Shipping Emissions: on a collision course with the EU's Emissions Trading System?

"We'll never get anywhere if you want to convince the last climate change denier." This is the damning indictment by EU MEP¹ Jutta Paulus, who was commenting on the slow progress of the International Maritime Organization in tackling the shipping industry's greenhouse gas emissions.² The trouble for the shipping industry is that Ms Paulus is the rapporteur for maritime emissions, and, by all accounts, she means business.

Under Ms Paulus's direction, the ENVI Committee³ recently made a legislative proposal to include maritime emissions in the EU Emissions Trading System (ETS). The effect of this, if enacted, would be to put a price on greenhouse gases emitted from ships within the EU. While such a proposal is in line with the EU Commission's 2019 "European Green Deal", it has faced fierce criticism from the shipping industry.

This article analyses the current EU landscape in relation to the regulation of greenhouse gas emissions from ships, current EU policy and the proposed legislative reforms, and comments on the potential impact on the shipping industry should the ETS be expanded.

If introduced, the inclusion of maritime emissions in the ETS would have a significant effect on the shipping sector. Therefore, if further developed, the proposal is likely to be subject to challenge, both in principle and in terms of its scope and application. Given the scale and importance of the shipping industry to the global economy, it would appear that the EU and the shipping industry are currently on a collision course.

Scene setting and data crunching: shipping emissions in a global context

For context, we have set out below the scale of emissions from shipping and the rate of growth. This is important to an understanding of the relevant policy and regulatory drivers.

The first key point relates to the scale of greenhouse gas (GHG) emissions from shipping:

• Globally, the most recent International Maritime Organization (IMO) GHG Study⁴  estimated that international shipping accounted for approximately 2.1 per cent of the total global anthropogenic GHG emissions. While 2.1 per cent is a relatively small contribution in percentage terms, the EU Commission has stated that "This is more than the emissions of any EU state. If the shipping sector were a country, it would rank sixth in emission[s] in the world".⁵
• At EU level, in 2019, shipping contributed approximately 13 per cent of the overall EU GHG emissions from the transport sector (the top three being 71.7 per cent road, 13.9 per cent aviation, 13.3 per cent maritime).⁶

The second key point relates to the rate of growth in GHG emissions from shipping. Unlike many modes of transport and industry, GHG emissions from shipping have not only grown significantly in recent years but are also projected to continue to grow significantly.

• Globally, the Third IMO GHG Study estimated that emissions from international shipping could grow by up to 250 per cent by 2050, mainly due to the global growth of maritime trade.⁷ 
• At EU level, CO2 emissions from maritime transport increased by 48 per cent between 1990 and 2008, and are expected to increase by 86 per cent above 1990 levels by 2050, despite the adoption of minimum ship efficiency standards for new ships by the IMO in 2011.⁸

These statistics should be considered against the backdrop of significant momentum on climate change at an international level, coalescing around the Paris Agreement adopted at the UN climate conference⁹ (COP) in December 2015. The Paris Agreement aims to limit global temperature increase well below 2 °C compared to pre-industrial levels, and "pursue efforts" to limit the temperature increase to 1.5 °C based on ambitious GHG mitigation by all countries.

The EU submitted its Intended Nationally Determined Contribution (NDC) under the Paris Agreement to the UNFCCC¹⁰  in March 2015, committing to a binding target of at least a 40 per cent domestic reduction in economy-wide GHG emissions below 1990 levels by 2030.¹¹  Since then, in December 2019, the EU has revealed its aim to be climate-neutral by 2050. An updated and more ambitious NDC target is expected in 2020.¹²

Since then, the EU has remained at the forefront of global climate diplomacy, calling for ambitious action on climate change both in terms of mitigation and adaption. Further, the next COP will now take place in Glasgow in November 2021, having been rescheduled due to the coronavirus pandemic. Notwithstanding Brexit, this, alongside EU policy and legislative changes, will maintain momentum on action to reduce EU GHG emissions. EU policy developments in relation to maritime emissions are discussed below.

