What the Sea Cargo Charter is and is not
The Sea Cargo Charter is a voluntary climate-disclosure framework, not a commercial contract. Launched on 7 October 2020, it was created by the Global Maritime Forum to give cargo buyers and shipping operators a standardized method for measuring, assessing, and publicly reporting whether their chartered shipping activities are aligned with the International Maritime Organization’s greenhouse-gas reduction targets.
That distinction matters because the phrase “sea cargo charter” can refer to two entirely different things in shipping. In commercial practice, a charterparty (from the Latin charta partita, a divided document) is the legal contract between a shipowner and a charterer specifying freight rates, vessel hire terms, cargo description, port obligations, and loading/discharge conditions. The Sea Cargo Charter framework is nothing of the kind. It imposes no freight terms and creates no contractual rights over a vessel. It sits alongside a charterparty and creates voluntary reporting obligations for signatory companies about the climate performance of the voyages their charterparties generate.
The framework uses the Energy Efficiency Operational Indicator (EEOI) as its emissions intensity metric. EEOI expresses the GHG emissions produced to move one tonne of cargo one nautical mile, measured in grams of well-to-wake CO2 equivalent per tonne-nautical mile (gCO2e/tnm). Each signatory calculates EEOI across its chartered voyages and compares the result against a decarbonization trajectory derived from the 2023 revised IMO GHG Strategy, producing a Climate Alignment Score that is published annually.
Background: the cargo-buyer gap after the Poseidon Principles
When the Poseidon Principles for Financial Institutions launched in June 2019, shipping’s climate accountability infrastructure shifted. For the first time, lenders representing a significant share of global ship finance committed to reporting whether their loan portfolios aligned with IMO decarbonization goals. The framework used the Annual Efficiency Ratio (AER) drawn from IMO Data Collection System (DCS) submissions. Thirty-six banks, representing approximately 75% of the global ship finance portfolio, now participate.
But lenders are one step removed from operational decisions. Cargo buyers, by contrast, sit at the point where the commercial decision actually gets made: which vessel, on what voyage, at what speed, with what fuel. In 2018, the 20 largest commodity traders, mining houses, and oil majors collectively controlled chartering decisions for hundreds of millions of tonnes of bulk cargo per year. Their vessel-selection choices have a direct effect on fleet average emissions. An owner who invests in fuel-efficient vessels gains a commercial advantage only if charterers actually prefer those vessels when fixing. Without a charterer-side framework, the market signal was absent.
The Global Maritime Forum’s Annual Summit in Singapore in 2019 identified this gap. Cargill Ocean Transportation, Trafigura, Dow, Norden, Total, and Anglo American, among others, began developing a cargo-buyer equivalent. Technical guidance was provided by UMAS (University Maritime Advisory Services) and the Smart Freight Centre, the same organizations that contributed to the Poseidon Principles methodology. Legal input came from Stephenson Harwood.
Launch: 7 October 2020
The Sea Cargo Charter was publicly announced on 7 October 2020 at the Global Maritime Forum’s Annual Summit, held virtually because of the COVID-19 pandemic. The 17 founding signatories were: Anglo American, ADM (Archer Daniels Midland), Bunge, Cargill Ocean Transportation, COFCO International, Dow, Equinor, Gunvor Group, Klaveness Combination Carriers, Louis Dreyfus Company, Norden, Occidental, Shell, Torvald Klaveness, Total (now TotalEnergies), Trafigura, and Orsted.
Jan Dieleman, then president of Cargill Ocean Transportation, described the framework as providing “a standard greenhouse gas emissions reporting process” that would “simplify some of the complexities” in comparing vessel emissions across different trades and cargo types. Rasmus Bach Nielsen of Trafigura stated that “the shipping industry as a whole needs to adopt a transparent approach,” a position that Trafigura later reinforced by taking the role of Steering Committee Chair.
The 17 founding companies collectively moved bulk commodities comprising a substantial fraction of global seaborne trade. Together they represented primarily dry bulk and tanker cargo: grain, oilseeds, coal, iron ore, crude oil, and refined products.
