MEPC 84: NGOs Call for Black Carbon Action on Curb Shipping’s Arctic Impacts
Ahead of next week’s meeting of the International Maritime Organization’s (IMO) Marine Environment Protection Committee (MEPC 84, April 27-May 1), the Clean Arctic Alliance is calling on Arctic states to step-up on efforts to regulate black carbon emissions from international shipping and define the geographical extent for a polar fuels measure, and for IMO member states to act on a number of crucial issues, including adoption of the North East Atlantic Emission Control Area, underwater noise and marine pollution from scrubbers.
MEPC 84’s extensive agenda will address several forms of shipping impacts on the marine environment, including greenhouse gas emissions via IMO’s Net Zero Framework (NZF) and Carbon Intensity Indicator (CII). There are however other important matters addressing international shipping’s impact on climate and air pollution:
Black Carbon and Polar Fuels Measure
A paper submitted to MEPC 84 by eNGOs, International efforts to reduce emissions of Black Carbon, calls on IMO states to consider the evidence it presents ahead of taking action to address the impact on the Arctic of emissions of black carbon from international shipping. The Arctic is warming four times faster than elsewhere on Earth; in March, Arctic winter sea ice tied for its lowest measured level. Black carbon is a short-lived climate pollutant, produced by the incomplete burning of fossil fuels, and accelerates melting if deposited onto snow and ice and has a disproportionate impact when released in and near to the Arctic (more information below).
This paper comments on the latest polar fuel concept discussions, and highlights ongoing research and a number of recent initiatives focused on reducing black carbon emissions from a variety of sources due to the impact on climate, on the environment and communities and on the Arctic.
“While decades of Arctic and global efforts to reduce black carbon emissions have made recent headway, the IMO’s lack of progress is a distinct outlier and may draw action from other internal fora to ensure that shipping’s black carbon emissions are also curbed”, said Dr Sian Prior, Lead Advisor to the Clean Arctic Alliance.
“February’s PPR 13 meeting considered a concrete proposal on polar fuels which would replace all residual fuel use in the Arctic with cleaner distillate fuels or new alternative fuels or forms of propulsion”, added Prior. “The IMO now must consider the appropriate geographic scope for such a polar fuel concept, in order to ensure effectiveness of the proposed measure – countries need to know where on shipping charts that the rules will apply.”
“It is essential that IMO members urgently work together on defining the geographic application of this new measure between now and November’s MEPC 85, so they can submit a new or amended proposal to an IMO meeting in early 2027 – PPR 14”, said Prior.
“This is an opportunity for governments, led by Arctic governments – to use multilateralism to rise above the current geopolitical and energy turmoil by taking action to curb shipping’s black carbon impact on the Arctic.”
Emission Control Areas
Agreed in April 2025, the IMO’s North-East Atlantic Emission Control Area (ECA) should have been adopted during a special meeting (MEPC/ES.2) of the IMO in October 2025, but was deferred to MEPC 84.
“IMO Member States must, without further delay, adopt the proposal for a new North East Atlantic Ocean Emission Control Area, the world’s biggest ECA for sulphur and nitrogen oxide ”, said Carolina Silva, Shipping Policy Officer at ZERO, a Clean Arctic Alliance member. “Implementation of this ECA will have important benefits for the climate and for the health of communities throughout the area covered and also for the Arctic.”
“The North-East Atlantic ECA will significantly and cost-effectively reduce ships’ emissions, improve air quality, and contribute to improving public health and environmental protection in the north-east Atlantic region, including the Arctic waters around Greenland and Iceland”, added Silva.
By restricting the use of the most polluting shipping fuels, the North East Atlantic Emission Control area will see SOx emissions cut by up to 82% and particulate matter by 64%, which will avoid thousands of premature deaths by 2050, and have a co-benefit of reducing the black carbon emissions which have a detrimental impact on Arctic snow and ice.
“The positive impacts from adoption of this emission control area will be further bolstered by action on black carbon by the IMO”, said Silva. “Black carbon is one of the longest, unresolved issues running at the IMO, and must be dealt with without delay.”
“The unfortunate delay on the assessment of options and resources to support an IMO-commissioned underwater noise study – which was due to be prepared for MEPC 84 – is extremely frustrating considering the solution-driven momentum from proactive member states and industry stakeholders is now”, said CT Harry, Senior Ocean Policy Analyst at the Environmental Investigation Agency, a member of the Clean Arctic Alliance. “The delay in even assessing the means for a global noise study undercuts any assurance that an extended experience building phase will be able to deliver real progress in underwater noise reduction”.
“The Clean Arctic Alliance is calling on IMO member states to voice their strong support for the study and for policy discussion on underwater noise at MEPC 85 and to submit proposals to MEPC 85 for multiple instruments to drive forward underwater noise policy”, said Harry.
During PPR 13 in February, IMO member states made no progress on scrubbers use, only extended a time frame for work on regulation, while member states and interested parties were 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”, said Sam Davin, Head of Delegation to MEPC 84 for WWF, a Clean Arctic Alliance member. “The IMO must put in place global regulation surrounding scrubber use or scrubber wastewater discharges.”
At MEPC 84, eNGOs WWF and Pacific Environment – both Clean Arctic Alliance members – are seeking views on a technology-neutral, goal-based approach to discharges using a fuel-based compliance approach – using scrubbers would only be permitted if the environmental performance of scrubbers was equivalent to the use of cleaner fuels i.e. resulted in no pollutant discharge into the ocean and reduced air pollution in line with emissions from cleaner fuels).
About 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 Programme (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-sulphur residual fuels (VLSFO, ULSFO) or distillate fuels/blends (MGO, MDO) reduces BC emissions, however switching to low sulphur 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-sulphur 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 recognise 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.
Black carbon is a short-lived climate pollutant, produced by the incomplete burning of fossil fuels, with an impact more than sixteen hundred times that of CO2 over a 20 year period. It makes up around one-fifth of international shipping’s climate impact. Not only does it contribute to warming while in the atmosphere, black carbon accelerates melting if deposited onto snow and ice – hence it has a disproportionate impact when released in and near to the Arctic.
The melting snow and ice exposes darker areas of land and water and these dark patches then absorb further heat from the sun and the reflective capacity of the planet’s polar ice caps is severely reduced. More heat in the polar systems – results in increased melting. This is the loss of the albedo effect.
Declines in sea ice extent and volume are leading to a burgeoning social and environmental crisis in the Arctic, while cascading changes are impacting global climate and ocean circulation. Scientists have high confidence that processes are nearing points beyond which rapid and irreversible changes on the scale of multiple human generations are possible. Scientists say it is now too late to save summer Arctic sea ice, and research has shown that “preparations need to be made for the increased extreme weather across the northern hemisphere that is likely to occur as a result.”
Black carbon also has a negative impact on human health including premature death and harmful effects on the cardiovascular system (heart, blood and blood vessels), and recent research has found black carbon particles in the body tissues of foetuses, following inhalation by pregnant mothers.
The need to reduce emissions of black carbon because of both the climate and health impacts has been long recognised. On land, considerable effort has been made to ban dirtier fuels in power stations, to install diesel particulate filters on land-based transport, and to improve the burning of dry wood – all to reduce emissions of black carbon and improve air quality. However, at sea the same efforts have not yet been made.
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