Climate Lobbying Overview: The International Chamber of Shipping (ICS) is actively lobbying global and EU shipping climate policy with mixed to negative engagement in 2020-22. While ICS has increasingly positive top-line messaging on climate policy in 2021-22, it has used its support for global climate regulations to oppose regional or national regulations, such as the inclusion of maritime transport in the EU Emissions Trading System (ETS), while advocating for a global $2 levy on fossil marine fuel to produce a dedicated research and development fund for shipping decarbonization.

Top-line Messaging on Climate Policy: In an October 2021 paper submitted to the IMO, ICS advocated that the IMO should consider a more ambitious target of net-zero CO2 emissions by 2050, which however excludes other greenhouse gases. Since committing to a net-zero CO2 emissions by 2050 target in November 2021, ICS has echoed its support for this goal, including in an October 2022 IMO submission paper. However, despite appearing to support the goals for the Paris Agreement in 2022, ICS has consistently used its support for global climate regulations, solely implemented through the IMO, to actively oppose more stringent national and regional climate legislation in 2020-22, such as in a consultation submission to the IMO in September 2021. ICS’s ‘100 Years Book’ appeared to argue that “the effectiveness of IMO…has also been placed under strain” due to regional regulations implemented by the EU. In a February 2021 EU consultation response, ICS further stated “the global industry is opposed to any unilateral measures at variance to what has been agreed globally by IMO”. However, in January 2022 testimony to the UK government, ICS Secretary General Guy Platten advocated for "more regulation" on climate at a global level through the IMO, including a market-based measure.

Engagement with Climate-Related Regulations: In September 2021, ICS submitted a paper to the IMO recommending a mandatory carbon levy per tonne of CO2 emitted by ships with major exceptions, stating that a “disproportionately high carbon price on shipping” should not be imposed. A March 2022 IMO submission also appears to emphasize ICS support for a global shipping levy with major exceptions, emphasizing concerns around cost, ambition and timing. In its May 2022 ‘Fuelling the Fourth Propulsion Revolution’ report, ICS echoed support for a global carbon levy. An October 2022 press release further clarified support for a CO2 tax on shipping fuel to support a "fund and reward" program for alternative fuels that would be “much lower” than 100 USD per tonne of CO2 for ships initially, which is then "subject to a 5-year review as increasing quantities of new fuels become available".

ICS has consistently opposed the inclusion of maritime transport in the EU ETS in 2020-22. In the EU’s November 2020 consultation on the ETS, ICS submitted comments stating that it “is opposed to any proposal for unilateral or regional regulation of international shipping which undermines the authority of IMO”, seeming to oppose the inclusion of maritime transport. ICS also wrote in its 2020 Annual Review that its “the application of an EU ETS to shipping would be counterproductive”. ICS Secretary General Guy Platten also appeared to express his opposition to the EU ETS proposal in July 2021, stating that “it cannot be equitable for non-EU shipping companies to be forced to pay billions of euros to support EU economic recovery plans”. ICS also appeared to oppose the inclusion of shipping in the EU ETS in its ‘100 Year Book’, published in June 2022.

In an October 2022 submission to the IMO, ICS also appeared generally supportive of a strengthened Energy Efficiency Design Index at the IMO, with unclear stringency levels, and a global GHG fuel standard. A November 2022 report, commissioned by ICS, also appeared to support policies promoting green hydrogen production, including mandates and production credits under the US Inflation Reduction Act, and called for the EU’s hydrogen target under RePowerEU to be “backed up with enabling policies”. However, in a February 2021 consultation response, ICS appeared unsupportive of the EU’s Renewable Energy Directive, advocating instead for global regulations through the IMO, a technology-neutral approach, and for the responsibility of compliance to be placed on fuel suppliers.

Positioning on Energy Transition: ICS appears to have frequently expressed support for the IMO to establish an International Maritime Research and Development Board (IMRB), including in a March 2022 submission to the IMO. The fund would be funded through a tax of USD 2 per tonne of marine fuel purchased for consumption by ships, and focus on research to accelerate the introduction of low-carbon and zero-carbon technologies and fuels. ICS further advocated for the IMO to adopt the IMRF proposal in March 2021 and April 2021 submissions to an IMO working group. Ahead of an upcoming IMO meeting in November 2021, ICS Secretary General, Guy Platten, urged for governments to adopt the IMRB proposal, citing how essential it will be to decarbonize the shipping industry. Platten further appeared to communicate support for an IMO IMRB in oral evidence to a UK Parliamentary Committee in January 2022. A November 2021 Bloomberg article further suggested that ICS supported the R&D proposal, noting it would be an effective carbon price of 62.4 cents per tonne. In an October 2022 submission to the IMO, ICS advocated for a ‘fund and reward’ system for ships using alternative maritime fuels, with unclear emissions reduction potential.

In May 2021, ICS released a report on the FuelEU Maritime initiative, appearing to argue that a mandate for a minimum share of low-carbon and renewable fuels for ships should not be introduced without first guaranteeing the availability of an adequate supply of such fuels. A February 2021 EU consultation response from ICS further described fuel standards under FuelEU Maritime as “unwelcome”. However, in an October 2022 submission to the IMO, ICS proposed a 5% target of total energy consumption to come from alternative fuels by 2030, without specifying which fuels count as ‘alternative’. Additionally, in a November 2021 ‘Zero Emissions Blueprint’ report, ICS appears to communicate support for the increased use of ‘zero-carbon fuels’ in shipping, including “hydrogen, ammonia, biofuels and electrification from renewable sources”. Furthermore, in November 2022, ICS commissioned a report which advocated in favour of using maritime to transport green hydrogen and ammonia to facilitate the wider energy transition, alongside supporting the expanded use of green hydrogen in shipping. Nevertheless, ICS’s ‘Shipping and New Technologies’ webpage, accessed in August 2022, appears to support liquid natural gas, alongside other alternative fuels, as a “medium-term” solution.