The three-framework family
The Sea Cargo Charter is one of three aligned transparency initiatives developed under the Global Maritime Forum umbrella, all sharing the same four core principles.
Poseidon Principles for Financial Institutions (launched June 2019): 36 signatory banks measuring climate alignment of their ship finance portfolios using AER and IMO DCS data. Covers approximately 75% of global ship finance.
Sea Cargo Charter (launched October 2020): signatory charterers and shipowners measuring climate alignment of their chartering activities using EEOI and voyage-level data. Covers approximately 18% of global wet and dry bulk cargo by volume as of 2024.
Poseidon Principles for Marine Insurance (launched December 2021): signatory marine insurers measuring climate alignment of their hull and machinery portfolios using IMO DCS data. Covers a share of global marine insurance premiums.
All three frameworks align against the same trajectory (the 2023 IMO GHG Strategy), publish annual disclosures, require third-party verification, and are administered by the Global Maritime Forum secretariat. The deliberate commonality means that a vessel financed by a Poseidon Principles bank, insured by a PPMI insurer, and chartered by a Sea Cargo Charter signatory appears in all three disclosure cycles. Each party discloses its own exposure, not the same number twice: the bank reports loan value, the insurer reports hull insurance premium, the charterer reports tonne-miles of cargo.
The key technical distinction is data source and metric. The Poseidon Principles use AER (annual fuel consumption × CO2 emission factor, divided by DWT × distance sailed), fed by the IMO DCS which provides annual vessel-level aggregates. The Sea Cargo Charter uses EEOI, fed by voyage-level data that the charterer collects directly because it knows the actual cargo lifted (from bill of lading quantities) and the laden distance (from fixture terms and noon reports). EEOI is more granular: it allocates emissions to the specific cargo on that specific voyage rather than spreading annual vessel emissions across full DWT capacity. That granularity matters for a charterer whose voyages may include part-load fixtures, transshipments, and multi-port itineraries.
The four principles
The Sea Cargo Charter operates on four principles, consistent across all three Global Maritime Forum frameworks.
Assessment requires signatories to calculate the GHG emission intensity (EEOI) and total GHG emissions of their chartering activities annually, then compare results against the IMO-derived decarbonization trajectory. The methodology uses measured data (actual fuel consumption by type, actual cargo quantities from bills of lading, actual laden distance sailed). Estimates are permitted only for ballast legs when measured data is unavailable. Since the 2023 methodology update, all calculations use a well-to-wake CO2e perspective, covering not only combustion emissions but also upstream production and processing of fuels.
Accountability requires that data used in the assessment is practical, unbiased, and accurate. Signatories rely on reliable data sources and, after two reporting cycles, must transition to the “Preferred Pathway Track” requiring third-party verification. Over 90% of 2024 data was third-party verified, up from approximately 50% in earlier cycles. Accredited verifiers include major class societies and specialist emissions verifiers.
Enforcement provides the operational mechanism. The framework recommends a Sea Cargo Charter Clause that signatories can incorporate into charterparties to ensure data collection obligations flow through to vessel operators and owners. Without a contractual obligation to receive fuel consumption and voyage data from the shipowner, a charterer cannot calculate EEOI accurately.
Transparency requires annual public disclosure of results through the Sea Cargo Charter Secretariat. The Annual Disclosure Report is published once per year, with each signatory’s climate alignment score disclosed alongside the aggregate results.
The EEOI metric and the climate alignment calculation
The EEOI formula is:
where is the mass of fuel type consumed on the voyage (metric tonnes), is the well-to-wake CO2 equivalent emission factor for fuel type (gCO2e per gram of fuel), is the global warming potential factor for non-CO2 GHG species in that fuel’s combustion (methane, nitrous oxide), is the cargo mass in metric tonnes from the bill of lading, and is the laden voyage distance in nautical miles.
The result is in gCO2e per tonne-nautical mile (gCO2e/tnm).
