
Shipping and the Environment
Overview
Shipping is a growing source of transport greenhouse gas emissions and a major source of air pollution, causing health problems, acid rain and eutrophication.
It’s estimated that between 2007 and 2012 the shipping sector emitted about 1,000 Mt CO2 per year, about 3.1% of annual global CO2 emissions. In 2005, in the seas surrounding Europe, sulphur dioxide (SO2) emissions from international shipping were estimated at 1.7 million tonnes a year, nitrogen dioxide (NOx) emissions at 2.8 million tonnes, and particulate matter (PM 2.5) at 195,000 tonnes. Since 2015, a 0.1% limit on fuel sulphur content in the North and Baltic Seas and the English Channel is thought to have considerably reduced ship sulphur emissions in these areas – but there is still much more to be done.
T&E works together with other members of the Clean Shipping Coalition to reduce air pollution and climate impacts of shipping globally and in Europe.
What’s Being Done about Shipping’s Climate Impact?
In April 2018, the United Nations’ global shipping body, the International Maritime Organisation (IMO), agreed a draft greenhouse gas (GHG) strategy committing the shipping sector to reducing emissions by at least 50% by 2050 compared to 2008. It envisions total shipping GHG emissions peaking as soon as possible while at the same time the sector pursues efforts to phase them out entirely. The strategy specifically calls for “a pathway of CO2 emissions reduction consistent with the Paris Agreement temperature goals”. The full text of the Initial IMO Strategy on reduction of GHG emissions from shipping can be downloaded here.
Monitoring, Reporting, and Verification of Shipping Emissions
The EU regulation on monitoring, reporting and verification (MRV), agreed in 2015 and implemented in 2018, requires operators of all ships above 5,000 gross tonnes calling at EU ports to monitor and publicly report annual emissions every year. Three metrics which measure the environmental performance of ships are used: the theoretical design energy performance of the ship according to the IMO’s Energy Efficiency Design Index (EEDI); real-world fuel consumption; and real-world operational energy efficiency, which is the amount of fuel consumed divided by transport work (that is, the amount of cargo carried multiplied by distance covered).
The more cargo a ship can carry using the same amount of fuel, the more efficient and cheaper it is to run. The publication of ships’ real-world operational energy efficiency will provide shipping users in Europe and worldwide with transparent data to identify the most efficient ships and practices. This can trigger a virtuous cycle of increased competition among operators and ship owners, which will drive fuel savings and emissions reductions. The MRV is intended as a stepping stone for an eventual measure to require actual emissions reductions.
Should Shipping Be Included in the Emission Trading System?
In 2016, after the adoption of the MRV Regulation and the Paris Agreement, there was still no sign of global action at IMO meetings. This led the European Parliament to push for the inclusion of shipping in the EU emissions trading system (ETS) after the European Commission failed to include the sector’s emissions in their phase 4 ETS review proposal. The proposal would include EU-related shipping emissions under the ETS from 2023 if the IMO has not delivered a global deal with short-term measures to reduce emissions from shipping by then – coinciding with the end of the IMO’s seven-year GHG work plan. According to the Commission’s own 2013 impact assessment, shipping CO2 emissions could be reduced cumulatively by 80 million tonnes by 2030 – the total annual emissions of Austria – if the sector were included in the ETS. Read our briefing here.
What about Air Pollution from Ships?
In October 2012 the European Council formally adopted the revision of the EU Directive limiting the sulphur content of fuels used by ships in EU seas. From January 2015, ships were only allowed to use fuels with a maximum of 0.1% sulphur content, down from 1.5% previously permitted in the North Sea, Baltic Sea and English Channel. They could either use cleaner fuels, which are more expensive, or install abatement technologies such as scrubbers. Read our briefing on the issue.
