Does the new IMO carbon agreement incorporate crew change travel emissions?

In April 2025, the International Maritime Organization (IMO) reached a historic agreement to introduce the first-ever global carbon pricing mechanism for shipping emissions. Designed to curb the maritime industry’s greenhouse gas output, the agreement will implement charges on emissions that exceed set thresholds, with penalties reaching up to $380 per tonne of CO₂ emitted above those limits.

A secondary, stricter standard adds an additional $100 per tonne for higher-level emissions, creating a two-tiered structure that encourages decarbonisation. The initiative is projected to generate up to $40 billion annually to support the essential transition to cleaner fuels and technologies.

The charges are set to begin in 2028 and apply strictly to Scope 1 emissions, meaning only the direct emissions produced by ships themselves are regulated. Emissions from activities like the production of fuel or crew-related logistics, are not included in the current IMO framework.

So what about Scope 3 and crew change travel?

Crew change travel emissions, e.g. from air travel, are not yet regulated as they fall under Scope 3, the category for indirect emissions from a company’s wider value chain. Crew change travel is an essential and frequent operation for maritime companies and can contribute significantly to a vessel or company’s overall carbon footprint, so while it is not included in the latest agreement, shipping’s Scope 3 emissions are gaining attention.

In regulatory environments like the EU Emissions Trading System (EU ETS), maritime emissions are already included, and there’s growing awareness around full supply chain impact, even if Scope 3 is not yet legally required. Many industry leaders expect that Scope 3 reporting could become standard in future regulatory phases, especially in carbon-conscious markets.

Why forward-thinking companies are acting now

ATPI Marine Travel is already helping maritime clients measure, understand, and reduce the carbon impact of their crew change logistics. Through tailored travel planning, route optimisation, and emissions tracking tools, we offer practical ways to address Scope 3 emissions, ensuring that our clients are ready from an Environmental, Social, and Governance (ESG) perspective, and before regulation catches up.

Our CO₂ reporting tools are specifically designed to give shipping clients clear visibility of their Scope 3 crew travel emissions, enabling data-driven strategies to mitigate their environmental impact. By identifying high-emission routes and travel behaviours, we support clients in reducing their footprint through e.g., smarter itinerary design and sustainable travel alternatives.

So, while the new IMO carbon agreement does not currently include crew change travel emissions, the industry is moving in a direction where indirect emissions will matter more. Whether driven by future regulation or ESG expectations, being able to track and optimise Scope 3 emissions is fast becoming essential.

By partnering with ATPI Marine Travel, shipping companies can prepare for this next phase while aligning sustainability with operational excellence and crew care.