Uncertainty in Maritime Decarbonization Regulations and
How the Maritime Industry
Should Prepare and Respond

Since the final adoption of the IMO Net-Zero Framework was postponed last year, the international community has continued to seek a new consensus. At MEPC 85, scheduled for late November, and in the discussions that follow, the future direction of the IMO Net-Zero Framework is expected to be revisited in light of the various concerns and proposed amendments raised to date. At present, several possibilities remain open, including maintaining the existing framework, making partial adjustments, or introducing further changes to the timeline, making the eventual outcome difficult to predict.

However, the uncertainty surrounding the IMO Net-Zero Framework does not mean that the overall direction and momentum of maritime decarbonization are weakening.

In Europe, the EU ETS and FuelEU Maritime are already in full operation, and the regulatory framework continues to evolve toward more detailed requirements and implementation mechanisms. The first compliance cycle of FuelEU Maritime, examined in this issue, also demonstrates that the regulation has entered a stage where it is beginning to influence actual shipping operations, costs, and fuel choices. In the first compliance year, pooling emerged as a major compliance option, while the trading of surpluses also began to function as a real market mechanism.

The pressure for decarbonization is also no longer coming solely from regulators. Automotive OEMs, global manufacturers, and cargo owners are strengthening efforts to reduce greenhouse gas emissions across their supply chains and to meet ESG objectives. As a result, the carbon performance of maritime transport is increasingly becoming an important element of competitiveness. At the same time, financial markets are increasingly incorporating ESG considerations into investment and lending decisions, making the decarbonization strategies of shipping companies and shipbuilders increasingly relevant to financing and investment.

Maritime decarbonization, therefore, should not be viewed as something determined by a single IMO regulation. Rather, it is being driven collectively by regional regulations such as those of the EU, the supply-chain requirements of global cargo owners, ESG expectations from financial markets, and continuing changes in technology and market conditions.

In this issue, we look at what the maritime industry should prepare for amid these changes from a number of different perspectives.

First, in Insights, we examine the key considerations for marine SMR technology and the latest developments in international regulation. Marine nuclear energy is attracting attention as a long-term decarbonization option because it produces no direct CO₂ emissions during operation. At the same time, its practical application will require a wide range of challenges to be addressed, including reactor-vessel integration, safety under marine operating conditions, regulatory and licensing frameworks, operational infrastructure, and social acceptance. In particular, as international efforts such as the revision of the IMO Nuclear Code and the IAEA ATLAS project gain momentum, marine nuclear technology is gradually moving beyond technology development toward the establishment of a regulatory framework for practical deployment.

The second Insights article analyzes the first compliance cycle of FuelEU Maritime. The widespread use of pooling in the first compliance year demonstrates how regulatory compliance and cost optimization are already working in practice. At the same time, it is important not to base long-term fuel transition strategies solely on the relatively modest reduction targets and current surplus market conditions. As GHG intensity targets are progressively tightened and additional requirements, including RFNBO use and zero-emission energy use at berth, are introduced, investment decisions concerning alternative fuels and energy-efficiency technologies are also likely to change.

In this issue’s interview, we take a closer look at methane slip reduction technology, one of the key challenges associated with LNG. While LNG continues to serve as a practical transition fuel, the inclusion of CH₄, in addition to CO₂, in regulatory frameworks means that methane slip reduction performance is becoming an increasingly important factor in determining the GHG competitiveness of LNG-fuelled ships and engines. The characteristics of methane slip under different engine types and operating conditions, together with the technologies being developed to reduce it, will be among the key factors shaping the future role of LNG.

I would also like to extend my special thanks to Senior Vice President Minho Kang of HD Hyundai Heavy Industries for sharing his extensive experience and valuable insights on LNG engines and methane slip reduction technologies despite his busy schedule. His practical perspectives, built on real-world technology development experience, have greatly enriched this issue.

In Regulatory Updates, we examine the latest proposed revisions to the EU’s maritime carbon regulations. The EU is proposing to expand the role of EU MRV as a common data and verification framework and to make the implementation of the EU ETS and FuelEU Maritime more consistent around this common basis. The proposals also include an expansion of scope for certain ship categories, as well as procedures to review consistency and potential double burdens between EU measures and any future global IMO measures.

Inside KR highlights a range of KR activities aimed at turning maritime decarbonization into practical projects. These include engagement with global customers through overseas committees, cooperation on green shipping corridors following the successful delivery of the world’s first commercial ammonia-fuelled vessel, joint development of an LNG carrier equipped with wind-assisted propulsion, and joint development of an LNG bunkering vessel. These initiatives demonstrate KR’s efforts to move beyond regulatory compliance and support the practical application of new decarbonization technologies and services.

The future of the IMO Net-Zero Framework remains uncertain. The form of the regulation and its implementation timeline may change, and technology choices will continue to evolve depending on economics and market conditions.

But the way the maritime industry should prepare for decarbonization is not uncertain.

EU regulations are already a reality. Automotive OEMs and global cargo owners continue to strengthen their requirements for supply-chain decarbonization. Financial markets are also increasingly viewing ESG as an important factor in evaluating companies and projects.

What is needed now, therefore, is not to wait for the outcome of a particular regulation, but to secure the technologies, capabilities, and options necessary to respond flexibly to different regulatory and market scenarios.

Rather than waiting for uncertainty to disappear, now is the time to prepare for whatever changes may come.