UMAS: Revised GHG strategy is very close to the 1.5°C pathway targets

In their latest report, UMAS finds that the International Maritime Organization (IMO)’s Revised GHG Strategy creates a very clear onus for a rapid and strong upwards revision of corporate, national and regional actions.

The revised strategy 

Specifically, according to UMAS, albeit not unambiguously 1.5°C -aligned, the IMO strategy’s 2030 and 2040 targets (key guidance for investor’s decision making) are in practice very close to the 1.5°C pathway targets. The risk and opportunity space is now more strongly and clearly defined, UMAS notes.

Alas, UMAS finds that by association it is now much easier for any actor or initiative to adopt a clear 1.5°C alignment, whilst remaining broadly aligned with the mass market’s rate of change and transition.

Recommendation: Do not be complacent that decisions made based on the IMO’s 2018 initial strategy are sound, understanding and factoring in the new strategy’s targets – especially the 2030 and 2040 targets is crucial.

Beyond IMO 

Shipping’s transition has never been just about what happens at the IMO, it is about the interplay between various public and private behaviour and levers. Opportunities and risks exist in each of these spaces and where they overlap, interfere or reinforce, UMAS supplies.

Recommendation: Develop your own decarbonisation strategy factoring all the levers of transition e.g. how does IMO’s revised strategy and future regulation, in Implications of the Revised IMO GHG Strategy for national, regional and corporate action combination with national/regional/corporate actions create opportunities and risks?

To remain relevant, national, regional and corporate actions need to move to clear 1.5oC alignment otherwise they will lag behind IMO’s ambition and risk creating confusion, opacity, inaction and admin burden to the transition

… said Dr. Tristan Smith, Reader at UCL Energy Institute, Director of UMAS


Whilst many industry leadership efforts and initiatives have been ambiguous about fully aligning with the UN’s guidance on how to avoid being labelled as ‘greenwash’, the pressure to align with 1.5°C is now even higher – otherwise what is being stated as leadership may be nothing more than compliance.

UMAS supports that currently, none of shipping’s existing corporate initiatives (including Poseidon Principles, Sea Cargo Charter, cargo owners for Zero Emissions Vessels), reference or align with the UN’s guidance on integrity of voluntary net zero commitments.

Recommendation: Apply and align with the UN’s High-Level Expert Group on the Net-Zero Emissions Commitments of Non-State Entities guidance on integrity (alignment with IPCC’s science on 1.5°C, including all scopes (1-3), use of interim targets and disclosure).

Much remains to be desired of industry initiatives. Our analysis shows none are aligned with the latest climate science in terms of their ambition and lack transparency. This needs to change, for example by following guidance published by the UN for private actors, or the very actors that present themselves as the vanguard face the risk of being called out for greenwashing

… said Dr. Nishatabbas Rehmatulla, Principal research fellow at UCL and Principal Consultant at UMAS

National action 

The time window for national actions has been compressed, and their role/value is changing. UMAS believes that there will always be a need for action on the domestic fleet (which is not covered by IMO regulation) so domestic maritime regulation remains important. Specifically, UMAS notes the following:

  • For international shipping servicing a country, there is still a gap in legislative clarity until 2027/28 when IMO mid-term measures enter into force. So stimulating early adoption and first movers in that period remains important.
  • Post 27/28, the IMO is likely to increasingly become the driver of the business case to invest, so relevance in that period can only be secured if actions significantly exceed the IMO’s ambitions.
  • This limits the period of relevance from national action hoping to ‘kick-start’ the sector’s transition. Or seen from another angle, countries hoping to use policy to achieve a national strategic advantage in shipping’s transition now have only a small window of time to do so before there will be much wider competition.

Recommendation: Bring forward plans for national action to be particularly focused on the period from now to 2027/28, develop or align action on domestic shipping. Lower income countries with an opportunity in transition now have an urgent need to develop national strategies that can unlock the associated investment.

Green corridors 

UMAS also notes that as we approach the second anniversary of the Clydebank Declaration, there have been many announcements of Green Corridors, but many of these remain in pre-feasibility or feasibility stages.

Just as for other national actions that could be undertaken in advance of shipping’s IMO-regulated transition, unless these are in place and running on zero or near-zero solutions significantly before 2030, the rationale and justification for such initiatives will no longer be valid as they will be making compliance steps.

Recommendation: Bring forward public/private collaborations to ensure these have a chance of fulfilling their roles during the 2020’s and establish a norm/definition that Green Corridors must have zero or near-zero GHG operation significantly before 2030


The stringency and role of currently announced regional policies (e.g. inclusion of shipping in EU ETS, EU fuel standards), now appears of very low salience/relevance to business cases, relative to what should be anticipated from the IMO’s mid-term measures.

The partial coverage of a ship’s annual fuel consumption (unless operating solely in EU), and the limited potential to incentivise zero or near zero emissions in advance of the IMO’s regulations, all question their additionality in the transition, UMAS explains. The EU ETS policy increases the inequity of the transition (increasing cost to developing country trade, whilst transferring these revenues to high income countries).

Recommendation: The policies need to be revised to much higher stringency and reconsidered in how they can more effectively integrate and support the IMO’s Revised Strategy.

To remind, regarding the revised GHG strategy by the IMO, UMAS had published the paper An overview of the discussions from IMO MEPC 80 and Frequently Asked Questions, which can be found here.

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