PPR 13: NGOs criticize IMO’s slow progress on cleaner fuel rules for Arctic shipping

As a meeting of the International Maritime Organization’s (IMO) Pollution Prevention and Response committee closes (PPR 13, February 9-13), the Clean Arctic Alliance welcomed progress and support for an Arctic fuel measure, which would reduce black carbon emissions from international shipping in the Arctic, but expressed disappointment that an expedited process was deemed impossible - with further progress delayed for a full year. Meanwhile, the outcome on regulating exhaust gas cleaning systems (scrubbers) was even more disappointing, with no progress at this meeting - and further delay.

A key paper submitted to PPR 13-6, by Denmark, which represents Greenland at the International Maritime Organization, along with France, Germany and the Solomon Islands, proposed a new mandatory Arctic fuel measure for MARPOL Annex VI, requiring that ships sailing in the Arctic use cleaner fuels with low emissions of black carbon. The proposal received widespread support this week, however during discussion in a working group, it became apparent that some refinement was needed, while a handful of IMO member states opposed using the proposal as the basis of a new regulation. Furthermore, there was no discussion of the geographic area in which a new regulation would be applied.

“In the coming year, IMO member states - especially Arctic states - must urgently drive further progress on an Arctic fuel proposal, which sets out the characteristics of fuels that would be considered suitable for use in the region - so-called polar fuels”, said Dr Sian Prior, Lead Advisor to the Clean Arctic Alliance. “While progress was made this week on an Arctic fuel measure -with many countries showing support, after 15 years of stagnation by the IMO on polar fuels, this is far from what is needed to urgently address the clean-up of air polluting emissions from international shipping and thus curb their impacts on the Arctic. In particular, it is essential that the IMO and its members move ahead and agree on the geographic application of a new measure this year.”

At the beginning of this week, the Clean Arctic Alliance called on IMO Member States to support the PPR 13-6 proposal in a working group at PPR 13, and subsequently forward it to the Marine Environment Protection Committee for approval this year - but for now IMO member states and interested parties are invited to submit a new or amended proposal to the next meeting in early 2027.

“Emissions of black carbon from shipping have a disproportionate impact in the Arctic, by contributing to the melt of sea and land-ice leading to global consequences. Black carbon emissions also increase the risk of respiratory and cardio-vascular illnesses in local communities”, added Prior. “This past December saw the lowest Arctic sea ice extent in the 47-year satellite record - melting of the Arctic sea ice results in loss of ice habitat, important for wildlife and Indigenous communities in the Arctic, while the melting of land-ice - glaciers - contributes to rising global sea-levels. We can not wait another year before taking the next steps”.

“The Clean Arctic Alliance welcomes the wide support for characterizing polar fuels suitable fuels for use in the Arctic using fuel density, viscosity and carbon residue maxima to help limit sooting," said Bill Hemmings, Black Carbon Advisor to the Clean Arctic Alliance. “Polar fuels will prevent the use of residual fuels or blends including heavy fuel oil (HFO) used by many ships worldwide today, often in conjunction with exhaust gas cleaning systems (scrubbers), are now on the horizon. This would lead to the exclusive use of existing, widely available distillate fuels and new low carbon fuels which are beginning to come onto the market, resulting in lower emissions of black carbon, it really is low-hanging fruit for the IMO.”

Scrubbers

During PPR 13, IMO member states achieved no progress on scrubbers, with an extended time frame granted for carrying out the work, and member states and interested parties simply invited to submit proposals to PPR 14 in 2027. The lack of IMO regulation of scrubbers discharges is leading to an increasing patchwork of regulation which leads to fragmentation, confusion and environmental destruction.

“The Clean Arctic Alliance is bitterly disappointed by the IMO’s failure during this week to consider a proposal from EU Member States to protect Particularly Sensitive Sea Areas (PSSAs) as set out in PPR 13/7/2 to regulate scrubber discharges, and that our call for a resolution as an interim step towards regulation was ignored”, said Eelco Leemans, Technical Advisor to the Clean Arctic Alliance. “While a considerable number of member states supported regulation, some delegates clearly tried to smokescreen the issue, by asking for ‘evidence’ of scrubber wastewater pollution. However there is already overwhelming evidence - so there is no reason to not regulate scrubber pollution. The Clean Arctic Alliance is calling on ambitious member states to keep pushing for discharge bans, either in territorial seas, PSSAs and or Emission Control Areas.”

Sewage

Ahead of PPR 13, the Clean Arctic Alliance called on IMO member states to support stringent sampling and monitoring requirements for sewage treatment systems for existing ships as well as new builds, to ensure that they are fit for purpose, and support yearly review of all sewage treatment systems.

PPR 13 did make some progress this week on two key elements of work including the sewage management plan and the sewage record book. The meeting however hit a roadblock when attempting to discuss type approval for sewage treatment plants, while there was not enough time to discuss sampling/indicative monitoring on existing ships, which was thus put off until PPR 14.