Emission factors follow a prescribed cascading priority: MEPC-approved factors for conventional fuels (HFO, VLSFO, MGO, LNG) take precedence; the FuelEU Maritime database and the ecoinvent/GREET frameworks apply for alternative fuels where MEPC factors don’t exist.
For each signatory’s portfolio, the individual voyage EEOI values are aggregated into a portfolio-level score, weighted by transport work (tonne-miles). Comparing this aggregate against the relevant point on the trajectory for each vessel type and size class produces the Climate Alignment Score, expressed as a percentage deviation from the trajectory. A negative score means the signatory’s activities are below the trajectory (better than required); a positive score means they are above it (worse than required).
The trajectory itself is expressed as a time series of permissible EEOI values by ship type, segment, and size. The Sea Cargo Charter Secretariat publishes updated trajectory tables annually, calibrated to the IMO 2023 GHG Strategy checkpoints. The January 2025 update revised these tables to reflect updated emission factors, slightly adjusting the absolute trajectory levels but preserving the underlying percentage-reduction targets relative to 2008.
The IMO 2023 GHG Strategy and the 2023 methodology update
The original Sea Cargo Charter (2020) aligned against the Initial IMO GHG Strategy adopted at MEPC 72 in April 2018 (MEPC.304(72)), which set a goal of reducing absolute GHG emissions from international shipping by at least 50% by 2050 relative to 2008.
The IMO adopted a substantially revised strategy at MEPC 80 on 7 July 2023 (MEPC.377(80)), the 2023 IMO Strategy on Reduction of GHG Emissions from Ships. The revised strategy made three major changes relative to the 2018 version:
- The 2050 target shifted from “at least 50% reduction” to “net-zero GHG emissions by or around, i.e. close to, 2050.”
- Firm indicative checkpoints were added: 20% reduction in 2030 (striving for 30%) and 70% reduction in 2040 (striving for 80%), both against a 2008 baseline.
- The scope of GHG emissions shifted from a tank-to-wake (combustion only) to a well-to-wake (full lifecycle, including upstream fuel production) perspective.
On 5 December 2023, the Sea Cargo Charter Steering Committee announced that the framework would align with the 2023 revised strategy, reporting against it for the first time in the 2024 Annual Disclosure Report (covering 2023 activity data). This made the Sea Cargo Charter methodology update simultaneous with a parallel update to the Poseidon Principles methodology, ensuring the three frameworks remained internally consistent.
For signatories, the 2023 update had two practical consequences. First, the trajectory became steeper: net-zero by 2050 requires a faster decline curve than 50% by 2050, so alignment scores in 2024 reflect a more demanding benchmark than in 2023. Second, the well-to-wake scope widened the CO2e accounting to include upstream emissions, which particularly affects signatories moving LNG cargo or using LNG dual-fuel vessels where methane slip becomes a counted quantity.
The January 2025 technical update refined the emission factor tables to match the latest IMO-approved sources, adjusting trajectory absolute values without changing the percentage targets.
Scope expansion: shipowners join charterers in 2024
From its launch through 2023, the Sea Cargo Charter was purely a charterer-side framework. Mandatory reporting segments were C1 (time charters where the signatory is the final time charterer) and C2 (voyage charters where the signatory is the voyage charterer).
On 2 April 2024, the Steering Committee announced an expansion to include shipowners. Under the expanded scope, segment S1 (voyage charterparties where the signatory is the owner) became a mandatory reporting segment for shipowner signatories. The committee framed the move as bringing owners and charterers under one common framework and methodology, with the aim of improving transparency and encouraging collaboration across the industry.
The reasoning is straightforward: a voyage charterparty involves both a charterer (who selects the vessel and pays the freight) and an owner (who operates the vessel and burns the fuel). Both have operational influence. Charterers can select higher-efficiency vessels and specify sailing speeds. Owners can invest in vessel upgrades, retrofit hull coatings, and optimize trim and ballast. A framework that captures both sides of the fixture creates more complete market signals.