The EU's actions in a global context

The complexity of global developments and the range of stakeholders provide important context within which the EU regime sits. Before commencing a review of the EU regulatory landscape on shipping emissions, it should be acknowledged that the EU's proposals are only one part of a global shift towards green maritime transport, which is gathering significant momentum. Very briefly, key examples of other public and private measures adopted and developments currently under way include:

1. A raft of measures adopted or under consideration by the IMO to address shipping emissions, include:
   
   (a) the Initial IMO Strategy on reduction of GHG emissions from ships¹³  which includes in particular an ambition "to peak GHG emissions from international shipping as soon as possible and to reduce the total annual GHG emissions by at least 50 per cent by 2050 compared to 2008", while pursuing efforts towards phasing out GHG emissions as soon as possible this century;
   
   (b) the IMO's focus on energy efficiency measures, including the Energy Efficiency Design Index, Ship Energy Efficiency Management Plans and the Energy Efficiency Operational Indicator;¹⁴ 
   
   (c) a proposal to establish an IMO GHG reduction research and development (R&D) programme to accelerate the introduction of low-carbon and zero-carbon technologies and fuels. The sponsors propose that funding would be provided via a mandatory R&D contribution per tonne of fuel oil purchased for consumption.¹⁵
2. National governments seeking to include emissions from international shipping and aviation in carbon budgets and national net-zero targets (for example, the UK), where they have historically been excluded.¹⁶  
3. Shipping companies setting their own targets: for example, Maersk has announced a goal to reach carbon neutrality by 2050. Further, shipping companies are starting to differentiate themselves in the "low-carbon" market by offering low-carbon shipping solutions such as Maersk's "ECO Delivery".
4. Significant growth in corporate net-zero emission strategies, some of which include "scope 3 emissions" (i.e. the indirect emissions of a company's value chain). For example, the H&M Group in February 2020 sought to reduce its transport emissions by using Maersk vessels that run on sustainable biofuel.
5. The "Getting to Zero Coalition", a partnership between the Global Maritime Forum, the Friends of Ocean Action and the World Economic Forum, will focus on achieving the target set by the IMO to reduce greenhouse gas emissions from shipping by at least 50 per cent compared to 2008 levels by 2050.

The current EU legislative framework: MRV

EU law currently requires the monitoring, reporting and verification (MRV) of carbon dioxide emissions from maritime transport. It is, in essence, a data gathering regulation bolstered by the independent verification of emissions. Shipping does not presently have to participate in the ETS, the EU's flagship GHG mitigation scheme.

Following extensive debate as to the most appropriate way to regulate shipping emissions, in April 2015 the EU enacted Regulation 2015/757 on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport (the EU MRV Regulation). The EU MRV Regulation entered into force on 1 July 2015.

The overall effect of the EU MRV Regulation is that, from 1 January 2018, "large ships" (over 5,000 gross tonnage (GT)) which load or unload cargo or passengers at ports in the European Economic Area (EEA)¹⁷ have to monitor and report their related CO2 emissions and other relevant information.

The EU's aim is that the information collected informs future policy-making decisions and stimulates the uptake of new technologies and operational measures to make ships greener.

In summary, the main obligations for companies required to participate in the EU MRV Regulation are as follows:

1. Monitoring: From 1 January 2018, companies shall – in line with their respective monitoring plans – monitor for each of their ships: CO2 emissions, fuel consumption and other parameters (such as distance travelled, time at sea and cargo carried on a per voyage basis), so as to gather annual data for an emissions report to be submitted to an accredited MRV shipping verifier.
2. Emissions report: From 2019, by 30 April of each year, companies shall, through THETIS MRV (the EU's information system), submit to the EU Commission and to the states in which those ships are registered (flag states) a satisfactorily verified emissions report for each ship that has performed maritime transport activities in the EEA in the previous reporting period (calendar year).
3. Document of compliance: From 2019, by 30 June of each year, companies shall ensure that all their ships that have performed activities in the previous reporting period and are visiting ports in the EEA carry on board a document of compliance. This could be subject to inspection.

However, as with all laws with a significant technical component, the devil is in the detail. Set out below are several key points about the application, scope and design of the EU MRV Regulation. We highlight these points because similar principles are likely to arise when considering the potential inclusion of shipping in the ETS.

