Evaluation Cost and Environmental Impact of Compliance Measures

for IMO Sulfur Cap

Jiaqi Hu

University of Glasgow, Glasgow, U.K.

Keywords: Sulphur, Effect, Shipping.

Abstract: This research examines Maersk's crisis management in response to the NotPetya cyber attack, which severely

disrupted its global IT systems. It analyses the company's actions be-fore, during and after the at-tack,

highlighting Maersk's resilience, cross-functional coordination and transparent communication strategies. The

study examines how Maersk quickly mobilized global resources, made quick decisions under uncertainty and

restored operations with minimal long-term damage. Key success factors include proactive leadership,

effective stakeholder engagement and the ability to learn and adapt in real time. The case provides valuable

insights into how large multinational companies can manage cybersecurity crises, highlighting the importance

of preparedness, organizational agility and crisis communication. The analysis contributes to our

understanding of organizational resilience in the face of complex digital threats and has practical implications

for risk management and business continuity planning in an increasingly inter-connected world. In addition,

the study also revealed how Maersk can maintain business stability under chain reactions such as supply chain

interruption and damage to customer trust, and to rebuild the digital infrastructure through systematic recovery

measures.

1 INTRODUCTION

The "sulphur cap" refers to an environmental

regulation introduced by the International Maritime

Organization (IMO) that came into force on 1 January

2020. It requires a reduction in the sulphur content of

marine fuels from 3.5% to 0.5% (Seas, 2020). The

short-term goal of this policy is to reduce air pollution

and improve public health in coastal regions and

heavily trafficked maritime areas. The long-term

objective is to reduce sulphur dioxide emissions from

shipping by at least 50% by 2050. The

implementation of the IMO 2020 regulation has had

a profound impact on both the shipping industry and

the environment. On the one hand, the reduction in

sulphur emissions contributes to improved air quality,

reduced respiratory health risks and a reduction in

acid rain, which damages marine ecosystems (Wu &

Lin, 2021). On the other hand, compliance requires

significant financial investment. Switching to low-

sulphur fuels or installing scrubbers has significantly

increased operating costs (Bach & Hansen, 2023),

raising concerns about industrial competitiveness and

profitability. These challenges also raise questions

about the economic sustainability of such measures

and their compatibility with long-term

decarbonization goals. This paper aims to assess the

effectiveness of IMO measures in reducing sulphur

emissions, examine the associated compliance

burdens and contribute to future policy development

for sustainable shipping.

2 LITERATURE REVIEW

2.1 Blue Shipping: Assessing the

Environmental Impact of the 2020

Sulphur Cap

Numerous studies have examined the impact of the

IMO 2020 sulphur cap on maritime emissions. A

global study by Lindstad et al. (2017) showed a

significant reduction in sulphur emissions from ships,

with reductions ranging from 39% in Europe to as

high as 90% in East Asia. Similarly, the International

Council on Clean Transportation reported a reduction

in global sulphur emissions from shipping of 6.3

144

Hu, J.

Evaluation Cost and Environmental Impact of Compliance Measures for IMO Sulfur Cap.

DOI: 10.5220/0014298500004859

Paper published under CC license (CC BY-NC-ND 4.0)

In Proceedings of the 1st International Conference on Politics, Law, and Social Science (ICPLSS 2025), pages 144-151

ISBN: 978-989-758-785-6

million tons in the first half of 2020. These results

suggest that the regulation has made significant

progress towards the IMO's environmental goals,

particularly in terms of reducing sulphur emissions

and improving air quality. Wu and Lin (2021) also

found that container ships on the European trades

have often adopted scrubber systems, allowing the

continued use of high-sulphur fuel. This suggests that

while overall emissions have decreased, regional

differences in compliance methods - particularly the

reliance on scrubbers - may have undermined the

overall effectiveness of the policy in certain areas.

