IMO CO₂ regulations 2026: What will change for exporters

1 January 2026
Reading time: 3 minutes

Why 2026 will be a turning point

From 1 January 2026, stricter climate regulations from the International Maritime Organisation (IMO) will come into force. These relate in particular to CO₂ efficiency, emissions transparency and preparation for global pricing mechanisms. For exporters, this means more data, more responsibility – and more planning effort.

Key elements include stricter CII targets for 2027–2030, new auditing and reporting requirements, and initial market instruments for CO₂ pricing. Those who set the right course today will ensure operational stability and strengthen their own sustainability balance sheet.

Overview of IMO instruments

EEXI – Energy Efficiency Existing Ship Index

Assess the technical efficiency of existing ships, for example through power limitation or optimisations to the hull.

CII – Carbon Intensity Indicator

Measures annual CO₂ intensity in gCO₂ per tonne-kilometre. Shipping companies must gradually improve their fleets. Poor ratings (D or E) require improvement.

SEEMP Part III

Energy management plan at ship level with CII monitoring and catalogue of measures in case of deviations.

DCS – Data Collection System

Collects operational data on fuel consumption and emission factors as a basis for audits and reports.

Net Zero Framework (NZF)

Political and technical framework for the introduction of fuel standards and pricing elements from 2028 onwards.

Timeline 2024–2030: What exporters should bear in mind

  • 2024–2025Review of existing IMO measures, preparation for phase 2
  • from 1 January 2026Start of Phase 2 revision, stricter CII requirements, new audit obligations
  • 2027–2030: Annually increasing CII targets with operational implications (e.g. routing)
  • from 2028Implementation of CO₂ cost components in freight rates

Impact on quotations, routes and documents

1. Offers & CO₂ transparency

Offers increasingly include CO₂ figures such as gCO₂/tkm or well-to-wake values. Check:

  • Unity and methodology of calculation
  • Source and measurement method
  • Ship and service reference (IMO number, CII rating)
  • Data quality and auditability

2. Timetables & Routing

Driving more slowly to increase efficiency may result in changed ETAs. Recommendation:

3. Gate-Ready & Documents

In addition to the standard documentation, RoRo transports require:

  • Vehicle with no visibility
  • Fuel level below ¼
  • Photo documentation (exterior/interior/VIN)

Notes:
What do I need to bear in mind for a RoRo shipment?

Catalogue of measures: How to make your supply chain IMO-ready

Tactical (0–3 months)

  • Incorporate CO₂ criteria into tenders
  • Plan routes with flexible windows
  • Enforce gate-ready standards internally

Operational (3–12 months)

  • Analyse carrier services according to CII ratings
  • Align insurance cover with efficiency measures
  • Set up EDI and tracking workflows

Strategic (12–24+ months)

  • Align own Scope 3 targets with carrier targets
  • Testing fuel alternatives in pilot projects
  • Add contract clauses on emissions compliance

Three scenarios compared

scenariosetupCO₂ transparencyRiskRecommendation
base1 carrier, fixed ETDrudimentary (PDF)highPlan A/B departures
Advanced2 carriers, flexible windowsstandardised (gCO₂/tkm)moderateDefine KPIs in RFQ
leaderMulti-carrier, CO₂ targetgranular (WtW, IMO)lowUse bonus/penalty clauses

Common mistakes - and how to avoid them

  1. Only CO₂ on request → Request standard KPIs
  2. AIS instead of event tracking → Integrate EDI events
  3. No flexible window → Provide A/B departures
  4. Unclean gate-ready vehicles → Use checklists
  5. One carrier per lane → Diversify portfolio

Checklist: Your 10 steps through the IMO CO₂ regulations 2026

  1. Analyse trade lanes
  2. Define CO₂ KPI set
  3. Update tenders
  4. Review carrier roadmaps
  5. Integrate live timetables
  6. Sharpen the gate-ready process
  7. Establish data workflow
  8. Review insurance policies
  9. Synchronise customs processes
  10. Conduct quarterly reviews

FAQ: IMO CO2 regulations 2026

What specifically will change from 2026 onwards?
More binding CII requirements, stricter audits and more emissions data in tenders.

As an exporter, do I have to report to the IMO myself?
No, but you should request and document CO₂ KPIs (Scope 3).

Will freight rates rise as a result of the new rules?
Additional CO₂ costs possible, exact figures only available on quotation basis.

What is the difference between EEXI and CII?
EEXI measures technical efficiency, CII measures operational CO₂ intensity.

Are there any additional regional regulations?
Yes, e.g. EU ETS or FuelEU Maritime depending on the route.

Conclusion: Through 2026 with data, flexibility and strong partners

The IMO CO₂ regulations for 2026 bring more responsibility, but also more controllability. Those who use CO₂ data intelligently, create flexibility in logistics and enforce gate-ready standards will remain able to deliver – even with dynamic CII adjustments.

Plan ahead, rely on transparent partners and secure reliable CO₂ data for a sustainable export business.

Disclaimer: All information in this article has been carefully researched but is subject to change at any time. ODS Orient accepts no liability for the topicality, accuracy and completeness of the information provided.

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