Shipping compliance has always been about CO2. That era is ending.
MEPC 83 (April 2025) established a Correspondence Group to develop verification frameworks for non-CO2 greenhouse gases. MEPC 84 (Spring 2026) will approve the final methodology. The clock is ticking.
What Are Non-CO2 GHGs?
Three gases matter for shipping:
| Gas | Warming Potential | Shipping Source |
|---|---|---|
| Methane (CH4) | 28-36x CO2 | LNG engines, biogas, fugitive emissions |
| Nitrous Oxide (N2O) | 265-298x CO2 | Biofuel combustion, incomplete oxidation |
| Black Carbon | Climate forcer | Incomplete combustion, HFO |
Methane is the immediate concern. LNG-fleet operators take note: your climate benefits vanish if methane slip exceeds FuelEU limits.
The Verification Gap
Current regulations ignore non-CO2 gases:
| Regulation | Non-CO2 Coverage |
|---|---|
| EU ETS | CO2 only |
| FuelEU | CH4 slip factors defined, N2O pending |
| CII | No adjustment |
This gap won't last. MEPC 84 will introduce:
- Measurement methodology for CH4 and N2O
- Verification standards for onboard testing
- Default vs. measured emission factors
- Onboard carbon capture protocols
Why Small Fleets Should Care
Enterprise players (DNV, Lloyd's) focus on 50+ vessel clients. Your 5-15 vessel operation falls through the cracks.
The opportunity: Advisory services tailored to small fleet budgets and complexity.
What Operators Should Do Now
- Baseline your emissions — Know your CH4 and N2O output
- Understand methane slip — If you run LNG, measure actual emissions
- Monitor MEPC 84 — Spring 2026 will bring clarity
- Prepare for verification — Measurement systems are not cheap, but penalties will be pricier
The Bottom Line
Non-CO2 verification is not theoretical. It is the next compliance layer. Fleets that prepare now avoid the scramble later.
Urgency: HIGH
Timeline: MEPC 84 (Spring 2026)
First-mover advantage: Significant for small operators willing to act early.
This post was derived from internal research on maritime compliance opportunities.