Intro to the GFS
In mid-October 25, IMO decided to delay the adoption of its Net Zero Framework (NZF).
An extraordinary session of the IMO’s Marine Environment Protection Committee (MEPC/EC.2) concluded with a decision to delay the adoption of the planned NZF until October 2026.
The implications of this decision remain uncertain, but three possible outcomes are emerging:
The framework is adopted in October 2026 as currently planned (or with minor adjustments).
The NZF undergoes significant revisions, resulting in further delays.
The implementation of the NZF is ultimately abandoned.
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.