1. The EU MRV Regulation applies to ships above 5,000 GT regardless of their flag. This aligns with the IMO's principle of non-discrimination between flag States. There are a limited number of vessels exempted from the EU MRV Regulation, including warships, fish-catching or fish-processing ships, ships not propelled by mechanical means, and government ships used for non-commercial purposes.
2. The EU MRV Regulation applies to the emission of CO2 only. It does not apply to other GHGs from shipping.
3. The EU MRV Regulation applies to CO2 released during a ship's "voyage". Voyages are movements to or from EEA ports carried out after 1st January 2018 that transport either passengers or cargo for commercial purposes. Movements that do not serve either of these purposes are not subject to MRV requirements.
4. The exact geographical extent of the EU MRV Regulation is complex. It applies to CO2 released during voyages to or from a "port of call under the jurisdiction of a Member State". The EU MRV Regulation therefore applies, for example, to voyages to and from Martinique (the Caribbean) and Réunion (the Indian Ocean).
5. Obligations are to be fulfilled on a "per ship" basis by the "MRV company", that is, by either the shipowner or any other organisation or person, such as the manager or the bareboat charterer, which has assumed the responsibility for the operation of the ship from the shipowner. The EU MRV Regulation allows the parties involved in the operation of each ship subject to the regulation to determine who assumes the MRV monitoring and reporting obligations.

Overall, as its title suggests, the EU MRV Regulation imposes only MRV-related obligations on companies, and does not incorporate shipping into the EU ETS or establish any other form of market-based mechanism.

We note that, as is often the case with environmental data-collection regimes, once the data is collected, it drives awareness across the industry sector to investors, consumers and policy makers alike. The compiling and processing of such data creates a "policy problem" – here, rising shipping emissions – to which policy makers seek to find a "policy solution". Returning to Jutta Paulus:

"I don’t see any sense in keeping on counting emissions but doing nothing to reduce them."¹⁸

IMO Data Collection System and overlapping compliance regimes

Following the adoption of the EU MRV Regulation, the IMO established an IMO Data Collection System (IMO DCS). The IMO DCS entered into force on 1 March 2018 through amendments to MARPOL¹⁹  Annex VI²⁰ on the Data collection system for fuel oil consumption of ships.²¹

The IMO DCS requires owners of large ships (above 5,000 GT) engaged in international shipping to report information on fuel consumption (and other proxies) of their ships to the flag States of those ships. The flag States then report aggregated data to the IMO, which produces an annual summary report to the IMO Marine Environment Protection Committee.

Under the IMO DCS, monitoring obligations started on 1 January 2019, with reporting in 2020. As a result, from January 2019 ships performing EEA-related maritime transport activities have to fulfil monitoring and reporting requirements under both the EU MRV Regulation and the global IMO DCS. However, the regimes are substantively different in a number of respects.

The EU's position is that it is not looking to create duplicative legislation and that the EU MRV Regulation envisaged global action via the IMO. Article 22 of the EU MRV Regulation provides that: 

"In the event that an international agreement on a global monitoring, reporting and verification system for greenhouse gas emissions (…) is reached, the Commission shall review this Regulation and shall, if appropriate, propose amendments to this Regulation in order to ensure alignment with that international agreement."

To address this, the EU has sought to bring forward legislation amending the EU MRV Regulation.

Proposed EU amending regulation to EU MRV Regulation

The EU Commission's proposal for a regulation to amend the EU MRV Regulation in order to take account of the IMO DCS was published by the EU Commission in February 2019 (the Proposed MRV Amending Regulation).²²

The EU Commission has sought to streamline and reduce administrative effort for companies where possible, while preserving the objectives of the EU MRV Regulation. In bringing forward the Proposed MRV Amending Regulation, three policy options were assessed:

• Option 1: Do nothing
• Option 2: "Streamline" – different alignment options were assessed, in terms of scope, definitions, monitoring parameters, monitoring plans and templates, verification and transparency
• Option 3: "High convergence" – the EU MRV Regulation would be amended to harmonise all its technical aspects with the IMO DCS (i.e. the EU MRV Regulation would adopt the requirements of the IMO DCS)

Following consideration, the EU Commission proposed option 2, with a limited alignment of the EU MRV Regulation to the global IMO DCS in relation to definitions, monitoring parameters, monitoring plans and templates. The impact assessment recommended option 2, as it safeguards the expected environmental, social and economic benefits of the EU MRV Regulation, while reducing the administrative burden for shipowners.²³

Intervening evolution of EU policy

Since the Commission's Proposed MRV Amending Regulation in February 2019, EU policy on climate change has developed significantly.

Specifically, on 28 November 2019, ahead of the most recent COP, the European Parliament approved a resolution declaring a climate and environmental emergency in Europe and globally.²⁴

Following this resolution, on 11 December 2019, the European Commission presented the European Green Deal. The European Green Deal sets out a road map of key policies and measures for the EU to become the first climate-neutral continent by 2050 at the latest.²⁵  The key point from the shipping industry's perspective is that the European Green Deal makes it EU policy to include shipping emissions in the ETS.

