[By: INTERCARGO] The International Association of Dry Cargo Shipowners (INTERCARGO) has submitted proposals to the International Maritime Organization (IMO) calling for a review of the Carbon Intensity Indicator (CII) at the 82nd session of the Marine Environment Protection Committee (MEPC 82), being held between 30th September and 4th October at the IMO Headquarters in London. Drawing on extensive studies that analysed data from over 5,600 bulk carriers, INTERCARGO has highlighted several key issues with the current CII system: Impact of idle time: The studies show a clear correlation between increased idle time and poorer CII ratings, particularly for smaller vessel sizes. This idle time, which includes periods in port or at anchorage, is often beyond the vessel’s control. Perverse incentives: The current CII framework may inadvertently encourage ships to run their main engines unnecessarily, for example when waiting at anchorage, potentially increasing overall emissions while improving their CII rating. Inconsistent efficiency indicators: Vessels with E ratings often have lower average CO2 emissions compared to those rated A to D, suggesting the CII does not accurately reflect a vessel’s true efficiency. Size-based disparities: Smaller bulk carriers, especially in the Handysize and Supramax/Ultramax segments, show a higher percentage of D and E ratings compared to larger vessels.

**Ship Design: The Key to Energy Efficiency**

INTERCARGO’s proposal is based on the CII, which is a system for assessing a ship’s energy efficiency. It is a complex system with various factors that contribute to a ship’s overall energy efficiency. These factors include:

* **Ship’s design:** The hull shape, size, and weight all play a role in a ship’s energy efficiency.

INTERCARGO Chairman, Mr Dimitris Fafalios, added: “The current CII framework, while well-intentioned, may be leading us down a path which contradicts our ultimate goal of reducing overall emissions. We’re seeing situations where ships might actually increase their total emissions to improve their CII rating. This is clearly not the outcome we’re aiming for so it is crucial that we refine this system to ensure it truly incentivises energy efficiency and emissions reduction across our industry.” INTERCARGO has urged the MEPC’s Working Group on Air Pollution and Energy Efficiency to examine how the CII can be adjusted to better align with the IMO’s decarbonisation goals for global shipping.