The Paris and Tokyo MoUs open a joint Concentrated Inspection Campaign on cargo securing on 1 September, running to 30 November 2026 and exposing every operator carrying cargo units to inspections that can end in detention. The campaign lands in a regulatory season in which the industry's problem is no longer a shortage of rules, but the widening gap between what regulators agree in London and Brussels and what crews can actually prove on deck, in the engine room and in emissions data.

What does the CIC actually test?

Inspectors work through a standard questionnaire. Does the ship carry an approved Cargo Securing Manual? Is the crew complying with it? Are there sufficient approved portable securing devices aboard, and are fixed and portable devices in good condition?

Each ship faces one CIC inspection per MoU during the campaign. Outcomes range from a recorded deficiency to detention. Both MoUs will analyse the results and present them to their governing bodies, with a view to later submission to the IMO — so the data gathered this autumn may shape future rules.

The test is revealing precisely because a manual is easy to produce and file. Proving that the lashing gear on deck matches the manual, has been maintained under its inspection scheme and is understood by the crew is a different matter. A valid certificate confirms a survey took place; it does not confirm the condition of the ship on the day it matters.

What is happening at the IMO?

The organisation has completed the first cycle of its mandatory Member State Audit Scheme, covering 168 Member States since 2016 — 94% of the membership, one of the broadest assessments of maritime governance ever attempted. The findings, corrective action plans and consolidated reports have exposed recurrent problem areas and their root causes. No league table will be published. The second cycle begins in July 2027 under a more risk-based, data-driven continuous monitoring mechanism.

That diplomatic restraint is understandable. It is less helpful to owners, managers and charterers judging the real quality of oversight behind a flag and the recognised organisations acting on its behalf.

The Net-Zero Framework remains unsettled. Approved in principle at MEPC 83 in April 2025, it failed to win adoption at the extraordinary session in October 2025; MEPC 84 kept it alive without settling it. The 22nd intersessional working group met in London from 1 to 4 September with nearly 1,200 registered participants, and its chair reported a genuine willingness to put text before MEPC 85, while guideline and lifecycle assessment work slipped to the next session for lack of time.

The timetable is now tight:

• ISWG-GHG 23: 23–27 November
• MEPC 85: 30 November – 3 December
• Adjourned extraordinary session: 4 December, subject to confirmation by MEPC 85

Until then, there is no adopted global carbon price for shipping. Any broker note or charter clause treating IMO levies as settled is running ahead of the facts.

How hard does the EU squeeze?

On 30 September, shipping companies met their second EU ETS surrender deadline, covering 70% of verified 2025 emissions. For 2026 emissions the share rises to 100%, and methane and nitrous oxide now sit alongside CO2 in the calculation.

The methane inclusion bites hardest on LNG-fuelled tonnage. Unburned methane slipping through a dual-fuel engine now carries a carbon cost, making engine design, load profile and verified slip performance commercial variables, not just technical ones. FuelEU Maritime has applied in full since 1 January 2025, limiting well-to-wake greenhouse gas intensity — one regime prices emissions, the other sets an intensity limit, and both reward and penalise fuel choices differently using the same voyage data.

Brussels proposes to change the machinery again. On 17 July the Commission published COM(2026) 616, revising the ETS Directive, and COM(2026) 620, amending the MRV and FuelEU regulations. The Council and Parliament are working through them this autumn. The maritime elements are substantial:

• Certain ship types as small as 400 GT would come into scope, with offshore vessels of 400–5,000 GT following from 2031
• Up to 110 million allowances, valued at roughly €15 billion, reserved for sustainable fuels, electrification and wind propulsion
• Tightened rules on nearby non-EU transhipment ports; offshore worksites in EU waters treated as ports of call
• ETS, MRV and FuelEU reporting consolidated into a single submission, cutting annual MRV compliance costs by an estimated 10–20%

The proposal provides for ETS review if the IMO adopts a global carbon pricing measure, so owners do not pay twice. Agreement is expected in 2027, with entry into force in 2028 or 2029.

Closer to home, the UK ETS has applied to domestic shipping since 1 July, covering cargo and passenger ships of 5,000 GT and above on voyages between UK ports and in port. Offshore vessels join on 1 January 2027; the first surrender, covering 2026 and 2027 together, falls on 30 April 2028, and the tonnage threshold faces review in 2028.

What changes in the engine room?

Amendments to the NOx Technical Code 2008 entered into force on 1 September, setting out a certification procedure — never previously specified — for marine diesel engines that undergo substantial modification or are certified to a NOx Tier they did not meet when installed. Parent engine testing may now be carried out on an installed engine where no comparable test-bed engine exists. The practical consequence: fuel conversions, injection changes and Tier III upgrades need NOx certification on the critical path from feasibility, not as an afterthought at commissioning. A second set of amendments, on multiple engine operational profiles, follows on 1 March 2027.

New fuels are also exposing the limits of emergency planning. The IMO's R&D Forum in Singapore on 21–22 September, hosted by the Maritime and Port Authority of Singapore with support from China, examined pollution preparedness for LNG, LPG, methanol, ammonia, hydrogen, biofuels and e-fuels. Participants stressed that response procedures should be in place for each fuel before a major incident, not after one. A port that can supply ammonia is not, by that fact alone, a port that can respond to an ammonia release.

Security and autonomy complete the picture. The ISPS Code has been under review since MSC 111 in May, following a US submission on illicit trade and organised crime, and the EU is preparing MSC 112 submissions for December, including amendments to the ILO/IMO port security code of practice. The non-mandatory MASS Code has applied since 1 July, with the IMO roadmap pointing to a mandatory code from 2028, adoption by July 2030 and entry into force on 1 January 2032.

What should technical managers take from this?

Regulatory volume is not falling. What is changing is the burden of proof. Carbon regimes demand verified fuel and voyage data; port state control is testing whether manuals reflect practice; engine certification now has a defined route for modification; the audit scheme is moving to continuous, risk-based monitoring. For owners weighing LNG, methanol, ammonia or biofuel capability, investment decisions are being taken against two moving targets at once — a European regime under active revision and a global framework that may or may not be adopted in December.

The ships that will fare best are those whose documentation, equipment and data all tell the same story, and December's MEPC 85 will go a long way to deciding whether one of those moving targets finally stands still.