The relevant sections which suggest that broader tax reform can also be anticipated are set out below (our emphasis highlighted in bold):

"The price of transport must reflect the impact it has on the environment and on health. Fossil-fuel subsidies should end and, ……. the Commission will look closely at the current tax exemptions including for aviation and maritime fuels and at how best to close any loopholes.

Similarly, the Commission will propose to extend European emissions trading to the maritime sector, and to reduce the EU Emissions Trading System allowances allocated for free to airlines. This will be coordinated with action at global level, notably at the International Civil Aviation Organization and International Maritime Organization."

"[The Commission] will take action in relation to maritime transport, including to regulate access of the most polluting ships to EU ports and to oblige docked ships to use shore-side electricity."

It is clear from these policy statements that the shipping sector is likely to be directly affected by EU legislative reforms. While, at present, the European Green Deal is policy and not law, shipowners and operators should be aware of significant changes on the horizon.

The declaration of a climate and environmental emergency and the European Green Deal have together driven the European Parliament's ENVI Committee to propose the inclusion of maritime GHG emissions in the ETS, which we explore in more detail in the next section.

The Draft report of the Committee on the Environment, Public Health and Food Safety

The European Parliament's ENVI Committee published its draft report on the Proposed MRV Amending Regulation on 24 January 2020²⁶  (the ENVI Committee Report). The ENVI Committee considers that the Commission's Proposed MRV Amending Regulation is not ambitious enough. In particular, the ENVI Committee considers that the Commission's policy has evolved since the Commission's publication of the Proposed MRV Amending Regulation in February 2019. As such, the ENVI Committee Report recommends that amendments should be made to the Proposed MRV Amending Regulation, including to incorporate maritime transport into the ETS.

The drafting amendments tabled by the ENVI Committee propose the inclusion of additional articles into the ETS Directive 2003/87 to include GHG emissions from the maritime sector in the ETS. Conceptually, this is quite a leap; the ENVI Committee Report seeks to include maritime emissions in the ETS through an instrument which seeks to make what are largely technical amendments to the EU MRV Regulation. In doing so, the ENVI Committee Report merges MRV with a market-based mechanism, which does not sit easily. As we set out in more detail below, it will be very challenging to simply "patch" maritime emissions into the ETS, because there are a number of complex considerations that will need careful consideration and drafting.

Putting to one side this conceptual issue, the explanatory memorandum sets out the proposed legislative changes in more detail. In relation to the ETS, it states: 

"The European Parliament must take responsibility and transpose what Commission President Ursula von der Leyen has already proposed: the inclusion of maritime transport in the ETS system of the European Union…….The rapporteur warmly welcomes the Commission’s commitment in the Green Deal to broaden the scope of the EU Emissions trading scheme (ETS) to shipping.

Several attempts to regulate the shipping sector were already made over the past years, none of which was successful. The momentum to include shipping in the ETS is now. There will be no distortion of competition, as all flag states and all companies are treated in the same way. The scope of the regulation includes all intra-Union voyages, all incoming voyages from the last non-Union port to the first Union port of call and all outgoing voyages from an (sic) Union port to the next non-Union port of call."

The explanatory memorandum also provides a real sense of the EU's frustration with the IMO's lack of action:

"The IMO has promised for more than 20 years that it will tackle shipping emissions and has only introduced its Data Collection System after the EU has implemented the MRV Regulation. No real progress has been seen, which is why EU action is a necessity to achieve the Paris objective to limit the temperature increase to 1.5C above pre-industrial levels."

While this may be seen as mere rhetoric, the language used indicates the level of exasperation of the ENVI Committee with the perceived lack of tangible progress through the IMO.

In addition to the proposed inclusion of maritime emissions in the ETS, there are a series of other significant proposals, including:

1. the establishment of a maritime transport decarbonisation fund to foster research and development in the energy efficiency of ships and support investments in innovative technologies and infrastructure to decarbonise maritime transport, and the deployment of sustainable fuels, with the fund financed from ETS revenues. The drafting proposed envisages that 30 per cent of the funds raised by the auctioning of EU allowances under the ETS would capitalise this fund;
2. provisions in relation to "zero emission ports" including requiring the EU Commission to establish binding targets for Member States to ensure that there is an adequate supply of shoreside electricity in maritime and inland ports;
3. the transposition into EU law of the IMO's target to reduce CO2 emissions per transport work by at least 40 per cent by 2030; and
4. an extension of the scope of the EU MRV Regulation to all GHGs, in particular methane (not just carbon dioxide).

