Who Gets to Shape Shipping’s Climate Transition? Japan’s IMO Proposal Raises Concerns for Africa

As countries prepare for crucial maritime climate negotiations in November and December, a proposed change to the International Maritime Organization’s (IMO) Net-Zero Framework has raised concerns about climate finance, emissions reductions and the influence of developing countries over the transition.

The rules governing how the global shipping industry reduces its emissions could have significant implications for climate-vulnerable countries, including those in Africa.

A new analysis by Opportunity Green, a UK-based climate policy organisation, warns that Japan’s latest proposal to amend the International Maritime Organization’s (IMO) Net-Zero Framework (NZF) could weaken the agreement’s emissions-reduction ambitions and limit developing countries’ ability to influence how the maritime sector transitions to cleaner energy.

What is the IMO Net-Zero Framework?

The International Maritime Organisation is the United Nations agency responsible for regulating international shipping. In 2023, its member states adopted a revised greenhouse gas strategy that set ambitions for international shipping to reach net-zero greenhouse gas emissions by or around 2050, alongside interim targets for reducing emissions.

In April 2025, a majority of IMO member states approved the policy architecture of the Net-Zero Framework, designed to translate these ambitions into regulatory measures.

The framework combines greenhouse gas fuel-intensity requirements with economic measures intended to encourage shipping companies to reduce emissions. It also establishes a proposed Net-Zero Fund to collect revenues from compliance payments and channel funding towards cleaner shipping technologies and a just and equitable transition.

Under this arrangement, the revenues could support the deployment of zero- and near-zero-emission fuels and technologies, technology transfer, capacity building and infrastructure development. These investments could be particularly important for countries that have limited financial resources to support the transition independently.

However, the framework’s future remains contested, with Japan proposing changes that Opportunity Green argues would significantly alter how its economic measures operate.

What Japan is proposing

Japan’s submission to the IMO’s Marine Environment Protection Committee (MEPC 85) builds on a proposal it first tabled in April. According to Opportunity Green’s briefing, it would remove the Net-Zero Fund, make purchases of Surplus Units (credits earned by ships that beat the fuel-intensity targets) the main way to cover compliance shortfalls and let ships make direct contributions to IMO-approved projects when not enough Surplus Units are available, at a price fixed in advance, possibly the current $100-per-tonne Remedial Unit price

Trade press reports additional changes. Japan would ease the emissions-reduction trajectory from 2030 onwards while keeping the 2028-2029 targets, and it drops the regulation that sets the threshold for zero and near-zero fuels and their rewards from the Fund.

Japan’s stated reasoning is about flexibility and politics. It argues that expanded trading gives ship owners more flexibility and answers concerns from some states that mandatory payments resemble a global carbon tax.

What does this mean for Africa?

For climate-vulnerable developing countries, the question of how maritime climate finance is distributed is particularly important. Many developing countries face competing demands on public resources, including climate adaptation, infrastructure development and energy transitions.

Moving towards cleaner shipping may require investments in port infrastructure, new fuel supply systems, technology and technical capacity. A dedicated international fund could provide a more predictable source of finance for these investments.

Africa is not speaking with one voice. Kenya supports the framework and made a detailed submission on governing principles for the Fund, and the DRC, Ghana and Togo have backed the Fund. Liberia, a major flag state, opposes any GHG pricing, and Algeria opposes the NZF.

The African Union Commission has been working toward a common continental position, and only 18 of Africa’s 44 IMO member states have ratified MARPOL Annex VI.

The cost concern is real. Several African and other developing nations worried that the levy on high-emitting ships would raise the cost of food and goods. That is a fair counterweight to the NGO’s framing. The Fund’s backers argue that redistributed revenue is what offsets those costs. Critics of the Fund argue that a global pot of money managed by the IMO is the problem.

For Kenya, the stakes include port upgrades and green-fuel ambitions. At a Mombasa workshop with delegates from 25 African countries, officials stressed the need for a coordinated African position.

The decision ahead

The IMO’s next round of discussions will take place in two stages. The twenty-third session of the Intersessional Working Group on Reduction of Greenhouse Gas Emissions from Ships (ISWG-GHG 23) is scheduled for 23–27 November 2026, followed by the eighty-fifth session of the Marine Environment Protection Committee (MEPC 85) from 30 November to 4 December 2026, where adoption will be discussed.

As governments prepare for these negotiations, Opportunity Green is calling for member states to preserve the core elements of the framework approved in April 2025.

Its recommendations include retaining the mandatory economic measures, keeping decisions on the equitable distribution of revenues with member states, protecting the integrity of the Surplus Unit market and preserving the framework’s collective financing architecture.

The outcome will help determine how the shipping industry is held accountable for its climate impact and how the costs and opportunities of the transition are distributed.

As negotiations approach, the central question is whether the final framework will preserve a collective approach to reducing shipping emissions and supporting vulnerable countries, or move towards a system in which private-sector decisions play a greater role in determining where the benefits of climate finance flow.