In parallel, ships sailing in other EU waters and the rest of the world will be allowed to use fuels with a maximum of 0.5% sulphur content from 1 January 2020 (adopted by the IMO in 2016). T&E played a significant role in securing 2020 as the effective start date of the global 0.5% sulphur content limit. T&E, through the Clean Shipping Coalition, secured a seat at the steering committee overseeing the IMO fuel availability study. The study has analysed whether or not there would be enough 0.5% sulphur content compliant fuel available in 2020 to start the new standard in 2020 or delay it to 2025. At the steering committee, T&E made sure the study was performed by a neutral consultant (CE Delft) and not the one favoured by industry, which had in the past concluded there would not be enough compliant fuel in 2020. The sulphur cap enters into force January 2020.
Shipping and Climate Change
Overview
At current growth rates, shipping could represent some 10% of global greenhouse gas emissions by 2050. Which measures could reduce its contribution to climate change?
What Is the Impact of Shipping on Climate Change?
The Third IMO GHG Study (2014) estimated that for the period 2007-2012, shipping emitted about 1,000 Mt CO2 per year, equaling approximately 3.1% of annual global CO2 emissions. The latest update to the study by CE Delft projects shipping emissions to increase by up to 120% by 2050 if other sectors decarbonise successfully. Under a business-as-usual scenario and if other sectors of the economy reduce emissions to keep the global temperature increase below 2 degrees Celsius, shipping could represent some 10% of global GHG emissions by 2050.
Shipping also contributes to climate change through emissions of Black Carbon, tiny black particles, produced by combustion of marine fuel. The highest amounts of black carbon particles are produced by ships burning heavy fuel oil. Black carbon accounts for 21% of CO2-equivalent emissions from ships, making it the second most important driver of shipping’s climate impacts after carbon dioxide. Currently there are no regulations controlling black carbon emissions from shipping.
Is Shipping Included in the Paris Agreement?

Until the Paris agreement was finalised at the end of 2015, the major climate agreement in force was the Kyoto Protocol which tasked developed countries to work through the IMO to cut emissions. The Paris agreement is different. Unlike Kyoto, which had specific emission targets only for developed countries, the Paris agreement requires all parties to address all emissions. Parties are required to establish ‘economy-wide’ emission reduction targets, and shipping is clearly a key part of the economy. Read more here.
What Action Is the IMO Taking to Address Climate Change?
In April 2018 the IMO agreed a draft greenhouse gas strategy for shipping requiring the shipping sector to reduce its emissions by at least 50% by 2050 compared to 2008’ while pursuing efforts towards phasing them out as soon as possible. It was agreed that carbon intensity of international shipping should decline with reductions in CO2 emissions per transport work, as an average across international shipping, by at least 40% by 2030, pursuing efforts towards 70% by 2050, compared to 2008.
This is to be achieved by an agreed set of short, medium and long measures which are the subject of ongoing negotiations. The candidate short-term measures, include strengthening the energy efficiency requirements for existing ships (EEDI), speed and other technical and operational measures. CE Delft has analysed the impact of the proposed short-term measures on emissions and concludes that only with measures that change operational practices (for example, the vessel speed) the 2030 target can be met. On their own, technical measures or measures that remove market barriers will not improve carbon intensity sufficiently to meet the global goal for reducing energy intensity of shipping of 40% by 2030.
Despite these plans and many successive rounds of negotiations, the IMO has so far failed to adopt reduction measures to set the maritime sector on a pathway compatible with the temperature goals of the Paris Agreement.
What Is the EEDI?
The IMO’s Energy Efficiency Design Index (EEDI), approved in July 2011, is the first globally-binding design standard aimed at abating climate change from shipping. It applies to (almost) all new ships and entered into force in 2013. The index requires new ships to become more energy efficient, with standards that will be made increasingly more stringent over time. Read our questions and answers on the IMO’s EEDI.
How Much More Fuel Efficient Will EEDI Ships Have to Be, and by When?
Different classes and sizes of ships will have different standards to meet. Standards are compared to the baseline, set as the average efficiency of ships built between 1999-2009.
