Ghana faces lose-lose situation as IMO, EU rules take centre stage

By Maria OGBUGO

With the International Maritime Organization (IMO) on course, after a 12-month setback, to take a major decision this year on rules to decarbonise global shipping, the future of the European Union’s Emissions Trading Scheme (ETS) for maritime has come into sharp focus.

Many have called for the withdrawal of the ETS from international shipping to avoid duplication of regulation and the attendant costs and reporting burdens.

However, recent communication by the European Commission suggests that the ETS could overlap with forthcoming IMO regulations, deepening cost pressures on developing regions and jeopardising a just and equitable transition.

Given the calls by the EU for Africa to support the IMO’s Net Zero Framework (NZF), I argue that Africa’s support should be conditioned on agreement that the NZF will serve as the only global regulation for reducing emissions from international shipping.

The ETS was extended to the maritime sector in 2024 under the EU’s Fit for 55 package. Shipping lines have since introduced emissions surcharges to pass these costs to consumers. Shippers in Ghana are paying an average of USD280 per twenty-foot container in emissions surcharges, contributing to roughly a 10% increase in maritime freight costs since 2024.

Ahead of the October 2025 Marine Environment Protection Committee meeting, the EU pledged to “review the relevant regulation” once the NZF came into effect.

Subsequently, in March 2026, at a recently concluded EU–Sub-Saharan Africa dialogue on the NZF, Director Jan Dusik, Head of the EU Commission’s climate action department (DG CLIMA) stated that the EU would not compromise on its climate ambitions.

Dusik added that if the NZF is implemented, the EU ETS would be calibrated to price the emissions not covered by the NZF.

Efforts would be made to avoid duplication and harmonise reporting. The precise mechanism, he indicated, would become clearer in July 2026.

In effect, the EU, often a strong advocate of multilateralism, is signalling that even after the IMO’s multilateral process produces an outcome, it may still determine the appropriate level of ambition unilaterally.

The ETS could, therefore, remain an additional layer on top of the NZF, applied to shipping beyond EU territorial waters.

For Ghanaian consumers, this means continued exposure to the emission surcharges currently being paid to shipping lines, funds that ultimately flow into the EU’s Innovation Fund, alongside higher maritime costs associated with the NZF.

The NZF itself is already expected to have a disproportionate impact on Africa. African countries could experience maritime cost shocks of between 0.1% and 0.15% of GDP, compared with around 0.04% for developed countries.

It is thus difficult to reconcile the EU’s stance on the ETS with its call for Africa to support the NZF “as-is” as the pathway to a just transition. This is particularly concerning given that the EU remains one of Africa’s largest trading partners.

We are doomed if we do, doomed if we don’t

Supporters of the NZF, including the EU, warn that failure to adopt the framework could lead to a patchwork of regional regulations, and yet the EU itself cannot assure the global community that its unilateral measures, namely the EU ETS and FuelEU Maritime, would be withdrawn if the NZF is adopted.

In essence, Ghana, like many other African nations faces a lose-lose scenario: regardless of its position on the NZF, a fragmented regulatory landscape and its associated costs may persist.

Unilateral climate measures applied extraterritorially raise broader legal and equity concerns. Applying emissions pricing to voyages outside EU jurisdiction risks overlapping with the IMO’s mandate and raises questions about fairness and sovereignty.

Moreover, global climate agreements, which include the Paris Agreement, are grounded in the principle of common but differentiated responsibilities. Given Africa’s limited contribution to historical emissions and existing freight imbalances, applying the ETS to Africa-EU routes risks shifting disproportionate costs onto African economies.

Recent submissions by African countries, including Ghana, Kenya, the Democratic Republic of Congo and Togo, indicate growing support for elements of the NZF. But embracing the framework already exposes Ghana to higher maritime costs, declining competitiveness for low-value exports and potential food security risks.

It is therefore difficult to justify additional regional measures alongside the NZF.

The author urges the Ghanaian delegation that will be attending the upcoming meetings of the IMO in London to insist that their support for the NZF should go hand-in-hand with their European counterparts committing to withdrawing the ETS from shipping outside EU territorial waters, and to working collaboratively within the framework of the IMO towards a fair, inclusive and effective transition for global shipping.

Maria is a maritime consultant with Ahorlu Marine Limited. She can be reached at [email protected].

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