However, a common limitation of existing studies is

their focus on direct emissions outcomes, often

overlooking secondary impacts such as changes in

operational strategies or market dynamics. There

remains a gap in the literature on how different

compliance mechanisms affect emissions across

regions, particularly when taking into account

fluctuating fuel prices and the varying availability of

cleaner alternatives. Furthermore, a comprehensive

assessment of the economic and environmental trade-

offs associated with these compliance strategies is

lacking. My research aims to contribute to this field

by critically analyzing how the 2020 sulphur cap is

working in practice, highlighting regional

differences, fuel-related challenges and potential

unintended consequences. In doing so, it will provide

a deeper understanding of the implementation of the

policy, its practical constraints and its wider

implications for the environmental transition of the

shipping industry.

Although the 2020 sulphur cap has delivered

encouraging results in reducing sulphur emissions

from shipping, its economic impact also warrants

careful consideration. Singh and Shanthakumar

(2023) point out that the transition to low-sulphur

fuels has significantly increased fuel costs for

shipping companies. This cost increase contributes to

a cost-push effect, increasing overall operating costs

and potentially weakening the ability of companies to

maintain performance standards, thereby reducing the

global competitiveness of the industry. The

effectiveness of IMO environmental policy needs to

be examined in the broader context of

decarbonization efforts in the maritime sector. Wang

and Wright (2021) acknowledge that the sulphur cap

is an important first step in limiting air pollutants, but

argue that it is only a temporary solution. Achieving

the IMO's longer-term goal of reducing greenhouse

gas emissions by at least 50% by 2050 will require

continued innovation, particularly through the

introduction of alternative fuels and cleaner

technologies. Therefore, while the sulphur cap has

played a key role in reducing sulphur-related

pollution, it must be seen as one component of a

broader transition strategy. To address this gap in the

existing literature, my research seeks to explore how

the 2020 sulphur cap may influence the promotion

and adoption of cleaner alternative fuels in the

shipping industry. This perspective raises the critical

question of whether the current IMO regulations are

not only effective in limiting sulphur emissions, but

also capable of supporting the sector's longer-term

decarbonization trajectory. Understanding this

relationship is central to assessing the true

effectiveness of such international environmental

policies in promoting sustainable shipping.

2.2 Setting a Low-Sulphur Course:

Compliance Approaches in

Response to the 2020 Sulphur Cap

A growing body of literature has examined how

shipping companies have responded to the

requirements of the 2020 sulphur cap through

different compliance strategies. Cuong and Hung

(2020), in their survey of Vietnamese shipping

companies, found that the majority have chosen to

switch to low-sulphur fuel as their primary means of

compliance. Other approaches identified include the

installation of scrubbers and reliance on exemptions

or regulatory leniency in specific contexts. Similarly,

Lindstad et al. (2017) report that most ships are

largely compliant with emissions regulations,

although some continue to use scrubbers or even

resort to using non-compliant fuels. These studies

highlight the need for more in-depth research on the

economic impact of scrubber adoption and the

regulatory considerations surrounding its

implementation. Wu and Lin (2021) argue that

scrubber-equipped ships may adjust their routes to

pass through regions that still allow the use of high-

sulphur fuel, raising the question of how such

technologies affect compliance behaviour. This

research seeks to address this gap by assessing the

impact of scrubber use on both emissions control and

regulatory integrity, providing insight into the

broader challenges and potential benefits associated

with different compliance mechanisms.

Debate continues on the effectiveness of

enforcement of the sulphur cap in international

waters. Bach et al. (2023) argue that robust

enforcement is essential as shipowners may resort to

Evaluation Cost and Environmental Impact of Compliance Measures for IMO Sulfur Cap

145

illegal practices such as fuel blending to reduce

operating costs, leading to unreported or unjustified

emissions. There are also concerns that gaps in

enforcement, particularly in regions such as the

Arctic, could undermine environmental objectives.