By the time of the 2025 Annual Disclosure Report, 34 charterers and shipowners reported under the framework. Looking at the current signatory list, the 32 public signatories include a mix of commodity trading houses (ADM, AMAGGI Switzerland, Alvean, Bunge, Cargill, COFCO International, Gunvor Group, Louis Dreyfus Company, Trafigura, Wilmar International), energy companies (Equinor, TotalEnergies), mining and industrial groups (Anglo American, Heidelberg Materials, Holcim Trading, K+S Minerals and Agriculture, South32, Tata Steel Group), and shipping operators (Copenhagen Commercial Platform, Diana Shipping, Klaveness Combination Carriers, MC Shipping, Navig8 Group, Norden, Nova Marine Carriers, Stolt Tankers). Industrial and materials companies (Aluminium Bahrain/Alba, EBE, EGA, Global Chartering, Golden-Agri Maritime) fill the remaining slots.
Future mandatory requirements will expand scope further: from the 2026 Annual Disclosure Report (covering 2025 data), segments C4 and S4 become mandatory for any voyage not time-chartered out.
Reporting cycle and disclosure structure
Each signatory follows a defined annual reporting cycle:
Data collection (January to approximately May, year N+1): the signatory gathers voyage-level data for all chartering activities in calendar year N. Required inputs per voyage are: fuel consumed by type (metric tonnes, measured), the GHG emission factors applicable to each fuel, actual laden distance (nautical miles), and cargo transported (metric tonnes from bill of lading). Charter agreements incorporating the Sea Cargo Charter Clause receive data from vessel operators as part of the contractual data flow; others must request data bilaterally.
Third-party verification: signatories in the Preferred Pathway Track (required after two reporting cycles) engage an accredited verifier to review the calculation methodology and data quality. Over 90% of 2024 data underwent third-party verification, a notable jump from approximately 50% in the previous cycle, reflecting the growing proportion of signatories reaching the Preferred Pathway threshold.
Disclosure report preparation (spring/early summer, year N+1): the Secretariat aggregates signatory data and each signatory prepares its individual disclosure, including the portfolio-level Climate Alignment Score against the minimum and striving trajectories, scores by ship type, total tonne-miles, number of voyages, and year-on-year trajectory.
Annual Disclosure Report publication: the 2025 Annual Disclosure Report, covering 2024 data, was released on 12 June 2025. This timing is earlier in the calendar than the Poseidon Principles disclosure (which typically publishes later in the year), allowing charterers to use the results in their chartering strategy for the second half of the reporting year.
Beginning with the 2025 Annual Disclosure Report, signatories now publicly disclose the reporting percentage achieved, the verification pathway used, and the identity of their third-party verifier.
2025 Annual Disclosure: key results for 2024 data
The 2025 Annual Disclosure Report, released 12 June 2025 and covering 2024 chartering activities, showed the following:
34 signatories (out of 37 total at the time of reporting) submitted disclosures representing approximately 18% of global wet and dry bulk cargo transported by sea in 2024.
On aggregate, signatories were 12% behind the minimum IMO trajectory and 18% behind the striving trajectory for 2024. This is the second year of reporting against the steeper 2023 IMO GHG Strategy trajectories, so the absolute misalignment numbers are not directly comparable to earlier cycles which used the less demanding 2018 strategy baseline.
Within the cohort: 19 of 34 signatories reduced their emission intensity year-over-year. Eight improved their Climate Alignment Score (i.e., moved closer to trajectory). Ten signatories were within 10% of the minimum trajectory. Five achieved alignment with the minimum trajectory. Three achieved alignment with the striving trajectory.
The range of individual signatory misalignment scores ran from approximately -16.5% (below trajectory, the best performers) to +47.6% (well above trajectory) against the minimum ambition, and from approximately -14.8% to +54.7% against the striving ambition. The simple average misalignment was +16.9% against minimum and +21.9% against striving.