Dissenting views within Europe?

While the direction of travel from the ENVI Committee appears clear, it would be naïve to assume that all EU institutions and committees agree with these more ambitious proposals.

For example, the European Economic and Social Committee's (EESC) Opinion²⁷ on the Commission's Proposed MRV Amending Regulation advocates a complete alignment of the EU MRV Regulation with the IMO system, in order to ensure an international level playing field for the European fleet. It considers that the partial alignment proposed by the Commission would create ineffective double monitoring and reporting requirements that would increase the workload, administrative burden and costs.

While the EESC's opinion was prepared in May 2019 (ahead of the recent ENVI Committee Report and the European Green Deal), and so does not comment on the ETS expansion proposals, it shows that the EU is not advancing on a unified front in relation to the roles played by the EU and the IMO.

The most striking section of the EESC's Opinion is as follows – it clearly advocates that the IMO be allowed by the EU to take the lead on a coordinated global regulatory system:

"The EESC considers that the proposed partial alignment will lead to burdensome and ineffective double monitoring and reporting requirements...

…The aim of a complete alignment exercise of the EU MRV Regulation with the UN IMO DCS is to have global regulatory uniformity in order to minimise the additional burden that has a large impact…and avoid any dual reporting requirements under two different systems."

In the light of this disparity in approach, further divisions can be expected.

The shipping industry's views on including emissions within the ETS

The shipping industry is, as one might expect, against the proposed inclusion of shipping in the ETS.

The shipping industry's main argument is that shipping is a global system which should not be distorted by regional regimes. The shipping industry generally supports progress through the IMO, the UN agency which sets rules for the industry more generally.

The shipping industry points towards the positive measures adopted by the IMO to date, in particular the Initial IMO Strategy on reduction of GHG emissions from ships, which contains the IMO's key target to cut total GHG emissions from international shipping by at least 50 per cent by 2050.²⁸  It is noted that the IMO proposes to revise its initial strategy in 2023. Proponents of the IMO system are of the view that EU action before 2023 would prejudge multilateral efforts to find an effective global consensus.²⁹  

It is further argued that regional regulation has the potential to distort competition. Concerns about carbon leakage have also been raised.

We can expect further, and more detailed, arguments to be put forward by the shipping industry as to why the IMO, and not the EU, should be entrusted to deliver ambitious GHG reductions.

Inclusion of maritime emissions in the ETS

As noted above, it seems unlikely that maritime emissions will be included in the ETS without a significant challenge from the shipping industry. However, if they are, the financial impact for the shipping industry will be that EU emissions allowances will have to be acquired and surrendered in respect of GHG emissions. This additional cost will no doubt have to be redistributed through supply chains.

A detailed proposal from the EU as to how shipping emissions would be included in the ETS has not yet been published. However, key considerations for the inclusion of maritime emissions into the ETS include the following:

1. When would such a scheme commence?
2. Would the 5,000 GT threshold used in the EU MRV Regulation for participants continue to apply?
3. Which vessels would be excluded?
4. Which parts of a participating ship's voyage would be captured? Would this be an EU or EEA measure?
5. How would Member States' territories outside of the continent be treated?
6. Are there concerns that the EU is legislating outside of its jurisdiction (as there have been with aviation)?
7. Would all allowances be auctioned or would there be an introductory "grandfathering" phase?
8. Would it be possible to use international-type offsetting credits to comply?
9. Would there be specific provisions for small operators or new market entrants?
10. Who would be liable for the costs of compliance – shipowners or ship operators?
11. How viable is the idea of a maritime transport decarbonisation fund, where similar revenue-recycling funds have not been a significant feature of the ETS?
12. How would those liable (shipowners/operators) pass costs down to other parties?
13. Do contracts currently provide for this, noting that, as a matter of classification, the ETS is not usually viewed as a tax?
14. As a significant maritime nation, would the UK participate in such a scheme, or design a similar domestic scheme?

In all, it is not a simple case of "patching" maritime emissions into the ETS, as each one of these issues requires detailed consideration.

Next steps

The next step in the legislative process is for the European Parliament to vote on the proposal at first reading, in order to adopt a position. The European Parliament will discuss and vote on the proposal. This proposal is due to be heard at a plenary sitting on 8 July 2020; however, the parliamentary timetable may be disrupted by the impact of COVID-19. As the position is rapidly evolving, we would recommend that all interested parties keep these legislative and policy developments under close review.