- Phase I: an overall 10% improvement target in vessel energy efficiency applies to new ships built between 2015 and 2019;
- Phase II: ships built between 2020 and 2024 will have to improve their energy efficiency by 15 and 20%, depending on the ship type;
- Phase III: Ships delivered after 2025 will have to be 30% more efficient;
Smaller ships have different efficiency requirements for each phase.
Different classes and sizes of ships will have different standards to meet. Standards are compared to the baseline, set as the average efficiency of ships built between 1999-2009.
- Phase I: an overall 10% improvement target in vessel energy efficiency applies to new ships built between 2015 and 2019;
- Phase II: ships built between 2020 and 2024 will have to improve their energy efficiency by 15 and 20%, depending on the ship type;
- Phase III: Ships delivered after 2025 will have to be 30% more efficient;
Smaller ships have different efficiency requirements for each phase.
New Ship Designs Are Less Fuel-Efficient Than Those Built in 1990
Ships built in the first decade of the 2000s were, on average, less fuel-efficient than those built in the 1990s, according to the first study of the historical development of the design efficiency of new ships. The data indicates that new ships, such as bulk carriers, tankers, and container ships, built in 2013 were, on average, 10% less fuel-efficient than those built a quarter of a century ago. The findings contradict the shipping industry’s narrative that it has been constantly improving its environmental performance.
EEDI Standards Are too Weak to Drive Improvements
Since 2013, however, the design efficiency of ships has improved considerably. Industry claims it is due to the EEDI but this cannot explain some of the extraordinary levels of over-compliance being seen by certain types of new ships with the 2025 Phase III EEDI requirements, which are complying almost a decade in advance and sometimes by a factor of 2. Cyclical higher fuel prices and low freight rates are more likely to be the main drivers of efficiency. Although the current over-compliance is welcome news, without strengthening the EEDI new ships will likely be less efficient when market conditions (long-term fuel prices and freight rates) change.
IMO discussion has acknowledged that the EEDI is not stimulating the uptake of new technologies, nor is it driving efficiency improvements. Read the study here. Since 2013 newly-built ships subject to the EEDI have performed much the same as those not covered by the regulation.
Almost three-quarters (71%) of all new containerships, which emit around a quarter of global ship CO2 emissions, already comply with the post-2025 requirements of the IMO’s Energy Efficiency Design Index (EEDI), according to a recent study based on the in-house analysis of the IMO’s own data. Additionally, the best 10% of new containerships are already almost twice as efficient as the requirement for 10 years’ time. This reveals that the EEDI is not incentivising the uptake of new technologies – all it may do is prevent a reversion to the worst designs of the past. These recent efficiency gains are part of a recognised historical trend for ship design efficiency to fluctuate according to economic cycles and fuel prices.
While reducing design speed is a very effective way of improving the design efficiency of a ship, there has in fact only been a modest reduction in the average design speed of new vessels according to the data analysed (and that has largely been limited to container ships). Meanwhile the design efficiency of new vessels has improved considerably. With efficiency improvements via new technologies and speed reduction largely untapped, there remains considerable potential for further design efficiency improvements but these will not be taken up unless the IMO incentivises them through stricter EEDI requirements.
What Is Slow Steaming?

Slow steaming refers to the practice whereby the (operational) speed of the ship is reduced. It basically means that the ship’s engine is not used at full power, thus saving fuel, reducing CO2 and air pollutant emissions.
Reducing ship speed by 10% will lead to a 27% reduction of the ship’s emissions. Overall, if all ships were to slow-steam, the available capacity on the market would be reduced (more ships would be needed to carry out the same transport work). If the additional emissions of building and operating these new ships were considered in the equation, then reducing the fleet’s speed by 10% would lead to overall CO2 savings of 19%.
Click here to see how a 20% reduction in ship speed would have a big impact on the climate and environmental footprint of shipping.
What Is the Purpose of Developing Slow Steaming?
