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MARITIME POLICY
and Development Board (IMRB) and Fund than the shipping company, the shipping
(IMRF) to oversee an IMRD Programme to company is entitled to reimbursement from
accelerate the introduction of low-carbon that entity for the costs arising from the
and zero-carbon technologies and fuels, surrender of allowances. Nevertheless, the
according to paragraph 4.7.9 of the IMO shipping company remains responsible for
Initial Strategy on the Reduction of Green surrendering allowances (Article 3ga and
House Gas Emissions from Ships. Article 12 of the Directive), Monitoring and
Furthermore, on 25 October 2022, in a reporting emissions from maritime transport;
paper to the IMO, the ICS proposed a Verification and accreditation of emissions
“fund and reward” system to catalyse the from maritime transport; Administering
adoption of alternative fuels, which currently authority in respect of a shipping company;
cost at least two or three times more than Reporting and review.
conventional marine fuels (F&R proposal). In regulating the above, the Proposal
The proposal combines elements of various Directive took into consideration the
recent GHG reduction proposals by several following:
governments, plus a flat rate contribution – The need to regulate shipping
system previously proposed by ICS and emissions from vessels below
INTERCARGO. 5,000 gross tonnage; therefore,
the Commission was asked to
EU-ETS revision - inclusion shipping in the “fit for present a report to the European
55” package- provisions for transferring the ETS Parliament and the Council
costs from shipping companies to other entities later than 31 December 2026,
In July 2021, the European Commission examining the feasibility and cost-
adopted legislative proposals for reducing effectiveness of the inclusion of
greenhouse emissions by at least 55% by emissions from ships below 5,000
2030, extending the EU-ETS to maritime gross tonnage in the Directive.
transport. – The need to regulate the following:
In particular, the Proposal for a Directive of in line with the “polluter pays”
the European Parliament and the Council principle, the shipping company
(COM/2021/551 dated 14.7.2021), as amended should be entitled, under national
on 30 June 2022, adopted, among other law, to claim reimbursement
things, the following basic provisions: for the costs arising from the
Scope of application to maritime transport surrender of allowances from the
activities; Phase-in of requirements for entity that is directly responsible
maritime transport: Shipping companies for the decisions affecting the CO2
shall be liable to surrender allowances emissions of the ship.
according to a schedule; Provisions for the
transfer of the ETS costs from the shipping In conclusion, the above emission reduction
company to another entity: the Member system is still being processed, discussed
States shall take the necessary measures to and developed. The author’s opinion is that
ensure that when the ultimate responsibility it should be guided by IMO experts and
for the purchase of the fuel or operation regulated by special maritime legislation.
of the ship is assumed by a different entity
2 Press release ICS, 25th October 2022, www.ics-shipping.org, “International Chamber of Shipping proposes global CO2 reduction
fund to reward “first moves” using low emission fuels”. Ναυτικά Χρονικά, “Απανθρακοποίηση της Ναυτιλίας: Η πρόταση του ICS”,
26 Οκτωβρίου 2022.
3 See, also, “the Joint letter of ECSA, the Advanced Biofuels Coalition, CLECAT, CLIA, ESPO, eFuel Alliance, ENMC, ESC, EWABA,
FEPORT, SEA Europe calling for the earmarking of the EU ETS revenues to the European maritime sector to foster its decarbon-
ization”, in ECSA website, “Maritime industry unites to call for earmarking of ETS revenues”, 29th September 2022.
Also, in ECSA website, “Provisional ETS Agreement: Earmarking of revenues can mark turning point for European shipping’s de-
carbonization.
4 Finally, on 18 December 2022, the European Parliament and Council came to an agreement on the revision of the EU Emission
Trading System, extending to shipping from 1st January 2024 (preliminary agreement to include shipping).
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