Petrossian et al. (2020) also suggest that certain flag

states may offer incentives or regulatory leniency,

compromising the uniform application of the sulphur

cap and weakening its intended effects. These

findings highlight the urgent need for stronger

monitoring and enforcement mechanisms. Wang and

Wright (2021) also note that smaller shipping

companies may be disproportionately affected by the

regulation due to their limited financial capacity to

invest in compliance technologies. This study aims to

contribute to the debate by analyzing the economic

impact of the 2020 sulphur cap on different segments

of the industry, assessing how these regulations affect

competitiveness and long-term sustainability. It also

aims to provide policy-relevant recommendations to

support the future development of effective and

equitable environmental regulation in maritime

transport.

2.3 Low Sulphur Mandate, High

Economic Stakes: The 2020 Cap

and Its Impact on Shipping

The enforcement of the 2020 sulphur cap has created

significant economic challenges for the shipping

industry. Singh and Shanthakumar (2023) highlight

that the mandatory switch to low-sulphur fuels has

significantly increased operating costs, which was

particularly difficult during the COVID-19 pandemic

when freight demand and rates were already

depressed. In addition, Bach et al. (2023) argue that

varying levels of enforcement and leniency -

particularly through incentives offered by certain flag

states - can create an uneven regulatory landscape.

Such disparities risk undermining the principle of fair

competition, disadvantaging compliant companies

and potentially encouraging a shift in trade routes and

shipping operations to jurisdictions with more lenient

compliance requirements. These issues suggest that

the economic sustainability of the regime may be

compromised if consistent global enforcement is not

achieved. The theoretical underpinnings of this

research draw on the literature examining emissions

leakage, competitive distortions and shifts in

maritime activity. It examines how compliance

strategies and technological adjustments affect not

only cost structures but also broader trade dynamics.

Ultimately, this study aims to provide practical

insights for both industry practitioners and policy

makers on how to implement sulphur regulations in a

more equitable and sustainable manner.

Another important economic concern highlighted

in the literature relates to the influence of the 2020

sulphur cap on strategic flag state selection.

Petrossian et al. (2020) found that ships may

increasingly reflag to countries offering more

affordable or lenient compliance routes. While this

trend may reduce costs for operators, it threatens the

competitiveness and regulatory standards of

traditional flag states and raises questions about

safety and oversight. Furthermore, while the sulphur

cap has delivered measurable emissions reductions, it

has not yet catalyzed a meaningful shift towards long-

term decarbonization. The industry has largely

avoided addressing the wider need to adopt

alternative, low-emission fuel technologies. This

disconnect suggests that while short-term

environmental targets are being met, the

transformational changes required for deep carbon

reduction remain elusive. This research project seeks

to bridge this gap by analyzing how economic factors

shape compliance decisions and identifying the

systemic barriers that prevent the wider uptake of

sustainable fuel options. In doing so, it will provide

valuable insights into how international regulations

can be designed to encourage not only emissions

reductions, but also sustainable shifts towards

environmental innovation in shipping.

2.4 Impacts and Implications of

Sulphur Emission Regulations

In summary, the literature reviewed shows that the

International Maritime Organization’s sulphur

emissions policy has had a significant impact on the

maritime sector. The introduction of the 2020 sulphur

cap has led to measurable reductions in sulphur

emissions globally, but the extent of the impact varies

by region, particularly where alternative compliance

measures - such as the installation of scrubbers - are

widely used. Economically, the regulation has posed

notable challenges, in particular the increase in

operating costs due to the introduction of low-sulphur

fuel and the disproportionate burden placed on

smaller and less financially resilient shipping

companies. Despite these findings, there remains a

need for more comprehensive research into the wider

impacts of the policy - in particular its role in

facilitating long-term decarbonization and its impact

ICPLSS 2025 - International Conference on Politics, Law, and Social Science

146

on the global competitiveness of the shipping

industry. This research gap provides an opportunity

to deepen understanding of how international

regulations shape industry practices and to evaluate

the effectiveness of different compliance strategies.

Ultimately, the successful implementation of IMO

regulations must be accompanied by a shift towards

cleaner fuels and innovative technologies. These

elements are essential not only to meet immediate

emissions targets, but also to support the long-term

sustainability and efficiency of maritime transport in

a rapidly evolving regulatory and environmental

landscape.