Reducing the (operational) speed of ships multiplies the positive effects of an energy efficiency index, as it results in burning less fuel and therefore emitting less CO2 and other greenhouse gases. It also contributes to significantly lower emissions of air pollutants such as NOx and PM, with benefits greatly outweighing costs. Slow-steaming is often regarded as the most cost-effective way to reduce CO2 emissions as it can be done at almost no cost while translating into operational savings (for more on this see here).
Is the Industry Already Practicing Slow Steaming?
The industry started to slow steam in order to deal with the overcapacity resulting from the economic crisis and the subsequent drop in international trade. In a seminar organised in October 2011 by T&E and Seas at Risk, a representative of Maersk – the world’s largest container shipping company – described how they had been successfully using slow steaming since 2007, decreasing their engines’ load by 35% without any technical problems for ship owners. On the contrary, slow steaming has brought about fuel savings and reduced costs for maintenance and operational issues. The Maersk representative also said that his company sees no technical problems in implementing so-called super-slow steaming, which would mean decreasing the engine power by up to 90%.
Is Regulated Slow Steaming Legally and Technically Enforceable?
The findings of the first ever study on the feasibility of regulated slow steaming indicate that it is technically possible and legally enforceable without any major administrative burden and at no cost for the shipping industry. The report – carried out by the Dutch consultancy CE Delft, and commissioned by T&E and Seas at Risk – showed that reducing the average operational speed of the world fleet can have dramatic reductions in global ship CO2 emissions even after taking into account the need to build and operate additional ships to deliver the same amount of transport work. Slow steaming could be enforced globally using the Automatic Identification System (AIS), already mandatory on all large ships, since it provides real time information on the ship’s location, speed and direction. It is therefore impossible to cheat the system.
Is LNG and Option?
Liquid natural gas (LNG) is considered a potential alternative to conventional heavy fuel oil (HFO) and marine gas oil (MGO) partly due to its perceived environmental benefits as LNG can lead to a net decrease in SOx of up to 100% and of NOx emissions up to 90% compared to HFO. Also, some industry leaders and policymakers also consider LNG an option in delivering a pathway to decarbonisation for the shipping sector, leading to LNG being classified as an ‘alternative fuel’.
However research shows that, at best, LNG delivers at best up to 10% reduction of GHG compared to the replaced diesel fuel and all this under an optimistic methane leakage scenario. This level of potential GHG savings will likely be cancelled out in absolute terms because of the growth of the maritime trade. If methane leakage rates are higher, as some studies suggest, switching to LNG could result in increased GHG emissions compared to the diesel fuel it replaces. Analysis of laboratory engine tests show that modern dual-fuel LNG engines installed in new ships will have a GHG performance worse than MGO. Read our recent blog on LNG.
Shipping’s Impact on Air Quality
Overview
Learn about the health and environmental impacts of poor air quality due to shipping pollution – and what measures can be taken to reduce ship emissions.
How Does Shipping Harm Air Quality in Europe?
In 2005, in the seas surrounding Europe (the Baltic Sea, the North Sea, the North-Eastern part of the Atlantic, the Mediterranean and the Black Sea), sulphur dioxide (SO2) emissions from international shipping were estimated at 1.7 million tonnes a year, nitrogen dioxide (NOx) emissions at 2.8 million tonnes, and particulate matter (PM 2.5) at 195,000 tonnes. Due to the application from the start of 2015 of the 0.1% MARPOL limit in Sulphur Emissions Control Areas (SECAs) in the North and Baltic Sea and English Channel, ship-sourced sulphur emissions have reduced considerably in these areas. Emissions will be further reduced in the remaining EU seas with the implementation in 2020 of the global sulphur cap which limits sulphur to 0.5% in shipping fuel.
However, in the long term, emissions may rise due to increases in transport volume. Ships also emit Black Carbon, tiny black particles produced by combustion and released from the ship exhaust which contribute to heart and lung disease and are a danger to the environment. Find out more about black carbon, which is also a potent climate forcer, here.
