Key findings include: 

• Identification of six candidate ports: Three public ports (Santos, Rio Grande, and Itaqui) and three private ports (Porto do Açu, Pecém, and Navegantes) could serve as potential renewable marine fuel bunkering hubs. Public ports generally scored higher in infrastructure, strategic location, and connectivity.
• High port readiness: Santos, Latin America’s largest port, ranked high in four out of five readiness criteria, while Porto do Açu and Itaqui demonstrated strong performance across all categories except access to offshore wind energy. All six candidates received readiness scores between 3.5 and 4.4 (on a 1–5 scale).
• Feasibility of renewable fuel usage on major shipping routes: Among 10 sample trade routes connecting these ports to key domestic and international markets, five could be completed with renewable liquid hydrogen (RE-LH2) in fuel cells without refueling. All routes are feasible using renewable ammonia (RE-NH3) and renewable methanol (RE-MeOH) in internal combustion engines, eliminating the need for mid-route refueling.
• Estimated fuel and energy demand: To support zero-emission shipping on these routes, between 1,785 and 1,911 tonnes of renewable hydrogen are required—equivalent to a renewable electricity demand of 82 to 92 GWh. For context, this represents just 0.1% of the annual output of Itaipu, Brazil’s largest hydroelectric power plant, and approximately 0.2% of Brazil’s planned renewable hydrogen production.
• Current ship traffic emissions: In 2023 alone, vessels operating on these sample routes are estimated to have consumed over 4,449 tonnes of fuel and emitted approximately 13,862 tonnes of CO₂ per trip. Operational efficiency varied by route, indicating opportunities to prioritize the most efficient routes for early deployment of zero-emission vessels.   

This pre-feasibility assessment demonstrates the significant potential of Brazilian ports to serve as renewable marine fuel hubs, offering both economic and environmental benefits. By quantifying the potential bunkering demand and analyzing port readiness, this study provides a guideline for future investments and policy initiatives aimed at accelerating the decarbonization of maritime shipping. 

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Principais conclusões incluem: 

• Identificação de seis portos candidatos: Três portos públicos (Santos, Rio Grande e Itaqui) e três portos privados (Porto do Açu, Pecém e Navegantes) poderiam servir como potenciais centros de abastecimento de combustíveis marítimos renováveis. Os portos públicos, em geral, obtiveram pontuações mais altas em infraestrutura, localização estratégica e conectividade. 
• Alta capacidade portuária: Santos, o maior porto da América Latina, teve alto desempenho em quatro dos cinco critérios de prontidão, enquanto o Porto do Açu e Itaqui apresentaram desempenho sólido em todas as categorias, exceto no acesso à energia eólica offshore. Todos os seis portos candidatos receberam pontuações de prontidão entre 3,5 e 4,4 (em uma escala de 1 a 5). 
• Viabilidade do uso de combustíveis renováveis em rotas marítimas importantes: Entre 10 rotas comerciais de amostra, conectando esses portos a mercados domésticos e internacionais chave, cinco poderiam ser percorridas com hidrogênio líquido renovável (RE-LH₂) em células de combustível, sem necessidade de reabastecimento. Todas as rotas são viáveis utilizando amônia renovável (RE-NH₃) e metanol renovável (RE-MeOH) em motores de combustão interna, eliminando a necessidade de reabastecimento no meio da rota. 
• Estimativa de demanda de combustível e energia: Para viabilizar o transporte marítimo de zero emissões nessas rotas, seriam necessárias entre 1.785 e 1.911 toneladas de hidrogênio renovável, o que corresponde a uma demanda de eletricidade renovável entre 82 e 92 GWh. Para contextualizar, isso representa apenas 0,1% da produção anual de Itaipu, a maior usina hidrelétrica do Brasil, e aproximadamente 0,2% da produção planejada de hidrogênio renovável no país. 
• Emissões atuais do tráfego marítimo: Apenas em 2023, estima-se que as embarcações operando nessas rotas de amostra tenham consumido mais de 4.449 toneladas de combustível e emitido aproximadamente 13.862 toneladas de CO₂ por viagem. A eficiência operacional variou conforme a rota, indicando oportunidades para priorizar as rotas mais eficientes na implantação inicial de embarcações de zero emissões.  