3 CASE

3.1 Case Study

Maersk's response to the IMO 2020 sulphur cap -

strategy, impact and lessons learned A.P. Moller-

Maersk, headquartered in Denmark, is the world's

largest container shipping company with an extensive

global fleet and logistics network. The

implementation of the IMO 2020 regulation, which

limits the sulphur content of marine fuels to 0.5%

(down from 3.5%), marked a major regulatory shift

for the shipping industry. The regulation aims to

reduce harmful sulphur oxide (SOx) emissions, which

have a significant impact on human health and the

environment, particularly in coastal regions. As a

global industry leader, Maersk's approach to

complying with the IMO 2020 regulation offers

valuable insights into how large companies can

balance environmental responsibility with economic

viability. This case study examines the company's

chosen compliance strategy, the resulting operational

and financial impact, and the wider implications for

sustainability and competitiveness in the maritime

sector.

3.2 Compliance Strategy: Opting for

Low-Sulphur Fuel

Shipping companies had several main compliance

options under the new sulphur cap: switching to very

low sulphur fuel oil (VLSFO), installing exhaust gas

cleaning systems (commonly known as scrubbers) or

switching to alternative fuels such as LNG or

methanol. Maersk has primarily chosen to switch to

low-sulphur fuels across its fleet rather than install

scrubbers. Between 2018 and 2020, the company

invested significantly reportedly more than $150

million - to prepare for this transition. This included

upgrading fuel handling systems, retraining crew and

securing reliable supplies of compliant fuel at key

global ports.

Unlike some of its peers, Maersk deliberately

limited its use of scrubbers, citing concerns about

environmental controversies in particular open-loop

scrubbers that discharge the contaminated washing

water into the possible regulatory ban in the future.

The company emphasized a long-term view, seeking

consistency with its broader environmental goals

rather than short-term economic gains.

3.3 Economic Impacts: Managing

Rising Fuel Costs

Maersk's switch to low sulphur fuel, while

environmentally progressive, had significant

financial implications. Initially, very low sulphur fuel

oil (VLSFO) was 30-50% more expensive than

traditional high sulphur fuel oil (HSFO), leading to a

significant increase in operating costs. According to

Maersk 2020's financial reports, fuel-related costs

increased by approximately $200 million in the first

half of the year alone, largely as a result of the new

regulation.

To mitigate these costs, Maersk has implemented

several strategic responses. First, the company

introduced an "IMO 2020 Environmental Fuel Fee"

to pass on part of the additional fuel costs to

customers. Second, it implemented operational

measures such as route optimization and slow

steaming to reduce overall fuel consumption. Third,

Maersk entered into strategic sourcing partnerships

with refiners to secure a stable and cost-effective

supply of VLSFO.

Despite the initial challenges, Maersk has

successfully maintained operational efficiency and

market competitiveness. By the end of 2020, the price

gap between VLSFO and HSFO had narrowed,

alleviating some of the financial pressure. In addition,

the company's proactive approach and transparent

communication with stakeholders helped to maintain

customer confidence and strengthen brand credibility.

3.4 Environmental Benefits and

Broader Decarbonization Strategy

The switch to low-sulphur fuel has had a significant

positive impact on the environment. Maersk reported

a reduction in sulphur oxide emissions of more than

Evaluation Cost and Environmental Impact of Compliance Measures for IMO Sulfur Cap

147

80% in 2020, contributing to improved air quality

along major shipping routes and in port cities. These

achievements were in line with IMO targets and

reinforced Maersk's image as a sustainability leader

in the maritime sector. Crucially, Maersk saw IMO

2020 not as an isolated compliance challenge, but as

a steppingstone to full decarbonization. The company

has publicly committed to achieving net-zero carbon

emissions across its operations by 2040 and a 50%

reduction in greenhouse gas emissions intensity by

2030 (compared to 2020 levels).