How Much and How Fast Can Pollution from Ships Be Cut?
Technical measures to protect air quality from ships significantly are available and cost effective. These measures include the adoption of cleaner fuels, adding closed-loop ‘scrubbers’ or other exhaust gas cleaning devices to ships (for SOx), SCR systems (for NOx), slow steaming, and wider use of alternative sources of energy including wind propulsion, battery-electric propulsion, alternative fuels like ammonia and hydrogen, and port-side electricity.
Why Is It Important to Pay More Attention to Ship Emissions?

Ships’ detrimental impact on air quality continues to increase as the sector grows. Land-based emissions – SOx and NOx – on the other hand, particularly from fixed installations, have been reduced dramatically at great cost. NOx from shipping is set to exceed NOx from all EU land-based sources in the coming decade.
How to SO2, NOx, and Particle Emissions from Ships Pose a Threat to Air Quality and Human Health?
Poor air quality due to international shipping accounts for approximately 400,000 premature deaths per year worldwide, at an annual cost to society of more than €58 billion according to recent scientific studies. Through chemical reactions in the air, SO2 and NOx is converted into fine particles, sulphate and nitrate aerosols. In addition to the particles directly emitted by ships such as black carbon, these secondary particles increase the health impacts of shipping pollution. Tiny airborne particles are linked to premature deaths. The particles get into the lungs and are small enough to pass through tissues and enter the blood. They can then trigger inflammations which eventually cause heart and lung failures. Ship emissions may also contain carcinogenic particles.
The sulphur standard for shipping fuels that the International Maritime Organisation (IMO) adopted in 2008, and which will be implemented in 2020, is expected to save 26,000 lives a year in the EU as from 2020.
What Are the New Sulphur Standards Agreed to By the IMO and in the EU?
In 2008, the IMO revised its standards on the sulphur content of marine fuels (contained in MARPOL Annex VI). In October 2012, the standards were officially transposed in Europe. Under the current EU regulations:
- Since 2015, ships sailing in a Sulphur Emission Control Area (SECA) cannot use fuels with more than 0.1% of sulphur. The European SECAs currently include the Baltic Sea, the North Sea and the English Channel;
- Globally, ships are allowed to use fuels with sulphur content up to 3.5%. In 2016, the IMO confirmed 2020 implementation date of the new global of 0.5% sulphur standard outside SECAs;
- In Europe only, passenger ships are required to use fuels with sulphur content of maximum 1.5%, which was set in 2005 and updated in 2012 by the EU Sulphur Directive. From 2020, all ships sailing outside SECAs will have to comply with the 0.5% sulphur standard as required both by the EU Sulphur Directive and IMO’s MARPOL Annex VI;
- Different compliance methods are offered to shipowners. Instead of using low-sulphur marine diesel, marine gasoil or low and ultra-low sulphur heavy fuel oil (LSFO/ULSFO), ship operators can choose to switch to LNG, methanol or to cut their sulphur emissions by fitting exhaust systems with scrubbers or other exhaust gas cleaning technologies.
What Standards Are in Place to Reduce NOx Emissions from Ships?
The IMO MARPOL Annex VI has also strengthened the standards relating to ship NOx emissions, with NOx emissions from new ships to be cut by 16-22% as from 2011 and by 80% (only in NECAs) from 2016/2021 compared to 2000 levels.
While, ship fuel sulphur standards apply to the entire fleet, the NOx limits only apply to new ships. In addition, the strictest limit, called Tier III, currently only applies to new ships sailing in designated areas around North America from 2016, the NOx Emission Control Areas (NECAs).
