Navigating Net Zero: How Amendments to MARPOL Annex VI will Shape Africa’s Maritime Future
By Hannah Elliott, Mwathi Kitonga, Fred Kung’u and Elvin Nyukuri
A Turning Point in Maritime Climate Governance
In April 2025, the International Maritime Organization (IMO), the UN specialized agency responsible for preventing pollution from ships, approved historic amendments to the MARPOL Annex VI regulations for the prevention of air pollution from ships during the 83rd session of its Marine Environmental Protection Committee (MEPC 83). The amendments introduce the world’s first global greenhouse gas (GHG) pricing mechanism and establish the IMO Net-Zero Framework, including a new fuel standard for ships and the creation of the IMO Net-Zero Fund. The amendments are the IMO’s most concrete response to date to the growing pressure to reduce emissions in international shipping. Once adopted, they will become mandatory for large ocean-going ships over 5,000 gross tonnage, which emit 85% of the total CO2 emissions from international shipping. While debates persist over whether these measures match the scale of the ongoing climate crisis, they represent a pivotal shift in the multilateral decarbonisation approach worldwide. For Africa, these amendments are more than just a regulatory update—they represent both a challenge and an opportunity to reshape the maritime transport future of the continent.
Compliance and Climate Finance
The amendments will require ships to comply with a global fuel standard mandating the progressive reduction of their annual greenhouse gas fuel intensity (GFI), calculated using a well-to-wake life cycle approach. In parallel, ships will also be subject to a global economic measure: those exceeding the GFI threshold must acquire remedial units, paid for with contributions to the IMO Net Zero Fund, to offset their excess emissions, while ships operating on zero or near-zero emission technologies will be eligible for financial incentives, disbursed from the Net Zero Fund. The revenue from the Fund is also earmarked for supporting a just transition and the mitigation of negative impacts on vulnerable states, such as small island developing states, least developed states, and developing states, through technology transfer and capacity building.
The implications of the IMO Net Zero Framework for African states are immediate and far-reaching. Under the amendments, only countries that have ratified Annex VI will be eligible to cast their vote for the new Net Zero Framework in the IMO’s extraordinary Marine Environment Protection Committee meeting in October 2025; at the time of writing, only 17 African countries are parties to Annex VI. More critically, access to the Net Zero Fund will also be restricted to those states which are party to Annex VI. Unless swift action is taken, a large proportion of the continent will be disqualified from accessing critical funding meant to support low-emission shipping and port infrastructure upgrades. More African countries need to ratify and domesticate the MARPOL 73/38 Convention in order to benefit from the Fund.
For countries like Kenya, which have ratified MARPOL Annex VI and where Ocean economy ambitions intersect with climate vulnerability, the stakes are particularly high. Kenya’s Nationally Determined Contributions (NDCs) outline bold adaptation and mitigation goals, but the maritime sector remains weakly integrated into climate planning. Tapping into the Net Zero Fund could serve as a bridge, supporting port energy efficiency projects such as the provision of shore power to vessels while they are docked at the ports of Mombasa and Lamu and the production and supply of alternative marine fuels produced with Kenya’s abundance of renewable energy.
Africa’s Maritime Divide: A Call for Unity
The amendments to MARPOL Annex VI reveal structural inequalities present in Africa’s maritime sector. Beyond the critical issue of ratification, African states such as Liberia and South Africa, which have strong flag registries and well-established maritime institutions are better placed to adopt the amendments and capitalize on new funding opportunities. Meanwhile, key port states and trade hubs with weaker institutions risk being overlooked. This disparity could exacerbate the already widening gap between early adopters and those lagging behind, thereby undermining efforts to unify Africa’s maritime climate response.
There is a need for regional cooperation and strategic alignment. In the absence of a coordinated strategy in previous rounds of negotiations at IMO, Africa’s disjointed response may weaken its negotiating leverage in upcoming discussions on a 2028 GHG strategy and the long-term regulatory measures required to achieve it. At a moment when equity is becoming increasingly pivotal in global climate discussions, Africa needs to rally and amplify its unified continental voice. Through solidarity, Africa can ensure that its priorities – equitable fund distribution, capacity building and climate justice – shape the IMO’s agenda.
Beyond Compliance: An Opportunity for Strategic Domestication
Domestication of the MARPOL Convention and amendments should not merely be seen as a legal exercise. It is a strategic catalyst that requires deliberate policy reforms, resource mobilisation, and institutional strengthening. Maritime authorities must work across ministries to integrate shipping into national climate and economic development plans. Regional Economic Communities (RECs) like ECOWAS, SADC, and COMESA can play a key role in harmonising standards, while institutions like the African Union Commission and the African Maritime Transport Charter can help consolidate a shared continental position.
This transition also represents an opportunity for Africa to incorporate sustainable development into its utilization of maritime resources, not solely for trade and resource extraction, but as an integral component of a wider climate and development framework. From establishing clean energy corridors, developing green ports, or creating regional shipping hubs, the transition towards decarbonized shipping holds promise for sustainable growth.
Securing Africa’s Seat at the Table
The next round of IMO negotiations will be critical in determining how funds are governed, distributed, and monitored. African states have historically been weakly positioned in international maritime governance; low levels of ship ownership, in part due to national and regional shipping lines being competed out of the industry by foreign firms during the post-independence period, have rendered African states receivers rather than deciders on rules pertaining to shipping, while limited technical expertise hinders participation at IMO. The continent must strategize to lead global maritime governance, not just follow, ensuring it is at the table, not on the menu, as maritime climate rules continue to evolve. In particular, it will be important to negotiate simplified access to the IMO Fund and ensure that revenue redistribution reflects Africa’s developmental and environmental priorities. The MARPOL Annex VI amendments offer a rare opportunity. If Africa can seize it, the continent stands to reposition itself in a sector where it has long been sidelined. If not, the continent risks once again sailing in the wake of others’ decisions and ambitions.
To read more about EMG-K, please see the project website. The authors are members of the EMG-K research team.
Hannah Elliott is an Assistant Professor at the Department of Management, Society and Communication, Copenhagen Business School.
Mwathi Kitonga is a PhD candidate at the Centre for Advanced Studies in Environmental Law and Policy, University of Nairobi.
Fred Kung’u is a Graduate Assistant at the Centre for Advanced Studies in Environmental Law and Policy, University of Nairobi.
Elvin Nyukuri is a Senior Lecturer at the Centre for Advanced Studies in Environmental Law and Policy, University of Nairobi.
