics

Almost everything written about the IMO Net-Zero Framework asks whether it will pass. That is a fair question, and for anyone deciding whether to retrofit or reflag it may be the only one that matters. It is the wrong question for this quarter, because the prices are already written down and the arithmetic they imply for a voyage can be worked out now.

The draft revised MARPOL Annex VI sets two tiers. For the reporting periods 2028 to 2030, the initial price of a Tier 1 remedial unit is US$100 per tonne of CO2 equivalent on a well-to-wake basis, and a Tier 2 remedial unit is US$380 on the same basis. Tier 1 covers emissions between the direct compliance target and the base target; Tier 2 covers emissions beyond the base target. Both figures are in the text being negotiated, at Regulation 36, paragraphs 8 and 9. The Global Centre for Maritime Decarbonisation has published a calculator against them.

So the question worth asking is not whether shipping gets a carbon price. It is what a price at that level does to the decisions you are already making: how fast to sail, who pays for the difference, and whether the consumption figures you would be charged on would survive being read as an invoice rather than as a report.

A reporting obligation lands on a technical department. A priced liability lands in the charter party, in the speed instruction, and in the number a commercial manager defends at the end of the quarter.

What is unsettled, and what is not

The framework combines a global marine fuel standard with a pricing and reward mechanism. DNV describes it as the first of its kind to cover a global industry sector, measuring performance as well-to-wake greenhouse gas emissions per unit of energy used, on a technology-neutral basis rather than by mandating particular fuels.

It was approved at MEPC 83 in April 2025 and it has not been adopted. An extraordinary session of the Marine Environment Protection Committee met in October 2025 to adopt it and instead voted to adjourn for a year, by 57 states to 49. Maritime Executive reported that the United States had threatened tariffs and port taxes in the run-up to the meeting, and that Cyprus, Greece and Malta threatened to break EU voting unity. Russia, the United Arab Emirates, Liberia and Saudi Arabia opposed, while China, the EU, Brazil and the United Kingdom were openly in favour.

The opposition has not softened. The Cyprus Union of Shipowners has called on Cyprus and other EU member states to vote the framework down, arguing that as drafted it represents, in its words, a multi-billion-euro tax that does not reduce emissions but instead shifts the cost to end-consumers. A group of owners including Bahri, Frontline, Capital Group, TMS and Dynagas has stated that as it stands they do not believe the framework will effectively support decarbonizing the industry. A separate coalition of industry organizations has formally urged member states to adopt it in 2026. Both positions are on the record, and the practical reading is that the framework in its current form is unlikely to survive unamended.

The dates are firmer than the outcome. MEPC 85 runs 30 November to 3 December 2026, with the resumed Second Extraordinary Session on Friday 4 December, subject to confirmation by MEPC 85. Two intersessional working groups precede it, 1 to 4 September and 23 to 27 November, plus a one-day expert workshop on chain-of-custody models. DNV puts the earliest entry into force at 1 March 2028; some trade coverage suggests 2029 if adoption slips again.

Why this is a voyage-economics problem

Consider what already happens when a charterer asks for a faster passage. Earlier delivery, better utilization, a higher time charter equivalent, set against a fuel bill that rises steeply with speed. Some operators run that calculation explicitly, against a real curve for the hull in front of them. Others settle it in a phone call. The difference between those two is about to acquire a price.

A flat carbon price would shift that calculation. A differentiated one, priced in tiers against a target the ship is measured on, changes its shape. With a higher effective fuel cost resulting from the new penalties, the optimal sailing speed will be lowered. Passages that were marginally worth pushing stop being worth pushing. And because the mechanism prices the intensity of the energy used, it bites on the voyage rather than on an annual average.

This is where the framework differs from CII in a way that is easy to miss. CII is an annual, fleet-level rating you manage toward across a year, and a weak quarter can be recovered in a strong one. A priced fuel standard is a per-voyage cost. You cannot average your way out of a bill.

