Climate Policy Engagement Analysis
Climate Policy Engagement Overview: The European Community Shipowners’ Associations (ECSA) appears to be actively lobbying EU climate policy with negative engagement in 2020-22. Notably, it seems to be opposing the inclusion of shipping in the EU Emissions Trading Scheme and advocating against an EU tax on bunker fuel in the EU’s Energy Taxation Directive.
Top-line Messaging on Climate Policy: In 2021, an ECSA report supported “the complete decarbonization of international shipping as soon as possible”, without specifying a date for net-zero emissions. A position paper from ECSA in 2020 also stated support to reduce shipping’s GHG emissions with “the ambitious targets agreed for the sector” by the International Maritime Organisation (IMO), “consistent with the 1.5 °C UNFCCC climate change goal.” However, while ECSA stated support for the IMO’s 50% GHG emissions reductions target for 2050 on its corporate website in 2021, it is unclear whether this aligns with IPCC-demanded emissions reductions.
In an April 2020 press statement, ECSA urged the EU to prioritize the recovery of the shipping industry during the COVID-19 pandemic before committing to a European Green Deal. Moreover, in 2019-21 the organization appeared to have consistently used support for global GHG regulations for shipping to oppose more stringent EU-level climate policies, including in multiple 2020 EU consultation responses.
Engagement with Climate-Related Regulations: During 2019-21, evidence suggests ECSA has consistently opposed reforms to the EU ETS to expand its coverage to include shipping. In a 2020 report, ECSA emphasized carbon leakage concerns, and in a February 2021 EU ETS consultation response ECSA stated that “an EU ETS for shipping would undermine the international negotiations at the IMO level”, “increase political tension with third countries” and “have relatively little impact on the sector’s global GHG emissions”. ECSA further suggested in the same response that the proposed EU ETS for shipping should have a “limited” geographical scope to avoid political tension with third countries. In late 2021, ECSA appeared to expand on its recommendations for the proposed EU ETS for shipping, advocating for a dedicated marine fund to be set up under the ETS that would “stabilize the carbon price”. An updated position paper from ECSA in March 2022 further appeared to oppose the inclusion of shipping in the EU ETS, while advocating for numerous amendments to be made if applied that may weaken the stringency of the proposal. These include advocating that should have a limited geographical scope, that it included a phase-in period for emissions allowances and that it applies special conditions to ice-class vessels.
In a November 2021 consultation on the EU Renewable Energy Directive (RED), ECSA supported weakening the policy by advocating for “substantially” increasing the multipliers on the renewable energy used by marine fuel suppliers, making compliance with RED targets easier for the maritime sector.
Positioning on Energy Transition: The European Community Shipowners’ Associations appears to not support energy transition policy for the shipping sector. In a 2020 EU consultation response and a 2019 position paper, ECSA advocated against] a fuel tax on bunker fuels for maritime transport. However, in a 2020 position paper ECSA stated general support for the decarbonization of shipping, including through electrifying ferries. In an April 2020 EU consultation, ECSA appeared to oppose fuel mandates as part of the FuelEU Maritime initiative, supporting instead a "technology neutral" fuels approach for shipping that includes "non-prescriptive requirements" on the type of fuel used.