Open letter to co-legislators by environmental groups emphasising the importance of including climate pollution performance in the Union’s ship inspection risk framework using the Carbon Intensity Indicator (CII), a global measure in force globally since 2023 under the MARPOL Convention of the International Maritime Organization (IMO).

The EU’s Port State Control Directive is a crucial framework that upholds high standards in shipping safety, security, working conditions, and environmental protection. It applies the internationally agreed Paris Memorandum of Understanding on Port State Control, which, amongst others commits parties to ensure that ships calling at their ports comply with the standards listed in MARPOL. We applaud the efforts of the European Union towards its revision and the updating of criteria on shipping’s environmental impact.

The Carbon Intensity Indicator (CII) is a mandatory measure under MARPOL. It is key to reducing the climate and environmental impact of shipping, a sector where significant and affordable reductions are possible in this decade. It is a measure of carbon intensity adopted at the International Maritime Organisation, including by the European Union, that awards labels “A” to “E”, to large commercial ships as of 2024.

As a goal-based metric, CII allows individual ships and companies to make use of any one of a variety of technical and operational measures at their disposal, like slow steaming or retrofitting Energy Saving Technologies (EST). When ships slow down to improve their CII, they are also less likely to collide with and kill/injure whales and other ocean wildlife, produce less underwater noise pollution, as well as air pollution increasing human health and less polluting in general.

CII is a technology agnostic means for the EU and Member States to minimise the risk of pollution and all-around risks in and around European ports, understanding that vessels not complying to such standard might raise concerns or suspicions for other negligence.

We, the undersigned, emphasise that the CII is an important tool for the EU and Member States to reduce risks and lead to minimise shipping’s environmental impact, and a further step towards modernisation of the EU Port Inspection regime. We therefore urge co-legislators to include CII in the Port State Control Directive.

Source: Global Strategic Communications Council (GSCC)