- No carbon intensity target, and a weakened Energy Efficiency of Existing Ships Index (EEXI): The proposal still contains no carbon intensity target, and somehow, reduces the stringency of the required EEXI for many ship types. This means the proposal would, at best, now curb only 0.65% to 1.3% of GHG emissions from a business-as-usual growth pathway by 2030, (compared to 0.8% to 1.6% in the version going into these talks) where the business as usual pathway is +15% above the industry’s 2008
- Loopholes: non-compliant ships will be able to continue underperforming for three consecutive years before they even have to file a plan to make improvements, and can easily game underperformance indefinitely by ensuring one compliant year every three
- No actual enforcement: All clauses that would create consequences for non-compliance – such as increased EEXI stringency or ultimately revoking a ship’s statement of compliance – have been removed.