A new analysis by Opportunity Green warns that Japan’s proposed amendments to the IMO Net-Zero Framework (NZF) could undermine shipping’s decarbonisation objectives and weaken financial support for climate-vulnerable developing countries.

In its briefing, “Attempt to weaken the IMO Net-Zero Framework”, Opportunity Green argues that Japan’s latest proposal would significantly change the framework agreed in principle at MEPC 83 in April 2025, potentially weakening its ability to support the greenhouse gas (GHG) reduction objectives of the IMO’s 2023 Revised GHG Strategy.

According to the organisation, the proposal represents an insufficient compromise for countries seeking ambitious emissions reductions and equitable financial support, particularly Small Island Developing States (SIDS) and Least Developed Countries (LDCs).

Proposed changes to the IMO Net-Zero Framework

Under the NZF approved in April 2025, ships that fail to meet greenhouse gas fuel intensity requirements would be required to address compliance deficits through the purchase of Remedial Units (RUs) or, under specified conditions, the use of Surplus Units (SUs).

Revenue from the framework’s emissions pricing mechanism would be channelled into a dedicated IMO Net-Zero Fund to support zero- and near-zero-emission (ZNZ) fuels and technologies, as well as measures supporting a just and equitable transition.

Japan’s proposal would remove the Fund and make the purchase of Surplus Units the primary mechanism for addressing compliance deficits. Where insufficient units are available, shipping companies could instead make direct contributions to IMO-approved projects.

Opportunity Green argues that this approach would transfer greater influence over the allocation of climate finance from IMO Member States to private shipping companies, potentially affecting how financial support is distributed across the maritime sector.

Four risks were identified in the analysis:
#1 Weakening a just and equitable transition

Removing the Net-Zero Fund could reduce the availability of predictable financing for developing countries, particularly those facing disproportionate climate impacts and limited access to investment.

Opportunity Green argues that private-sector contributions cannot adequately replace a collective financing mechanism designed to distribute resources according to need.

#2 Reducing Member States’ influence over climate finance

Under Japan’s proposed approach, shipping companies could have greater discretion over which IMO-approved projects receive their contributions.

The analysis warns that larger fleet owners could direct funding towards projects connected to their own operations or supply chains, rather than towards countries requiring support for infrastructure, capacity building and climate resilience.

#3 Weakening incentives for zero-emission energy

Opportunity Green raises concerns that removing the Fund would also eliminate an important mechanism for rewarding the early adoption of zero- and near-zero-emission fuels and technologies.

According to the briefing, the absence of predictable financial support could create additional uncertainty for investment in alternative fuels and the infrastructure needed for their deployment.

#4 Undermining emissions-reduction incentives

The organisation also questions the implications for the Surplus Unit market.

It argues that allowing companies to meet compliance obligations through direct project contributions could reduce demand for Surplus Units, weakening the financial incentive for vessels to exceed their emissions-intensity targets.

Opportunity Green further warns that changes to the existing Remedial Unit pricing structure could increase uncertainty over compliance costs.

However, the central concern raised is not only how shipping companies would meet their future emissions obligations, but also who would control the financial resources generated by the framework and how those resources would support the wider maritime transition.

According to the organisation, Japan’s proposal could disadvantage climate-vulnerable developing countries by replacing predictable, collectively governed financing with arrangements more dependent on private-sector investment decisions.

Opportunity Green therefore considers the NZF architecture approved in April 2025 to be the strongest and most equitable option currently under consideration, arguing that it provides a clearer mechanism for supporting developing countries while maintaining incentives for emissions reductions.

The briefing calls on IMO Member States to retain the framework’s mandatory economic element, preserve collective decision-making over revenue distribution, protect the integrity of the Surplus Unit market and maintain the overall architecture of the approved NZF.

IMO negotiations approaching

The analysis comes ahead of further IMO discussions on the Net-Zero Framework, scheduled for 23–27 November 2026 during the 23rd meeting of the Intersessional Working Group on Reduction of GHG Emissions from Ships (ISWG-GHG 23).

The framework is then expected to be considered during the 85th session of the Marine Environment Protection Committee (MEPC 85), scheduled for 30 November–4 December 2026.

These negotiations will be important in determining the final structure of the framework, including the balance between compliance flexibility, emissions-reduction incentives and financial support for a just and equitable maritime transition.