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IWG Decarbonisation – Workstream New Non-Fossil Fuels

About this workstream

This workstream examines the private law and contractual consequences of the maritime industry’s transition to new, non-fossil marine fuels, including ammonia, hydrogen, methanol, biofuels and biofuel blends. As new fuels enter the bunker market, existing liability and compensation regimes must be reassessed to determine whether they remain fit for purpose. The workstream analyses gaps in the current international liability and compensation framework, develops proposals for its adaptation, and engages directly with the IMO Legal Committee to ensure that private law considerations are reflected in the regulatory response to decarbonisation.

Workstream members

  • Jaime Albors, Spain
  • Mark Broekhuisen, The Netherlands
  • Nick Gaskell, Australia
  • Neil Henderson, UK (England)
  • Frederick Kenney, USA
  • Jolien Kruit (chair), The Netherlands
  • Hannah Mosmans, The Netherlands
  • Jan-Erik Pötschke, Germany
  • Henrik Ringbom, Finland
  • Manami Sasoaka, Japan
  • Ante Vojkovic, Croatia

Our work

  • 2024 The IWG published the Decarbonisation Discussion Papers at the annual CMI meeting in Sweden in May 2024, covering areas such as a liability regime for new fuels, contractual guidelines on the description of new-fuel readiness, and issues relating to the contractual architecture of maritime trade in a decarbonisation context.
  • Gothenburg Discussion Paper (2024)
  • Spring 2025 The workstream’s paper fed into the submission by Antigua and Barbuda (LEG 112/13/2) proposing that the Legal Committee consider the suitability of existing liability and compensation regimes for alternative fuels, supported by a CMI submission (LEG 112/13/5). Following these submissions, the Legal Committee agreed to include “suitability of IMO liability and compensation regimes with respect to alternative fuels” in the IMO work programme (LEG 112/16). During the Colloquium in Tokyo an updated version of the Gothenburg Discussion Papers was presented.
  • IMO submission – CMI
  • IMO submission – Antigua and Barbuda
  • Tokyo Discussion Paper (2025)
  • Autumn 2025 The IWG published a Discussion Paper on the 2007 Nairobi International Convention on the Removal of Wrecks, examining its application to incidents involving new fuels.
  • Nairobi Wreck Removal Convention Discussion Paper (2025)
  • 2026 The workstream’s submission to the IMO Legal Committee on biofuel blends and the international liability and compensation regime (LEG 113/14/3) was received with considerable interest. The workstream also provided input and advice to the IMO Legal Committee’s informal correspondence group, which culminated in a comparative analysis submission (LEG 113/14) by Antigua and Barbuda and others.
  • Biofuel/Blends Paper (2026)
  • IMO submission – CMI

IMO submission – Antigua and Barbuda

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