The size of the shift is vessel-specific, because it depends on each hull's real speed and consumption relationship in its current condition rather than on the curves the yard supplied. A fleet-wide instruction to slow down is a blunt answer to a question that has a per-vessel one.

Who pays is already being answered

The allocation question is further along than most operators realize, and it is not being left to negotiation from scratch. BIMCO's published position is that the commercial party responsible for setting the speed and route of a ship should bear the greenhouse gas cost as an economic element: the charterer under a time charter party, and the party that commits the ship to the voyage under a voyage charter party. BIMCO already maintains a portfolio of carbon clauses, including a CII Clause for Voyage Charter Parties adopted in October 2023, and is developing clause language for the newer mechanisms.

The draft regulation points the same way. Regulation 36, paragraph 7 preserves the ship's ability to recover costs that relate to what it calls the operational responsibility of the ship, and defines that as determining the fuel used, the cargo carried, the route or the speed. That is BIMCO's speed-and-route principle appearing in the text being voted on rather than only in an industry position paper.

The practical consequence is that whoever controls speed is being pointed at as the party who pays for it. If that is the charterer, the instruction to push a passage acquires a price tag the charterer sees. If you are the owner, the exposure sits in whether your contract says so clearly, and fixtures agreed this year may still be running when a price applies.

The overlap, and the one cost that is certain

Operators trading in and out of Europe already face two regional mechanisms. EU ETS requires allowances to be surrendered against a rising share of reported emissions, and FuelEU Maritime separately caps the greenhouse gas intensity of energy used on board, with its own reporting and penalty cycle.

Lloyd's Register is direct about what a third, global mechanism means: any ship of 5,000 gross tonnes or more calling at EU ports, with certain exceptions, will be regulated twice, to comply with both the IMO framework and FuelEU. On payment it is more careful, suggesting there may be some way to report to both but pay only once, avoiding double payment if not double monitoring. It also flags the real risk: if the guidance and methodologies underpinning the IMO framework diverge too far from FuelEU once published, removing FuelEU becomes difficult. LR's own modeling has the IMO framework setting the greater annual financial penalties up to 2045, with FuelEU taking over from 2045 to 2050.

That distinction is the most useful thing an operator can take from the overlap debate. Double payment is a live negotiation and may not happen. What is close to certain is that the same voyage gets measured twice, under two methodologies, and verified against two regimes. This is not a new reporting burden in the sense of new fields: the amendments approved at MEPC 83 changed who can see IMO DCS data, not what is collected, and they sit under the review of the existing short-term measures rather than under the Net-Zero Framework. It is the same underlying consumption record being asked to satisfy two different sets of workings.

Which puts reporting quality, not levy exposure, at the center of what is worth preparing. A priced mechanism operating on reported figures makes data a financial control rather than an administrative one. If your consumption figures are reconstructed after the fact from noon reports of variable quality, you are not only risking a compliance finding. You are paying against a number you cannot defend, twice, to two regimes that will not accept the same workings.

What is worth doing before December

• •Model your exposure at the drafted levels. The US$100 and US$380 tiers are in the draft text and the Global Centre for Maritime Decarbonisation has published a calculator against them. A number for your own fleet is a better basis for a board conversation than a view on the politics.
• •Test whether your consumption data would survive a verifier reading it as the basis for a charge rather than a report. Those are different standards, and the gap between them is where the cost sits.
• •Establish the real speed and consumption curve for your hulls in their current condition. Every version of this regulation prices energy used, and a fouled hull moves that curve.
• •Put emissions cost allocation on the agenda for fixtures being negotiated now, against BIMCO's speed-and-route principle rather than in the abstract.
• •Follow the September and November intersessional groups rather than waiting for December. Given how much of the framework is expected to change, that is where its shape gets decided.

None of that is contingent on the vote. It is worth doing if the framework is adopted on 4 December, if it is postponed a second time, and if it passes materially amended, which on the current evidence is the most likely of the three. That is the test worth applying to any preparation someone recommends this autumn: does it still make sense if the vote goes the other way. If not, it is a bet rather than a plan.