Intro to the GFS
The regulation will enter into force on January 1st 2028, subject to a successful final vote in October 2025.
In April 2025, the IMO’s Marine Environment Protection Global Fuel Standard Mechanism Committee (MEPC 83) adopted in draft form the IMO NetZero Framework. This introduces a GHG global fuel standard (GFS) that will apply to all ships above 5,000 GT engaged in international trade.
Similarly to the FuelEU, the scheme sets annual GHG intensity limits for marine fuels on a well-to-wake basis, measured in gCO2eq/MJ.
There are two main compliance thresholds:
I. Base GFI Target – the minimum performance level vessels must meet.
II. Direct Compliance Target – a more ambitious target that, if exceeded, unlocks tradable surplus units (SUs).
If a vessel exceeds either target, it must purchase Remedial Units (RUs). The vessel must purchase Tier 1 RUs (priced at $100/tCO2eq) if its annual fuel intensity meets the Base GFI target but fails to meet the Direct Compliance Target. The vessel must purchase Tier 2 RUs (priced at $380/tCO2eq) if its annual fuel intensity fails to meet the Base GFI target.
