BIMCO circulates EU member-state position on IMO carbon levy ahead of MEPC 83

BIMCO has circulated to members the consolidated EU member-state position paper on the IMO economic measure under the GHG Strategy mid-term basket, following the outcome of MEPC 82 and in the run-up to MEPC 83 scheduled for autumn 2026. The note, dated Q2 2026, restates the bloc's preference for a per-tonne CO2 levy applied at the bunkering or voyage-emissions point, with revenues recycled via the IMO Net-Zero Fund for fuel transition and just-transition uses.

The European position is not yet IMO law. MEPC 82 closed without final adoption of the economic measure, and the technical and economic elements remain in negotiation. What MEPC 82 did do was narrow the design space: a levy-plus-GFI (Global Fuel Intensity) combined instrument is now the working text, replacing the earlier choice between a pure feebate and a pure standard.

For owners running into EU waters, the levy discussion sits on top of two instruments that are already live: the EU ETS extension to shipping (50% of voyage emissions on EU-EEA legs in 2025, 100% from 2026) and FuelEU Maritime, which began applying to vessels above 5,000 GT calling at EU ports from 1 January 2025. BIMCO's note is explicit that the IMO measure, when adopted, is expected to interact with — not replace — those EU instruments through a yet-to-be-defined equivalence mechanism.

Industry estimates cited in the BIMCO circular put the indicative levy band in the $30-150/tonne CO2 range under the scenarios being modelled by member states, with the lower end favoured by flag states with large bulk and tanker fleets and the upper end pressed by a coalition of Pacific and Caribbean states. A final figure is not expected before MEPC 83 at the earliest.

What it means for owners

• Begin modelling a per-tonne CO2 levy into 2027-2028 voyage budgets at a planning band, not a point estimate — the design is converging but the number is not.
• Make sure your charterparty bunker and emissions clauses route IMO levy cost and EU ETS/FuelEU cost separately; the equivalence mechanism is not yet defined and conflating them will create disputes.