Esta avaliação de pré-viabilidade demonstra o potencial significativo dos portos brasileiros para atuarem como centros de combustíveis marítimos renováveis, oferecendo benefícios econômicos e ambientais. Ao quantificar a demanda potencial de abastecimento e analisar a capacidade portuária, este estudo fornece um guia para futuros investimentos e iniciativas políticas voltadas a acelerar a descarbonização do transporte marítimo. 

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Black carbon, typically produced by incomplete combustion in marine engines, contributes to global warming and is linked to health impacts, including lung cancer, respiratory illness, and cardiopulmonary disease. It is considered a key driver of the rapid loss of Arctic Sea ice, a region experiencing significant environmental stress due to rapid warming, with temperatures rising three to four times faster than the global average.  

“Our findings show that ships connected to EU trade, regardless of their flag, are major drivers of black carbon pollution in the Arctic,” says Liudmila Osipova, ICCT Senior Researcher and lead author of the study. “Recognizing these emissions in future policies could help the EU better align its climate goals with its real footprint in the Arctic.” 

The EU generally accounts for Arctic shipping emissions only from ships flying EU flags (“EU-flagged ships”) in the region. This study expands the scope by also assessing emissions from ships traveling to and from EU ports (“EU-regulated ships”). The study compares the fleet composition, fuel use, and BC and CO2 emissions of these ships across both the broadly-defined Geographic Arctic (north of 59°N) and the IMO Arctic as defined by the International Maritime Organization (IMO) Polar Code. 

Between 2015 and 2021, the study finds, BC emissions in the IMO Arctic nearly doubled. EU-regulated ships contributed significantly: among vessels of at least 5,000 GT, EU-regulated ships emitted 52 tonnes of BC, accounting for 23% of total emissions. This is nearly twice the 27 tonnes emitted by EU-flagged ships, which made up 12% of emissions. In the broader Geographic Arctic, EU-regulated ships emitted 317 tonnes of BC and 1.9 million tonnes of CO₂ representing 44% and 60% of emissions from vessels of the same size. By comparison, EU-flagged ships contributed just 145 tonnes of BC and 726,000 tonnes of CO₂ or 20% and 23% of the emissions, respectively. 

Despite its potent climate and health impacts, BC remains one of the most unregulated short-lived climate and air pollutants. While the EU has committed to addressing shipping emissions as part of its broader Arctic climate strategy, BC emissions have not been included in the scope of EU maritime policies, such as FuelEU Maritime and the extension of the EU Emissions Trading System to the maritime sector.   

END

Media contact
Sophie Ehmsen, communications@theicct.org

Publication details Title: Black carbon and CO₂ emissions from EU-regulated shipping in the Arctic
Authors: Liudmila Osipova and Ketan Gore

Please use this link when citing this report: theicct.org/publication/black-carbon-and-co2-emissions-from-eu-regulated-shipping-in-the-arctic-may25

About the International Council on Clean Transportation (ICCT)
The International Council on Clean Transportation (ICCT) is an independent nonprofit research organization founded to provide exceptional, objective, timely research and technical and scientific analysis to environmental regulators. Our work empowers policymakers and others worldwide to improve the environmental performance of road, marine, and air transportation to benefit public health and mitigate climate change. We began collaborating and working as a group of like-minded policymakers and technical experts, formalizing our status as a mission-driven non-governmental organization in 2005.

