Six shipping organisations highlight IMO’s CII inadequacies

Not since the introduction of the global sulphur cap at the start of the decade has an International Maritime Organization (IMO) regulation attracted such criticism as the Carbon Intensity Indicator (CII).

Six of shipping’s top organisations have issued a joint industry policy statement this week on how the CII can be tweaked, the latest in a slew of recommendations for the controversial legislation.

The CII, which came into effect on January 1, 2023, is a measure used in the maritime industry to assess and track the carbon emissions of ships, measuring a ship’s emissions per ton-mile or per passenger-mile. Ships are rated from A to E in a way similar to how energy efficiency in household appliances are measured.

BIMCO, the International Chamber of Shipping, INTERCARGO, INTERTANKO, and the global association for cruise lines have issued their joint take on CII’s inadequacies this week as the regulation comes up for review soon.

With the CII ratings now delivered from flag states to shipowners, the six organisations questioned the CII’s accuracy and reliability.

The shipping bodies argue that the CII scheme must reflect the true efficiency rating for each ship.

The IMO’s Marine Environment Protection Committee (MEPC) at its 81st session in March 2024 publicly acknowledged that possibly inaccurate or misleading CII ratings could result in unintended adverse consequences for some ships, particularly with respect to business-critical decisions made by the finance, insurance, chartering, brokering and port sectors.

The shipping bodies are calling on the IMO to amend the current CII system to avoid unintended consequences that are contradictory to reducing overall GHG emissions. Indeed, the IMO has already received 78 proposals submitted by every sector of shipping, also calling for amendments to the CII.

The organisations have also called for public administrations, flag states, ports, and destinations to acknowledge that the current CII system has inherent shortcomings recognised by the IMO and may not accurately reflect the true environmental performance of ships.

The CII review process will take start at the MEPC in September, continuing through to December 2025.

CII has proven to be one of the IMO’s more controversial regulations, coming in for fierce criticism over the past couple of years.

Germany’s largest dry bulk operator Oldendorff Carriers released a detailed study into CII’s flaws, weeks ahead of the regulation coming into force.

They also considered three policy scenarios: current regulations, which only limit NOx emissions in some parts of the world; a scenario that adds ammonia emission limits over North America and Western Europe; and a scenario that adds global limits on ammonia and NOx emissions.

The researchers used a ship track model to calculate how pollutant emissions change under each scenario and then fed the results into an air quality model. The air quality model calculated the impact of ship emissions on particulate matter and ozone pollution. Finally, they estimated the effects on global public health.

In the end, they found that with no new regulations and ship engines that burn pure ammonia, switching the entire fleet would cause 681,000 additional premature deaths each year.