In Europe, shipping in the Baltic Sea, the North Sea and the English Channel causes more than 800,000 tonnes of airborne nitrogen to be deposited each year, worsening the existing problem of eutrophication. Moves to have NOx included in the Baltic Sea, North Sea and English Channel ECAs were first discussed in 2007, but a series of environmental and economic studies to justify the NOx limits have taken several years to complete. In 2014, Russia failed to join its Helsinki Commission partners in agreeing to go forward with an application to the IMO. This coincided with Russian moves to delay the Tier III implementation dates for all NECAs which resulted in the fixed date (2016) in MARPOL for new ECAs to apply to North America only. Under the compromise reached, the start date of each new NECA will in the future be decided on an individual basis.
After many rounds of negotiations, the Helsinki Commission – grouping the nine countries with Baltic coastlines – agreed to apply to the IMO for stricter NOx emissions limits for new ships to apply in the Baltic. Simultaneously a similar application was lodged for the North Sea and English Channel. Both applications were approved by the IMO’s marine environment protection committee in October 2016 and adopted in July 2017. The stricter Tier III NOx standard will apply to new ships built after 2021 only while sailing in the North Sea, Baltic Sea and English Channel. NECA Tier III standard requires new ships built after 2021 to emit a maximum of 2-3.4 g of NOx/kWh compared to the current global Tier II standard of 7.7-14.4 g of NOx/kWh.
Since the IMO Tier III NOx regulation only applies to new ships and only when sailing in NECAs, additional measures are needed in Europe to address NOx emissions from the existing fleet. A levy on nitrogen oxides (NOx) emissions with revenues earmarked to fund the uptake of NOx abatement technologies would appear to be the most promising tool with achievable emissions reductions of up to 70%. In addition to a NOx levy with a fund, mandatory slow steaming of ships (with a levy and fund as an alternative compliance option) and a stand-alone levy on emitted NOx could also deliver emission reductions. Read our briefing here.
What Technological Innovations Will the Industry Have to Put in Place to Cut Air Pollution from Shipping?

The shipping industry has at its disposal a wide range of options and techniques to reduce shipping’s impact on air quality, most of which are already available on a large scale and easily implementable. These include:
- Zero emission berth standard in ports. Shore-side electricity can be used while ships are at the port, virtually eliminating ship-sourced SOx, NOx, PM, but also CO2. Alternatively ships could comply using alternative fuels such as hydrogen of ammonia.
- Using low-sulphur fuels: this is the easiest way of reducing ships’ impact on air quality. Shipping fuels in use outside sulphur emission control areas contain up to 3,500 times the sulphur content of fuels used by road transport in Europe. Low-sulphur fuels can make the ship’s engine run smoother and more efficiently with less operating problems and maintenance costs. Last but not least, using low-sulphur (non-residual) fuels reduces other pollutant emissions, such as black carbon, which is a potent global-warming agent.
- Scrubbers: an alternative compliance option to burning low-sulphur fuels approved by the IMO and the EU is for ships to install scrubbers. These could cut emissions of SO2 by 99% and considerably reduce emissions of other polluting particles. There are, however, concerns regarding wash-water discharges from open-loop scrubbers which deposit them in open seas and closed-water areas. This leads to higher pH levels in surrounding waters causing additional environmental concerns. Hence, open-loop scrubbers are not a sustainable alternative compliance method for marine sulphur standards.
- Internal engine modifications, such as water injection and exhaust gas recirculation (EGR – for 4-stroke engines): these are techniques to prevent NOx production during the combustion process. However, Tier III standard cannot be met by these methods alone.
- Humid air motor: adding water vapour to the combustion air can also reduce NOx emissions, however, not down to Tier III levels.
- Selective catalytic reduction (SCR): a system to treat exhaust gases after their production but before they are actually emitted. SCR is very effective in reducing NOx emissions far beyond Tier III. It’s already used by many ships worldwide and works better with low-sulphur fuels.
- Development of alternative energy sources such as battery electric propulsion, wind propulsion, hydrogen, ammonia, biofuels and fuel cells is ongoing and could be useful in the future.
- Hybridisation and electrification can deliver emission savings regardless of the type of fuel used to generate electricity.