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Key findings

• In 2021, nearly three-quarters of the ships operating in the Geographic Arctic and half of those in the IMO Arctic were navigating to or from EU ports. Of the 3,171 ships of 5,000 gross tonnage (GT) or more identified in the Geographic Arctic, 2,315 reported to the EU MRV (73%), while only 816 were flagged to an EU state (26%). In the IMO Arctic, 278 of the 564 ships of 5,000 GT or more reported to the EU MRV (49%), while only 112 flew an EU flag (20%).
• In 2021, ships flagged to Norway burned the most fuel by mass in the Geographic Arctic, while Russian-flagged ships burned the most in the IMO Arctic. Norwegian-flagged vessels consumed an estimated 33% of the 3,789 kilotons (kt) of fuel used in the Geographic Arctic in 2021, while Russian-flagged vessels burned closed to half of the 877 kt of fuel consumed in the IMO Arctic the same year.
• Black carbon emissions in the IMO Arctic nearly doubled between 2015 and 2021. In 2021, Arctic shipping emitted 1.5 kt of BC and 12 kt of CO₂ north of 59°N, with about a quarter of these emissions occurring within the boundaries of the IMO Arctic. This indicates a strong growth trend in BC emissions in the IMO Arctic, from 193 tonnes in 2015 to 413 tonnes in 2021.
• Black carbon and CO₂ emissions from EU-regulated ships of at least 5,000 GT are nearly double those from EU-flagged ships. In the Geographic Arctic, EU-regulated ships contributed 44% of BC emissions and 60% of CO₂ emissions from ships at or above 5,000 GT, while EU-flagged vessels accounted for 20% and 23%, respectively. Notably, 72% of BC emissions from EU-regulated ships came from residual fuels. Liquefied natural gas (LNG)-fueled vessels accounted for 31% of the total CO₂ emissions from EU-regulated ships, despite contributing only 2% of BC emissions from all EU-regulated ships operating in the Geographic Arctic. In the IMO Arctic, EU-regulated ships accounted for 23% of BC emissions and 49% of CO₂ emissions from ships at or above 5,000 GT, while EU-flagged ships at or above 5,000 GT contributed only 12% and 20%, respectively.

Figure. Black carbon emitted in the Geographic Arctic and in the IMO Arctic by EU-flagged and EU-regulated vessels, by ship class

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The incentive policies cover a wide range of transportation equipment, including passenger cars, trucks, new energy buses and batteries, ships, and off-road agricultural machinery. Compared with the 2024 program, the 2025 program broadly follows the previous design, while extending the eligibility criteria and enhancing the incentive levels.

Highlights of the 2025 incentive policies include:

• The eligibility age of scrapping incentive for old passenger cars was extended in 2025, while the subsidy amounts remain at ¥15,000 for the replacement of an old car with a cleaner fossil fuel-powered car and ¥20,000 for replacing it with a new energy car.
• The old commercial China IV trucks are newly eligible for the program in 2025. Truck owners continue to receive subsidies for their early scrapping of old trucks before the mandatory retirement age and can receive additional subsidies for replacing them with new China VI trucks or new energy trucks, with the total subsidy amounts ranging from ¥10,000 to ¥140,000.
• The overall average subsidy per vehicle increased from ¥60,000 to ¥80,000 for the renewal of city buses aged 8 years and older, as well as batteries that are beyond their warranty period or do not meet safe operating conditions.

Table 1. Summary of key changes to incentive policies from 2024 to 2025

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On April 11, the International Maritime Organization’s (IMO) Marine Environment Protection Committee (MEPC 83) approved the Regulations on the IMO Net-Zero Framework. Meant to lower the well-to-wake (WTW) greenhouse gas fuel intensity (GFI) of ships over 5,000 gross tonnage, the direct compliance target requires a 21% GFI reduction by 2030 increasing to 43% by 2035 compared to the 93.3 gCO2eq/MJ fossil fuel baseline of 2008. No GFI target has been set for 2050. Shipowners who don’t attain GFI targets will either buy credits, use their own banked credits, or pay penalties. (There are lower penalties for ships that achieve a “base” compliance target of at least 8% in 2030, increasing to 30% in 2035.) 

The GFI targets are not strong enough to reduce absolute GHG emissions in line with the IMO’s 2023 GHG Strategy and it’s uncertain how many ships will directly comply or pay to pollute. It’s also unclear how the framework will reward the use of zero- or near-zero life-cycle GHG fuels. Nevertheless, IMO’s Net Zero Framework will be one of the key levers for achieving IMO’s goal of net-zero GHG emissions from maritime shipping “by or around” 2050 and a related goal for zero or near-zero GHG fuels to account for 5%–10% of energy use in international shipping by 2030. But without accurate accounting rules, nominally “clean” fuels used to comply with the framework could be substantial GHG emitters. 