This article was prepared and represents the position on 22 June 2020.

1. Member of the European Union's European Parliament.
2. The Lloyd's List Podcast: Why the EU won’t wait for IMO on climate change, listened to 9 June 2020. https://lloydslist.maritimeintelligence.informa.com/LL1131130/The-Lloyds-List-Podcast-Why-the-EU-wont-wait-for-IMO-on-climate-change
3. The Committee on the Environment, Public Health and Food Safety (ENVI).
4. See further http://www.imo.org/en/OurWork/Environment/PollutionPrevention/AirPollution/Pages/Greenhouse-Gas-Studies-2014.aspx
The IMO's third GHG study 2014 is the latest, with a final report of the Fourth IMO GHG Study being expected in Autumn 2020.
5. See further Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2015/757 in order to take appropriate account of the global data collection system for ship fuel oil consumption data COM(2019) 38 final.
6. See further the European Environment Agency's Greenhouse gas emissions from transport in Europe, published 17 December 2019 https://www.eea.europa.eu/data-and-maps/indicators/transport-emissions-of-greenhouse-gases/transport-emissions-of-greenhouse-gases-12
7. See further Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2015/757 in order to take appropriate account of the global data collection system for ship fuel oil consumption data COM(2019) 38 final.
8. See further Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2015/757 in order to take appropriate account of the global data collection system for ship fuel oil consumption data COM(2019) 38 final.
9. Conference of the Parties.
10. United Nations Framework Convention on Climate Change.
11. See further https://ec.europa.eu/clima/policies/international/negotiations/paris_en
12. https://climateactiontracker.org/countries/eu/
13. Adopted in April 2018 by the IMO's Marine Environment Protection Committee (MEPC) https://unfccc.int/sites/default/files/resource/250_IMO%20submission_Talanoa%20Dialogue_April%202018.pdf
14. http://www.imo.org/en/OurWork/Environment/PollutionPrevention/AirPollution/Pages/Technical-and-Operational-Measures.aspx
15. See further Proposal to establish an International Maritime Research and Development Board (IMRB) dated 18 December 2019 https://www.ics-shipping.org/docs/default-source/Submissions/IMO/final-imrb-submission-to-mepc-75.pdf?sfvrsn=6
16. See e.g. Committee on Climate Change Letter on International aviation and shipping and net zero to the Secretary of State for Transport https://www.theccc.org.uk/publication/letter-international-aviation-and-shipping/
17. Note that the EU MRV Regulation also applies to the non-EU Member States in the EEA. In practice, this means that it also applies to some non-EU states including Iceland and Norway.
18. https://www.euractiv.com/section/shipping/news/eu-starts-to-chart-shippings-new-green-course/
19. International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocols of 1978 and 1997.
20. Regulation for prevention of Air pollution from ships.
21. Adopted by resolution MEPC.278(70). See further http://www.imo.org/en/KnowledgeCentre/IndexofIMOResolutions/Marine-Environment-Protection-Committee-%28MEPC%29/Documents/MEPC.278%2870%29.pdf
22. See further Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2015/757 in order to take appropriate account of the global data collection system for ship fuel oil consumption data COM(2019) 38 final
23. A full analysis of the proposed limited alignment model is beyond the scope of this article. See further paragraph 1.4 of the Opinion of the European Economic and Social Committee on 'Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2015/757 in order to take appropriate account of the global data collection system for ship fuel oil consumption data dated 15 May 2019 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52019AE1686&from=EN
24. https://www.euractiv.com/section/climate-environment/news/european-parliament-declares-climate-emergency/
25. https://eur-lex.europa.eu/resource.html?uri=cellar:b828d165-1c22-11ea-8c1f-01aa75ed71a1.0002.02/DOC_1&format=PDF
26. https://www.europarl.europa.eu/doceo/document/ENVI-PR-646870_EN.pdf
27. Opinion of the European Economic and Social Committee on 'Proposal for a Regulation of the European Parliament and of the Council amending Regulation (EU) 2015/757 in order to take appropriate account of the global data collection system for ship fuel oil consumption data dated 15 May 2019 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52019AE1686&from=EN
28. Compared to a 2008 baseline.
29. See, for example, the European Community Shipowners' Association Position Paper 'A Green Deal for the shipping industry', February 2020 https://www.ecsa.eu/sites/default/files/publications/2020%20ECSA%20Position%20Paper%20-%20A%20Green%20Deal%20for%20the%20European%20shipping%20industry.pdf