In pursuit of this goal, Maersk has invested heavily

in alternative marine fuels and clean technologies. In

2023, the company will launch the world's first

container ship powered by green methanol and has

ordered more than a dozen dual-fuel ships that can run

on methanol or conventional fuel. While IMO 2020

focused primarily on sulphur reduction, Maersk’s

investments in green methanol and dual-fuel ships

indicate a broader environmental strategy that may

contribute to a low-carbon future in maritime

transport.

3.5 Challenges and Risks

While Maersk's approach was largely successful, it

was not without its challenges. The company had to

deal with. Operational complexity: Different VLSFO

formulations at different suppliers and ports required

more stringent fuel quality control and compatibility

testing. As for crew training, handling new fuel types

required updated operating procedures and safety

protocols, increasing the need for training. Market

volatility: In the early months of implementation,

unpredictable VLSFO prices created budget risks and

affected route planning. In addition, Maersk's

decision to avoid widespread use of scrubbers

revealed a wider tension in the industry: while some

companies invested in scrubbers to benefit from

cheaper HSFO, others like Maersk prioritized long-

term environmental responsibility. This created an

uneven playing field in the short term, where

companies with different strategies faced different

cost structures and competitive advantages.

Meanwhile, Maersk recognized the regulatory

loopholes exploited by some smaller operators such

as flag state leniency and inconsistent enforcement in

some regions which could undermine the

effectiveness of global sulphur limits. This highlights

the importance of international regulatory alignment

and robust monitoring mechanisms.

3.6 Lessons Learned and Policy

Implications

Maersk's experience with the IMO 2020 regulation

illustrates how a proactive strategy and

environmental leadership can deliver both

compliance and competitive benefits. By preparing

early, formulating a clear transition plan and

maintaining transparent communication with its

customers, Maersk was able to manage the transition

to low-sulphur fuels more effectively than many of its

competitors. This approach not only reduced

operational risks, but also strengthened customer

confidence. The company's alignment of regulatory

compliance with its long-term sustainability goals

further strengthened its brand image. Rather than

viewing environmental regulations as a burden,

Maersk integrated them into its broader vision,

enhancing customer loyalty and distinguishing itself

as a responsible market leader. However, the variation

in compliance across the industry reveals a gap in

global enforcement, pointing to the need for greater

international coordination and harmonized

environmental standards. IMO 2020 has also acted as

a catalyst for innovation, encouraging investment in

alternative fuels and new technologies. This

momentum is essential as the shipping industry

moves towards the IMO's 2050 target of reducing

greenhouse gas emissions by at least 50%. Maersk's

early move into green fuels such as methanol shows

that companies that see regulation as a strategic

opportunity will be better placed to shape the future

of sustainable shipping.

3.7 Maersk’s Strategic Response to the

IMO 2020 Sulphur Cap

Maersk's response to the IMO 2020 sulphur cap

shows how a leading shipping company can combine

environmental responsibility with economic

resilience. By choosing to switch to low-sulphur fuels

and investing in future-proof technologies, Maersk

not only met the short-term regulatory requirements,

but also laid the foundations for long-term

decarbonization. While challenges remain -

particularly around fuel costs, enforcement and

industry-wide fairness - the case shows that

compliance can go hand in hand with innovation,

competitiveness and sustainability.

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4 FINDINGS AND DISCUSSION

4.1 Maersk’s Compliance Strategy:

Low-Sulphur Fuel as a Long-Term

Bet

Maersk's primary response to the IMO 2020 sulphur

cap has been to proactively adopt very low sulphur

fuel oil (VLSFO), rather than relying on scrubbers.

This strategy involved an upfront investment of more

than $150 million to upgrade fuel systems, retrain

personnel and establish stable supply chains for

compliant fuels. Compared to other carriers who

opted for scrubbers to continue burning cheaper high

sulphur fuel oil (HSFO), Maersk's decision reflects a

strategic preference for long-term environmental

responsibility over short-term cost savings. This

approach aligns with its broader decarbonization

goals and reduces its exposure to potential regulatory

backlash against scrubber discharge practices. The

findings suggest that corporate environmental

leadership can be motivated not only by regulatory

compliance, but also by reputational considerations

and anticipated policy trajectories.