To accurately estimate the GHG intensity of marine fuels, IMO could consider changes in four areas of its 2024 Life-Cycle Assessment (LCA) Guidelines before the IMO Net-Zero Framework is fully implemented in 2028.

1. Account for indirect land-use change (ILUC) from biofuels. The IMO’s aviation counterpart, the International Civil Aviation Organization (ICAO), includes quantitative ILUC emission factors in its policies. Other regulations, including FuelEU Maritime, limit or exclude food or feed-based biofuels. The Net-Zero Framework does neither.

The most important factor influencing life-cycle GHG emissions of food and feed crops is ILUC, which occurs when incentives for biofuel production divert food and feed crops from existing uses to biofuel. Higher crop prices caused by biofuel incentives create economic pressure to bring more land into production, which can include deforestation. Even using crops grown on existing croplands that meet IMO’s sustainability criteria can still create land use pressure given the global nature of markets. 

Counting only direct GHG emissions from a biofuel’s life cycle gives an incomplete picture of its climate impact. For example, Figure 1 illustrates the life-cycle GHG emissions of hydroprocessed vegetable oils (HVO). Direct GHG emissions (shown in purple) are less than half those of fossil marine fuels. However, when ILUC emissions (blue) are included, the full life-cycle GHG emissions are accounted for. At best, palm or soy HVO provide little GHG benefit. At worst, they emit more than marine fossil fuel. Since HVO is the cheapest, most commercially ready drop-in biofuel, these fuels would be attractive under the Net-Zero Framework. 

Figure. Life-cycle GHG emissions for HVO compared with a fossil fuel comparator of 94 CO2e/MJ (the ICCT’s estimate of the GHG intensity of fossil marine fuels). ILUC values are from ICAO, which refers to two ILUC models to develop its values; error bars show ILUC values from each of these models. Rapeseed and soybean oils are global ILUC numbers, while the palm oil ILUC number is for Malaysia/Indonesia (no global number is available). Direct emissions are typical values from the European Union’s Renewable Energy Directive.

If IMO’s LCA Guidelines aren’t amended to include ILUC emission factors, the calculated GHG emissions for food- and feed-based biofuels will be underestimated; that could substantially inflate their purported GHG emissions reductions. Without amendment, large volumes of food and feed biofuels could be used to meet GFI targets.

2. Accurately account for methane emissions. IMO’s LCA Guidelines underestimate methane slip from LNG-fueled ships that use the most common LNG engine technology. Methane has a 100-year global warming potential (GWP) nearly 30 times higher than carbon dioxide (CO2); its 20-year GWP is more than 80 times higher. Measurements of methane slip from ships using the most common LNG engine (LPDF 4-stroke) averaged 6.4%, much higher than IMO’s assumption of 3.5%. Real-world measurements of other LNG engine technologies are underway.

Increasing IMO’s default methane slip assumption for LPDF 4-stroke engines to at least 6% would result in life-cycle GHG emissions nearly 20% higher than conventional marine fuels for LPDF 4-stroke engines; continuing to use 3.5% methane slip results in LNG having GHG emissions that are about the same as conventional fuel. (Shipowners could get credit under the Net-Zero Framework for measuring and certifying lower methane emissions). IMO’s LCA Guidelines lack a default emission factor for well-to-tank (upstream) emissions for fossil LNG, which ranges between 18.5 and 28 g CO2e/MJ. That’s 20%– 30% of the life-cycle GHG intensity of heavy fuel oil. IMO will agree on a value as it amends the LCA guidelines prior to implementing the Net-Zero Framework.