What Should the EU and Member States Do to Reduce Air Pollution from Ships?
T&E has formulated a series of recommendations for the EU and its member states. These include:
- Develop a short sea shipping strategy to transition to zero emission vessels, starting with converting ferries, Ro-Ro and cruise ships to battery-electric propulsion.
- Implement a ‘zero emission at berth standard’ in all European ports.
- Transpose the international IMO standards for NOx emissions into EU law and adopt additional EU legislation to address NOx emissions from the existing fleet.
- Extend SECA and NECA standards to the rest of the EU seas: Mediterranean, Adriatic, Black and Irish Seas and the North East Atlantic.
- Monitor whether proper enforcement procedures are adopted in Europe in order to ensure compliance with the standards. For sulphur, a global ban on bunkering of non-compliant fuels (unless ships are fitted with EGCS) and a global mandate for continuous emissions monitoring systems (CEMSs) are the most promising methods of enforcement. The latter would serve for NOx enforcement, too.
- Adopt market-based measures to make polluters pay a fair price for the emissions the shipping sector is responsible for.
Cruise Ships
Some Facts
While cruise ships account for only a small proportion of the global shipping fleet, they have a disproportionate impact on air quality, habitats and the climate.
Cruise ships require more fuel due to the energy demand of the hotels and leisure facilities provided onboard as well as propelling the ships through the water. Cruise ships travel fast and close to the coastline, meaning that huge volumes of fuel are burned in close proximity to coastal populations.
Most cruise ships burn heavy fuel oil (HFO), which is the dirtiest fossil fuel available. Most of these ships also do not have any diesel particulate filters or selective catalytic converters to clean the exhaust – technologies that are standard for road vehicles like trucks. Currently heavy fuel oil contains 35000ppm sulphur, which is 3,500 times more polluting that road diesel. The standard in the sulphur emissions control areas (SECAs) is 1000ppm.

Cruise ships sailing outside the SECA but within the EU exclusive economic zone (EEZ) – up to 200 nautical miles off the coast – are subject to a more stringent 15000ppm sulphur standard. In January 2020, the global sulphur cap – outside SECAs – comes into force and the maximum sulphur content will be reduced to 5000 ppm (0.5%), still 500 times more than sulphur in road diesel. Also, cruise ships spending more than two hours at berth are already subject to the 1000ppm sulphur standard.
In 2017, luxury cruise brands owned by Carnival Corporation & PLC emitted 10 times more disease-causing sulphur oxide in European seas than all of Europe’s 260 million plus passenger vehicles. That’s according to an analysis of data of cruise ships sailing in European waters. Spain, Italy, Greece, France and Norway are the most exposed countries to cruise ship air pollution in Europe.

The analysis also reveals that even in SECAs, where the most stringent marine sulphur fuel standard is mandated, air pollution from cruise ships is still significant. In Denmark, for example, the coasts of which are entirely within SECAs, cruise ships emitted 18 times more SOx in 2017 than all of the country’s 2.5 million passenger vehicles in a year. This is a reflection of both the effectiveness of the Fuel Quality Directive for road transport fuels and the failure to implement equivalent standards for the shipping industry.
Ship SOx emissions will still remain considerably large compared to the passenger car fleet even after the introduction of the global 2020 marine sulphur cap. Also of concern are nitrogen oxide (NOX) emissions. In Denmark again, 107 cruise ships analysed emitted as much NOx in the Danish maritime economic exclusive zone (EEZ) as half the passenger cars operating in the country itself.
Cruise Ships in the Arctic
Arctic cruising is increasing fast with Svalbard in Norway experiencing 20% year-on-year growth in cruise tourism. Studies show that 86% of cruise ships visiting the arctic are burning HFO, a toxic sticky substance that if spilled would devastate the Arctic environment. The HFO Free Arctic campaign, of which T&E is a member, is calling for ships to stop using HFO when entering and transiting Arctic waters. A case study conducted on 2017 cruise ship voyage data shows that a switch to distillate for cruise ships in Arctic waters would amount to less than an extra €7 per day per passenger. Read more here.