The 2024 report (covering 2023 data, released in 2024) showed a 17% average shortfall against minimum targets, compared to the 12% shortfall for 2024 data reported in 2025. That apparent improvement reflects a mix of genuine emissions reductions (slower steaming, vessel upgrades, biofuel blending) and the growing verification quality. It also reflects the change in signatory composition as shipowners joined in 2024.
Eligible vessel types and chartering segments
The Sea Cargo Charter covers international chartering of four vessel categories: dry bulk carriers, chemical tankers, oil tankers, and liquefied gas carriers. Container shipping is not covered (container lines typically operate under service contracts or slot charters, not voyage or time charters directly linking cargo buyer to vessel). Ro-ro and passenger vessels are also outside the current scope.
Since 1 January 2022, vessels under 5,000 gross tonnage are included, removing a threshold that had previously excluded smaller coastal bulk carriers from reporting.
For the chartering relationship itself, the framework uses four charterer segments (C1 through C4) and four shipowner segments (S1 through S4). C1 covers time charters where the signatory is the final time charterer in any charter chain. C2 covers voyage charters. C3 and C4 handle sub-charter and contract-of-affreightment scenarios. S1 covers shipowners operating under voyage charterparties. C1, C2, and S1 are the mandatory segments; C3, C4, S2, S3, and S4 expand the optional scope.
The relationship to voyage charter party and time charter party frameworks is purely mechanical: the charterparty is the commercial contract, and the Sea Cargo Charter Clause is an optional data-sharing addendum that signatories can include within that contract to secure the fuel consumption and voyage data they need for EEOI calculation.
Relationship to CII and the regulatory context
The Carbon Intensity Indicator (CII), which became mandatory for ships above 5,000 GT on international voyages from 1 January 2023 under MARPOL Annex VI Regulation 28 (MEPC.328(76) as amended), also measures carbon intensity per transport work. But CII and the Sea Cargo Charter measure from different perspectives.
CII is a ship-level, owner-side, regulatory metric. The IMO imposes it on the shipowner (or operator) to track annual vessel performance and receive an A-to-E rating. The required CII tightens by a reduction factor each year. Vessels rated D or E face mandatory corrective action plan obligations.
The Sea Cargo Charter is a portfolio-level, charterer-side, voluntary metric. It aggregates across all voyages a charterer undertakes, weighted by tonne-miles. There is no regulatory penalty for a charterer who reports a poor score; the incentive is reputational and commercial.
The AER metric used in CII calculations is closely related to the EEOI used in the Sea Cargo Charter. AER divides annual fuel-derived CO2 by DWT-miles across the vessel year. EEOI divides voyage emissions by bill-of-lading cargo mass times laden distance, voyage by voyage. For a fully loaded vessel on a direct voyage, AER and EEOI produce similar numbers; for part-loaded voyages, multi-port calls, or vessels in ballast, they diverge.
The practical interaction between CII and the Sea Cargo Charter is at the fixture stage. A charterer who reports under the Sea Cargo Charter has an incentive to prefer vessels with better CII ratings when selecting vessels to charter. A ship with a CII rating of A or B demonstrates lower carbon intensity than one rated D or E. This creates a secondary market effect: Sea Cargo Charter signatories exert commercial pressure on owners to maintain fleet efficiency, reinforcing the regulatory signal that CII already creates.
The IMO Net-Zero Framework (the global GHG levy and fuel standard taking effect from 2027) operates at yet another level: it prices the well-to-wake GHG intensity of fuels through a Greenhouse Gas Fuel Intensity (GFI) standard and levies charges on the gap between a vessel’s actual fuel intensity and the IMO benchmark. The Sea Cargo Charter’s 2023 methodology update to well-to-wake CO2e accounting positioned it to align with GFI accounting once GFI trajectories are confirmed.
For the EU ETS for shipping, which has applied to bulk carriers and tankers of 5,000 GT and above on qualifying voyages since 2024, the compliance obligation runs to the shipowner (or the ISM operator). The charterer bears EU ETS costs indirectly through freight rates or through contractual cost-pass-through clauses. EU ETS and Sea Cargo Charter reporting are distinct: the ETS uses EU MRV emissions data, whereas the Sea Cargo Charter uses EEOI calculated from bill-of-lading cargo data.
