CII: Current Viewpoint

BIMCO’s new CII clause and some of the calculations behind CII ratings clearly don’t reflect or consider the industry’s operational realities. The industry desperately needs some parameters to help charterers and ship owners understand where responsibility lies to achieve favourable ratings, but this blanket, unbalanced approach that favours the few, isn’t the answer. It adds an extra layer of tension when we already know that CII will inevitably pit charterer against owner, testing the relationships that can often be fraught with conflicting priorities. As BIMCO even highlighted, how can it “produce a fair and balanced clause that works in practice for both shipowners and charterers when one has to comply and the other holds the key to compliance?”

From Norvic’s vantage point, we appreciate the diverse challenges that CII creates for cargo owners, operators and fleet owners. While cargo owners will have their specific requirements to ensure they are meeting their own compliance targets, we still need to be able to work effectively and profitably within the constraints of CII. For example, the regulations favour long voyages over the spot market which isn’t always practical. Also, how can it be viable to reward vessels that are operating below capacity or penalise those on particular routes? There will also be some tough conversations if certain trades are seen to be negatively impacting a vessel’s rating.?

To avoid a slew of potential disputes between charterers and owners that are counterproductive to achieving the overall goal of making shipping more sustainable, agreements will need to become increasingly personalised. The quality and depth of relationships will also be critical to re-writing agreements that are as mutually favourable as possible. This takes deep expertise and a selection of resources to tap into.??

CII has the potential to create an unintended rift at a time when the industry is already navigating a multitude of macro challenges. Without open, pragmatic communication it could have a toxic, damaging impact on the industry. We’re currently on our own until the IMO reviews the regulations again in 2026. As an industry collective, we need to accept that the regulation is here but this three-year vacuum is grossly misguided. We call on the IMO to review the modelling behind CII with urgency and for BIMCO to also review this related clause.??

While these regulatory waters are unchartered, the onus is on all parties to dig deep, collaborate and forge a flexible path that works in the best possible way for everyone within these new requirements.?