Recommendations
In order to address (cruise) ship air pollution and also eliminate the climate impact of shipping, we recommend the below EU regulatory measures:
- Zero-emission berth standard for all European ports. Ships could either switch off their auxiliary engines and connect to land electricity grid, or implement something of equivalent nature.
- More stringent air pollution standards to apply to cruise ships.
- Extend the emission control areas, currently in place in the North and Baltic Seas, to the rest of the EU seas and to tighten marine SECA standard in Europe to 10ppm, equivalent to fuel used in road transport.
- Cruise ships to become first-movers in regulations to decarbonise the sector. For example, cruise ships should also be the first required to switch to zero emission propulsion in EU territorial waters and EEZ.
Arctic Shipping
Overview
Shipping traffic in the Arctic is likely to grow significantly over the coming decades. This activity is already exacerbating climate change and endangering delicate eco systems.
Studies estimate that overall shipping activity in the Arctic will increase by more than 50% between 2012 and 2050. It will mean continuing shrinkage of Arctic summer sea ice. Global warming has led to the thinning of polar ice, to the point where increasing numbers of ships are using the Arctic shipping routes (mainly the Northwest Passage north of Canada and the Northeast Passage north of Russia that includes the Northern Sea Route) which can cut journey times significantly. These routes are generally only open in summer, unless a ship is escorted by an ice breaker. Shipping companies are increasingly investing in vessels that can break through thin ice, but their voyages are generally limited to the summer months. However recently in 2018, the first ships made it through in winter without an ice breaker.
In 2012 T&E published a report Troubled waters: How to protect the Arctic from the growing impact of shipping. Without action, the increase in human activities in the Arctic will cause serious ecological damage. The report recommends that the shipping community recognise the potentially devastating effects of black carbon; that heavy fuel oil is the dirtiest fuel of any transport sector and should be banned; and that non ice-class vessels must be subject to a minimum hull strength to prevent accidents and spills that could have horrendous ecological consequences.
Heavy Fuel Oil Ban

The use of heavy fuel oil (HFO) by vessels operating in the Arctic poses a major risk to the marine environment as, if spilled, HFO is an extremely toxic and viscous marine fuel that breaks down slowly, particularly in colder regions like the Arctic. In the event of a HFO spill, lack of infrastructure, severe weather conditions and navigational hazards such as sea ice, would render spill response efforts nearly impossible. If an HFO spill were to occur in ice-covered waters, oil could be trapped in ice, causing it to persist even longer, and enabling its transmission over long distances.
Aside from the devastating acute impacts an HFO spill would have on sensitive Arctic ecosystems, studies on the long-term impacts of an Arctic spill demonstrate oil can remain within the affected area for more than a decade, impacting growth and reproductive rates of various species.
Many indigenous residents of the Arctic region depend on marine resources as a primary food source, use marine resources as a source of clothing and equipment and as material for handicrafts, and to support their limited commercial fishing, hunting, and ecotourism activities. Analysis has shown that it would cost passengers just the price of a glass of wine (less than €7) a day if cruise ships would stop burning highly polluting heavy fuel oil (HFO) when operating in the fragile Arctic environment.
Transport & Environment is a member of the Clean Arctic Alliance, a group of environmental NGOs committed to prohibiting the use of HFO as marine fuel in the Arctic.
At this time, phasing out the use of HFO as marine fuel is the most effective mitigation strategy and is currently the priority for the CAA. Accordingly, the CAA urges the International Maritime Organisation, the appropriate international body to regulate the use and carriage of HFO, to adopt a legally binding instrument to phase out the use of HFO as marine fuel in Arctic waters by 2020.
Originally published by Transport & Environment, republished with permission for educational, non-commercial purposes.