Comparison with related frameworks
| Dimension | Sea Cargo Charter | Poseidon Principles (Finance) | Poseidon Principles (Marine Insurance) |
|---|---|---|---|
| Launch date | October 2020 | June 2019 | December 2021 |
| Signatory type | Charterers and shipowners | Ship finance lenders | Marine insurers |
| What is disclosed | Climate alignment of chartering activities | Climate alignment of loan portfolio | Climate alignment of H&M insurance portfolio |
| Primary metric | EEOI (gCO2e/tnm, WtW) | AER (gCO2/DWT-nm, WtW from 2023) | AER from IMO DCS |
| Data source | Voyage-level bill of lading + fuel data | IMO DCS annual vessel aggregates | IMO DCS annual vessel aggregates |
| Weighting | Tonne-miles of cargo carried | Loan exposure (USD) | Insurance premium value |
| Trajectory base year | 2008 (per IMO 2023 strategy) | 2008 (per IMO 2023 strategy) | 2008 (per IMO 2023 strategy) |
| Trajectory type | Minimum and striving (two lines) | Aligned with IMO 2023 | Aligned with IMO 2023 |
| 2050 ambition | Net-zero by or around 2050 | Net-zero by or around 2050 | Net-zero by or around 2050 |
| Annual disclosure | Published annually (June 2025 for 2024 data) | Published annually | Published annually |
| Secretariat | Global Maritime Forum | Global Maritime Forum | Global Maritime Forum |
| Approximate coverage | ~18% of global wet and dry bulk cargo | ~75% of global ship finance | Portion of global H&M premiums |
| Signatories (2024/2025) | 32-37 depending on count date | 36 banks | Several leading marine insurers |
| Mandatory or voluntary | Voluntary | Voluntary | Voluntary |
| Regulatory basis | None (voluntary) | None (voluntary) | None (voluntary) |
All three frameworks share the same four principles (Assessment, Accountability, Enforcement, Transparency) and the same secretariat. The key technical distinction is data source: the Poseidon Principles and the Marine Insurance framework can rely on the IMO DCS, which provides standardized annual vessel fuel data. The Sea Cargo Charter requires voyage-level data because EEOI must allocate emissions to specific cargo, which the IMO DCS aggregate cannot support. This is why the Sea Cargo Charter has a more demanding data collection burden and why the Sea Cargo Charter Clause is important for operationalizing data flows between charterers and vessel operators.
How charterers use the framework operationally
A signatory to the Sea Cargo Charter integrates the framework into its chartering operations at three stages.
Pre-fixture screening: before fixing a vessel, many signatories apply vessel-efficiency filters. The RightShip GHG Rating system is widely used for this purpose: it assigns each vessel a letter grade (A through G) based on carbon intensity relative to a reference vessel of the same type and size. A charterer targeting a portfolio CAS that beats the minimum trajectory will systematically avoid vessels rated E, F, or G. Klaveness, Norden, and Cargill have all publicly described fleet-quality screening in their annual disclosures.
Fixture structuring: the Sea Cargo Charter Clause, when included in a charterparty, specifies how fuel consumption data flows from the owner to the charterer. Without this clause, the charterer must request data after the voyage and may face resistance from owners unwilling to share commercial fuel data. The clause can also specify speed instructions and operational parameters that support the agreed EEOI target.
Post-voyage reporting: after each voyage closes, the signatory calculates the per-voyage EEOI using the fuel data received and the bill-of-lading cargo quantities. These voyage EEOIs accumulate into the annual portfolio dataset that feeds the disclosure report. Third-party verifiers sample voyage records to confirm that the EEOI calculations are consistent with actual data.
The index-sea-cargo-charter calculator on this site implements the EEOI calculation and the Climate Alignment Score comparison against the current trajectory tables. The AER calculator provides the related AER calculation used by the Poseidon Principles. The CII attained calculator allows comparison of a vessel’s regulatory CII against its Sea Cargo Charter EEOI for the same voyages.