3. Account for nitrous oxide (N2O) emissions from ammonia. Renewable ammonia is emerging as a viable choice for the maritime sector, but IMO’s LCA Guidelines don’t account for its N2O emissions. The GWP of N2O is nearly 300 times that of CO2 (N2O’s 100-year and 20-year GWPs are the same); therefore, even small amounts of emissions can negate the climate benefits of ammonia. Recent ammonia dual-fuel engine experiments show a wide range of N2O emissions. IMO’s LCA Guidelines could include a default N2O emission factor for ammonia-fueled engines that’s high enough to avoid underestimating their climate impacts. As we recently suggested in comments on the United Kingdom’s plans to include shipping in its Emissions Trading Scheme, one option could be 0.0025 g N2O/g fuel (equivalent to approximately 36 g CO2e/MJ). That’s based on the maximum N2O emissions observed in two separate peer-reviewed studies, as summarized in a submission to MEPC 83. Shipowners could then measure, report, and verify N2O emissions to use a lower value when calculating their GFI.

4. Include black carbon. Black carbon is the second-largest climate pollutant emitted by ships; it accounts for 8% of shipping’s CO2e emissions based on GWP100 and 23% based on GWP20. But it isn’t considered in IMO’s LCA Guidelines. Having already agreed to guidelines to measure black carbon and to voluntary guidelines to reduce black carbon in the Arctic, IMO is now considering mandatory measures to reduce black carbon. But a global regulation could be achieved by amending the LCA guidelines to include black carbon. Note that the European Commission is considering including black carbon in the FuelEU Maritime framework during its current review, which runs through 2027.

The IMO has tasked an independent LCA expert group with recommending ways to improve the LCA Guidelines, including how to address ILUC and which default emission factors to use. The group will meet twice this year, and their recommendations will next be considered by MEPC 84 in 2026. We recommend the group consider the four changes we’ve outlined. Addressing these issues in the LCA Guidelines before full implementation of the Net-Zero Framework in 2028 would substantially advance IMO’s goals. Otherwise, we risk having a framework that promotes cheap-but-high-emitting fuels that could increase GHG emissions.  

Authors

Serkan Ünalan
Associate Researcher

Chelsea Baldino
Program Lead

Related Reading

Vision 2050: Fuel standards to align international shipping with the Paris Agreement

This report is a gap analysis, detailing the reduction in the global average GHG fuel intensity (GFI) and the operational efficiency improvements that would be necessary for the IMO to achieve its climate goals.

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SectorMaritime shipping

PoliciesFuelsGHG emissions

RegionGlobal

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The decision follows an official submission to the MEPC 83 of the research conducted by the International Council on Clean Transportation (ICCT) in collaboration with Porto University, demonstrating the proposal’s potential for reducing emissions while also benefiting public health and the environment. This research has been approved and submitted by all 27 EU member states, the United Kingdom, and the European Commission. The new ECA will cover the territorial seas and exclusive economic zones of the Faroe Islands, France, Greenland, Iceland, Ireland, Portugal, Spain, and the United Kingdom—a region home to more than 190 million people. It will serve as a link between existing ECAs in the Baltic, North, and Mediterranean Seas, and connect them to those recently approved in the Norwegian Sea and Canadian Arctic.

International shipping emits significant levels of pollutants. Stricter regulations under the new ECA is expected to reduce sulfur oxide (SOx) emissions by up to 82%, particulate matter (PM2.5) by 64%, and black carbon (BC) by 36%. Nitrogen oxide (NOx) emissions will decline by up to 71% over time with fleet renewal. As a result, the North-East Atlantic ECA is expected to prevent up to 4,300 premature deaths between 2030 and 2050 and save up to €29 billion in health-related costs. It will also benefit coastal communities, including Indigenous groups in the Arctic, who are especially vulnerable to the harmful effects of air pollution.

Moreover, the ECA will play a key role in protecting the region’s marine biodiversity and cultural heritage, covering over 1,500 marine protected areas, 17 important marine mammal habitats, and 148 UNESCO World Heritage sites. Reducing shipping emissions is crucial to prevent further pollution and ocean acidification threatening these ecosystems.

ICCT Senior Researcher Liudmila Osipova, who led ICCT’s research on the North-East Atlantic ECA, welcomes the decision: “The approval of this Emission Control Area reflects a strong international commitment to cleaner shipping. It’s a crucial step toward improving air quality and protecting public health and marine ecosystems for the long term.”

