Letter to the European Commission

Seven NGOs and industry alliances, including the SASHA Coalition, ZESTAs, NABU, Carbon Market Watch, the Green Hydrogen Organisation, ZERO and Cittadini per l’aria onlus together representing 82 clean maritime and green hydrogen industry stakeholders, wrote to the European Commission and European Union Presidency urging it to strengthen clean shipping policy in the wake of disappointing regulations agreed last month at the International Maritime Organization (IMO).

Before the IMO measures come into practical effect in 2028, we recommended the EU Commission pursue the following policy roadmap to unlock this potential:

1. 2025 — Sustainable Transport Investment Plan (STIP): introduce financial support mechanisms for e-fuel producers.

   Create financial support mechanisms for e-fuel producers, using revenues from the ETS, to establish the enabling regulatory environment needed to de-risk investment and unlock finances for scaling production.

2. 2026 — ETS maritime review: expand ETS and dedicate revenues to funding e-fuel development.

   Expand the EU ETS to ships under 5,000GT, and dedicate a portion of additional available funding to advancing the maritime energy transition with industry-sourced revenues rather than using public funds, in line with the polluter pays principle.

3. 2027 — FuelEU Maritime review: strengthen targets and make them legally binding.

   Amplify the limited demand signal for e-fuels the IMO measures send by further affirming maritime end-uses of e-fuels and green hydrogen with more ambitious and binding FuelEU Maritime mandates.

4. Urgently push for more ambitious regulation at the IMO in line with the objectives of the Clean Industrial Deal.

   This should include working towards (1) a more stringent ZNZ emission fuels definition, (2) a targeted reward mechanism for e-fuel adoption, and (3) a robust lifecycle analysis methodology that accounts for all climate impacts, including from indirect land use change (ILUC) in biofuel production.

The IMO agreement marks a missed opportunity – but the EU has the opportunity to fill in these gaps, for the sake of the climate and the future resilience and competitiveness of the shipping industry alike.