“During this week’s meeting, IMO member states made progress on key elements including completion of the sewage record book and the sewage management plan”, said Sarah Bobbe, Senior Manager, Arctic Program at Ocean Conservancy, a member of the Clean Arctic Alliance. “However, some member states continue to push back against progress on other important elements, including improving the type approval process for sewage treatment plants, as well as any discussion of sampling and indicative monitoring of existing ships. These IMO members do not want to be held accountable for having their existing ships discharge properly treated sewage, even despite a study from the Netherlands stating that 97 percent of ships are not compliant with current regulation. This has to change.”

The Clean Arctic Alliance is calling on IMO member states to support stringent sampling and monitoring requirements for sewage treatment systems for existing ships as well as new builds, to ensure that they are fit for purpose, and support yearly review of all sewage treatment systems. See PPR 13/10/2: Revision of Marpol Annex Iv and Associated Guidelines – Comments on documents PPR 13/10, PPR 13/10/1 and PPR 13/INF.17.

Black carbon emissions in the Arctic

A new report by Energy and Environment Research Associates (EERA), commissioned by the Clean Arctic Alliance, Black Carbon Emissions from Ships in the Arctic 2019 – 2024, provides a comprehensive analysis of tank-to-wake Black Carbon (BC) emissions from Arctic shipping using three geographic definitions: a latitudinal band north of 60oN (excluding the Baltic Sea and Gulf of Alaska), the Polar Code Arctic waters, as well as a broader ecological boundary defined by the Arctic Monitoring and Assessment Program (AMAP). It estimates BC emissions for the years 2019, 2022 and 2024.

The report examines the seasonal patterns of Arctic shipping routes, profiling ship characteristics, fuel consumption by EEZ and ship type as well as energy use. Historical estimates included in the report show how Arctic shipping activity and associated emissions have changed over time, while forecasts reveal how growth in emissions could affect the Arctic, and inform decisions on fuel choices.

Based on the report, it is clear that distillates are the dominant fuel choice in the Arctic. However, residual fuel use remains present and is increasing as ship traffic grows and receding sea ice opens new waterways. Arctic routes, including the Northern Sea Route (NSR) and North-West Passage (NWP), are seeing increasing traffic that passes through the Polar Code region, as such these activities will be captured when the Arctic HFO ban goes into effect. Full enforcement of the ban is not scheduled until 2029, and because its scope is limited to the Polar Code area, a considerable volume of traffic that affects the ecologically-defined Arctic region may still continue to utilize HFO. Norway’s Exclusive Economic Zone (EEZ) has the highest BC emissions within the 60°N and AMAP Arctic areas, but sees minimal reductions (≤ 2.1%) under the ban due to the Polar Code boundary's limited reach.

Switching from HFO to lower-sulfur residual fuels (VLSFO, ULSFO) or distillate fuels/blends (MGO, MDO) reduces BC emissions, however switching to low sulfur residual fuels instead of distillates does not produce the same level of reductions. Even with full implementation of the HFO ban within the Polar Code region, the BC reductions remain limited due to already widespread use of distillate. Even under an optimistic assumption that all ships shift entirely to distillates, rather than low-sulfur residual fuels once the ban takes effect, this analysis finds a 2.4 to 5.0% decrease in total BC emissions, depending on geographical scope. Greater reductions in Arctic BC emissions could be achieved through stronger regulatory measures. While ship activity is increasing in the Polar Code region, the highest concentration of traffic falls within broader Arctic geographical scopes, along coastal areas with dense port activity, especially concentrated along Norway. Ship traffic is however growing throughout the Arctic region and associated Black Carbon emissions have grown by 47% in the five years from 2019 to 2024.

The geographic scope of the Arctic fuel measure proposed for inclusion in MARPOL Annex VI is yet to be decided. The scope is proposed to include waters north of 60oN latitude, which would also encompass all Polar Code Arctic waters. The Arctic Council’s AMAP or AHDR boundaries are possible alternatives, but it is important to recognize that restricting a measure to the same geographic scope as the Arctic HFO prohibition in MARPOL Annex I would not result in any beneficial outcome in terms of air pollution. The Clean Arctic Alliance has prepared more information on potential geographic scopes which is available in PPR 13/6/3.

In the Atlantic part of the Arctic, over 366,000MT of residual fuel use in 2024 was beyond the Polar Code Arctic waters. The largest share of residual fuel burn in the Atlantic Arctic was in the Norwegian Sea EEZ (over 70%), with 9.6% in Russia’s EEZ, 9% in Iceland’s EEZ, 6.5% in Greenland’s EEZ and 1% in the UK’s EEZ. It is also worth noting that the largest percentage of Arctic shipping is flagged to Norway with some 25% being international ships in its NIS registry. Most EU MRV shipping operating in the Arctic is expected to approach the Arctic via the North Sea meaning either a 60oN latitude geographic scope or an AMAP boundary geographic scope would include these ships.

The proposal in PPR 13/6 also resolves concerns around potentially catastrophic Arctic fuel spill cleanup due to low pour point of blended fuels, voiced by Norway and Iceland at previous sessions of PPR and MEPC.