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A Maritime Book-and-Claim Compliance Pathway for the IMO Net-Zero Framework

Rebelo, P. T. ORCID: 0000-0002-7465-7529 (2026). A Maritime Book-and-Claim Compliance Pathway for the IMO Net-Zero Framework. Climate Law, 15(3-4), pp. 293-312. doi: 10.1163/18786561-bja10074

Abstract

The proposed International Maritime Organization Net-Zero Framework (NZF) will establish a global fuel standard for international shipping through amendments to MARPOL Annex VI. The NZF integrates a progressively tightening greenhouse gas fuel intensity (GFI) requirement with an economic element that applies a two-tiered charge on any greenhouse gas (GHG) emissions exceeding those limits. Effective implementation of the NZF will require both technology pathways addressing infrastructure, scalability, retrofits, and cost competitiveness, and compliance pathways that enable the regulated deployment of zero or near-zero fuels. Among these, Book-and-Claim (B&C) systems have emerged as a promising but underexplored compliance option for maritime decarbonization. B&C models allow entities to purchase and claim emissions-reduction credits independently of the physical fuel supply chain, thereby decoupling physical fuel consumption from the associated environmental claim. While not currently incorporated into any maritime regulatory instrument, B&C schemes are gaining traction in the voluntary markets. This article assesses the viability of B&C systems as a compliance pathway under the NZF GFI Standard, arguing that regulatory design can mitigate the legal vulnerabilities observed in voluntary carbon market products and enable B&C to function as an integrated compliance tool.

Publication Type: Article
Subjects: G Geography. Anthropology. Recreation > GE Environmental Sciences
H Social Sciences > HC Economic History and Conditions
H Social Sciences > HD Industries. Land use. Labor
H Social Sciences > HN Social history and conditions. Social problems. Social reform
K Law
Departments: The City Law School
The City Law School > Academic Programmes
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