END

Media contact 
Sophie Ehmsen, communications@theicct.org

About the International Council on Clean Transportation (ICCT) 
The International Council on Clean Transportation (ICCT) is an independent nonprofit research organization founded to provide exceptional, objective, timely research and technical and scientific analysis to environmental regulators. Our work empowers policymakers and others worldwide to improve the environmental performance of road, marine, and air transportation to benefit public health and mitigate climate change. We began collaborating and working as a group of like-minded policymakers and technical experts, formalizing our status as a mission-driven non-governmental organization in 2005.

Find us at:
www.theicct.org
Bluesky | LinkedIn | YouTube
Keep up with our research by signing up for our newsletters.

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Key findings include:

• From 2016 to 2023, total tank-to-wake (TTW) greenhouse gas emissions increased by 12%, with a compound annual growth rate of 1.4%. Shipping’s share of global anthropogenic CO₂e100 emissions remained stable at approximately 1.7% (or 2.3% of global anthropogenic CO₂).
• Despite improvements in fleet-wide carbon intensity, which declined by about 10.3% from 2016 to 2023, absolute emissions have continued to rise. This divergence reflects the rapid growth in global shipping transport work, which expanded by 21% over the same period.
• The fuel mix in shipping has undergone significant shifts. Consumption of heavy fuel oil has largely been replaced by very low sulfur fuel oil since 2020, while the use of liquefied natural gas (LNG) nearly doubled between 2016 and 2023. Methane emissions from LNG-fueled ships grew by more than 2.5 times during the study period due to the prevalence of dual-fuel internal combustion engines with high methane slip.
• Black carbon emissions remain a significant concern, representing 8% of the total TTW CO₂e100 emissions (or 23% of the total TTW CO₂e20 emissions) released during the study period.

Figure. Transport work, CO₂ emissions, and average carbon intensity from 2016 to 2023

Data on ship activity and emissions by ship class across all years studied are provided in the “supplemental material” Excel sheet below.

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Key findings

We find that the global shipping sector is on a trajectory to exhaust its proportional 1.5 °C carbon budget by 2030, its 1.7 °C budget by 2037, and its 2 °C budget by 2047. Mid-term measures aligned with the targets in the IMO Minimum or IMO Striving scenarios could achieve cumulative emissions that are consistent with limiting warming to 1.7 °C. As illustrated in Figure 1, projected operational efficiency improvements resulting from the IMO mid-term measures could reduce cumulative emissions by about 10% between 2020 and 2050. The remaining 90% will require replacing fossil fuels with net-zero GHG fuels or energy on a life-cycle basis, which can only be achieved by advanced technologies that have not yet been fully commercialized.

Figure 1. Cumulative well-to-wake greenhouse gas emissions avoided by scenario and measure, 2020–2050

Reducing the global average GFI using the GFS would require that the regulation, and the guidelines used to implement it, accurately account for the well-to-tank and tank-to-wake GHG emissions of marine fuels and prevent the use of food- and feedbased biofuels. It would also require an unprecedented level of financial investment in the nascent and pre-commercial technologies necessary to produce genuinely zero-carbon fuels.

If the real-world well-to-wake GHG intensity of the fuel mix used to satisfy the GFS requirements is not accurately accounted for, then the life-cycle GHG emissions from shipping will be higher than implied by the policy. To bridge this gap, regional and national governments would need to implement their own policies to regulate the GHG intensity of the fuels ships use on voyages to, from, or between their ports. These policies would need to be considerably more ambitious than current international best practices, as contained in the FuelEU Maritime regulation.

The results indicate that achieving the IMO’s GHG emission reduction targets will necessitate unprecedented ambition in GFS requirements and economic measures that ensure an effective carbon price signal. In addition, these mid-term measures should promote the use of scalable zero-emission fuels that can bring meaningful climate benefits: renewable hydrogen-based e-fuels. The findings underscore the urgency of finalizing and implementing these policies to align shipping with global climate goals.

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