Notable signatories and sectoral patterns
The signatory base covers most major sectors of bulk cargo shipping, with some gaps.
Commodity traders: Cargill Ocean Transportation, Trafigura, Gunvor Group, Louis Dreyfus Company, COFCO International, Bunge, and ADM are all signatories. These seven companies collectively move substantial volumes of grain, oilseeds, metals, and energy products. AMAGGI Switzerland (a major Brazilian soybean and corn trader) and Wilmar International (palm oil) represent the emergence of non-European commodity traders in the framework.
Energy companies: TotalEnergies and Equinor are among the original signatories; Occidental joined at launch. These companies charter tankers for crude oil, refined products, and LNG. Their chartering volumes are large enough that their individual EEOI scores can shift the aggregate framework result.
Mining and industrial: Anglo American (copper, diamonds, iron ore), South32 (aluminium, coal, manganese), Tata Steel Group, Heidelberg Materials, and Holcim Trading represent a group where the cargo is often dense and the trade routes are long-distance (e.g., Australian coal to Japan, Brazilian iron ore to Europe), generating high tonne-miles per voyage. High tonne-mile weighting means these signatories have outsized influence on the aggregate portfolio score.
Shipping operators: Klaveness Combination Carriers, Norden, Diana Shipping, Stolt Tankers, Nova Marine Carriers, Navig8 Group, and Copenhagen Commercial Platform are among the shipowner-side signatories that joined after the April 2024 scope expansion. Their participation is notable: shipowners are the operational counterparty to charterers, and their presence means that EEOI calculations can be reconciled against vessel-side fuel records.
Absent sectors: major container lines (Maersk, MSC, CMA CGM, COSCO) have not joined; their chartering structures differ because they primarily operate vessels they own or have on long-term time charter rather than voyage-chartering cargo in the bulk manner the framework covers. Large retail importers who move container freight through third-party logistics providers (3PLs) are structurally absent: the 3PL aggregates the cargo, and the actual vessel charterer is the 3PL, not the brand. This leaves a significant portion of container shipping outside the framework.
Limitations
Voluntary coverage gap. The 32 current signatories represent approximately 18% of global wet and dry bulk cargo. The other 82% is outside the framework, including many mid-tier traders, most government-controlled cargo movements (grain reserves, strategic petroleum reserves), and all container shipping.
Data collection burden. EEOI requires voyage-level fuel data from vessel operators. Charterers without the Sea Cargo Charter Clause in their contracts must negotiate data sharing bilaterally. Some owners are reluctant to share fuel consumption data (which reveals operational efficiency that may affect future freight negotiations). This creates systematic gaps in datasets, particularly for older spot-market fixtures.
Well-to-wake complexity. The 2023 shift to well-to-wake accounting is methodologically correct relative to IMO ambition but adds complexity. Well-to-wake emission factors for LNG, biofuels, and other alternative fuels carry uncertainty ranges that can shift a signatory’s aggregate score meaningfully. The MEPC-cascading factor hierarchy manages this, but upstream emission factor uncertainty is real.
Tonne-mile weighting asymmetry. Long-haul trades generate proportionally more tonne-miles than short-sea trades. A signatory moving Brazilian iron ore to China generates far more tonne-miles per cargo tonne than one moving Norwegian aluminium to the Netherlands. The tonne-mile weighting means that the aggregate score reflects long-haul trade structures heavily. A signatory who switches from one long-haul commodity to another of similar efficiency sees little score change even if vessel quality has improved.
Trajectory uncertainty after 2030. The 2023 IMO GHG Strategy’s interim checkpoints (2030 and 2040) are described as “indicative.” The 2027 GHG Fuel Standard and IMO Net-Zero Framework levy decisions (under MEPC 83, expected 2025) may reshape the trajectory definition before the next methodology update. Signatories may find their 2025 and 2026 disclosures benchmarked against a trajectory that subsequently changes.
No regulatory backstop. The Sea Cargo Charter has no enforcement teeth beyond reputational pressure. A signatory who posts a poor Climate Alignment Score faces no fine, no permit denial, and no legal sanction. The framework’s effectiveness depends entirely on charterers, lenders, and counterparties treating the score as a commercial signal. Where freight markets are tight and vessel availability is constrained (as in 2022 to 2023 post-pandemic disruption), environmental preferences can be displaced by commercial necessity.
Scope 3 reporting integration. Most major commodity trading companies and oil majors now report Scope 3 emissions under the GHG Protocol, which includes chartered shipping as a Scope 3 Category 4 (upstream transportation) or Category 9 (downstream transportation) emission. The Sea Cargo Charter disclosure is one credible data source for Scope 3 reporting, but the two frameworks use different boundaries, and reconciling them requires care. A charterer who uses Sea Cargo Charter data for Scope 3 reporting must ensure alignment between the EEOI-based well-to-wake figure and the Scope 3 boundary definition in GHG Protocol terms.
Future direction
The Steering Committee’s published priorities for 2025 and beyond include several concrete items.
The January 2025 emission factor revision was a technical maintenance step. More significant is the planned integration with the IMO Net-Zero Framework GFI standard: once GFI trajectories are finalized under MEPC 83 (scheduled for 2025) and the associated levy mechanism is confirmed, the Sea Cargo Charter will need to decide whether to adopt the GFI intensity metric or maintain the EEOI metric alongside it. The two are related but not identical: GFI is defined in MJ energy terms per ship, while EEOI is in gCO2e per tonne-nautical mile per voyage.
The 2030 checkpoint creates a hard review point for the framework. If the simple average misalignment remains above 10% by 2028 to 2029, questions about the framework’s actual market influence will sharpen. The 2025 disclosure showing 12% average misalignment against the minimum trajectory means signatories need to close that gap in five years or fewer to reach the 2030 checkpoint. Five of 34 signatories were already at or below the minimum trajectory in 2024, showing that alignment is achievable.
The expansion to mandatory C4 and S4 reporting from 2026 will increase the denominator of reported voyages, likely pulling the aggregate score in different directions depending on which charterers and owners have more exposure in optional segments.
A standardized emission reporting schema, established in January 2026, aims to improve data exchange between vessel operators and charterers, reducing the friction that currently drives data gaps and estimate use.
See also
- Poseidon Principles – the parallel lender-side framework sharing the same four principles
- IMO GHG Strategy – the policy framework supplying the alignment trajectory
- IMO Net-Zero Framework – the global GHG levy mechanism taking effect from 2027
- What is CII – the operational carbon intensity indicator for vessels under MARPOL Annex VI
- What is AER – the Annual Efficiency Ratio metric used by CII and the Poseidon Principles
- EU ETS for shipping – the EU cap-and-trade scheme running in parallel
- RightShip GHG Rating – the vessel-screening tool widely used by signatories at fixture stage
- Voyage charter party – the commercial contract underlying C2 segment reporting
- Time charter party – the commercial contract underlying C1 segment reporting
- What is EEDI – design-phase energy efficiency index for new vessels
- What is EEXI – the existing ship energy efficiency index
- Biofuels in shipping – alternative fuel pathway relevant to EEOI emission factor treatment
- LNG as marine fuel – dual-fuel option with methane-slip implications for EEOI
- Bulk carrier – the primary vessel type chartered by framework signatories
- MARPOL Annex VI – the regulatory framework within which CII operates
- Sea Cargo Charter alignment calculator – EEOI and Climate Alignment Score against the current SCC trajectory
- AER calculator – AER calculation used in the Poseidon Principles
- CII attained calculator – vessel-level AER for CII compliance
- CII required calculator – regulatory Required CII
- GFI attained calculator – well-to-wake intensity from fuel mix
- Poseidon Principles alignment calculator – Poseidon Principles portfolio CAS
- IMO DCS annual fuel report calculator – the underlying IMO DCS data that feeds AER