This forward-looking strategy differentiated

Maersk in a fragmented industry landscape where

enforcement and compliance were uneven. Maersk's

limited use of scrubbers also addresses the concern

raised by Wu and Lin (2021), who found that

scrubbers - while compliant - may reduce the

environmental effectiveness of sulphur caps,

particularly in regions where enforcement is uneven

or water pollution is an issue.

4.2 Economic Impacts: Cost Burden

and Strategic Adaptation

Although environmentally sound, Maersk's decision

to switch to VLSFO came at a significant financial

cost. At the start of 2020, the price of VLSFO was 30-

50% higher than HSFO, contributing to an estimated

$200 million increase in Maersk's fuel-related costs

in the first half of the year alone. This placed an

additional burden on operations already affected by

the COVID-19 pandemic, as noted by Singh and

Shanthakumar (2023), who identified the IMO 2020

regulation as a driver of cost-push inflation in the

shipping sector.

To mitigate these economic impacts, Maersk has

implemented several strategies, including the

introduction of the IMO 2020 Environmental Fuel

Fee, route optimization and slow steaming to improve

fuel efficiency. Strategic sourcing agreements with

refiners have also been instrumental in managing fuel

price volatility. This adaptability illustrates how large

operators can absorb regulatory shocks through

diversified operational and commercial levers.

However, such strategic flexibility may not be

available to smaller or less capitalized operators,

exacerbating competitive inequalities in the industry,

as observed by Wang and Wright (2021).

4.3 Environmental Outcomes and

Decarbonization as a Strategic

Trajectory

Maersk's switch to low-sulphur fuel resulted in a

reported 80% reduction in SOx emissions in 2020,

directly contributing to improved air quality along

global trade routes. This is in line with Lindstad et al.

(2017), who documented dramatic reductions in

sulphur emissions in key regions following the

implementation of IMO 2020. More importantly,

Maersk has positioned this regulatory milestone as a

platform for broader decarbonization. The company

has committed to net-zero operations by 2040 and to

halving its greenhouse gas intensity by 2030.

The company's investments in green methanol and

dual-fuel vessels mark a deliberate shift beyond

compliance to innovation. In 2023, Maersk will

launch the world's first green methanol-powered

container ship and has ordered additional vessels that

can run on either methanol or conventional fuels.

These initiatives, while still in their infancy,

demonstrate a willingness to front-load R&D

investment in order to shape the future regulatory and

market landscape. While these steps suggest a 'post-

fossil fuel' ambition, a more critical view would

require closer tracking of fleet-wide emissions

trajectories and life cycle analysis of alternative fuels

to fully substantiate this claim.

4.4 Operational and Regulatory

Challenges

Despite its successes, Maersk faced significant

challenges in implementing its strategy. VLSFO

formulations varied between regions and suppliers,

making it difficult to ensure fuel quality and

compatibility. Crew retraining and safety adjustments

were also required. These findings echo earlier

concerns raised by Cuong and Hung (2020), who

highlighted the operational burden of low-sulphur

fuel compliance in Southeast Asia.

Evaluation Cost and Environmental Impact of Compliance Measures for IMO Sulfur Cap

149

Furthermore, Maersk's aversion to scrubbers

highlighted the disparity in compliance costs across

the industry. While motivated by environmental

concerns, this stance put Maersk at a temporary cost

disadvantage to operators using cheaper fuels with

scrubbers. In addition, inconsistencies in global

enforcement - such as flag state leniency or weak port

state control in some jurisdictions - allowed less

scrupulous operators to avoid the financial burden of

compliance, distorting competition and undermining

global emissions targets. This is consistent with

Petrossian et al. (2020), who highlighted the risks

posed by flags of convenience and uneven

enforcement.

4.5 Broader Policy Implications and

Industry Lessons

Maersk's experience with the IMO 2020 regulation

offers important lessons for both policymakers and

industry stakeholders. First, early preparation and

transparent communication can reduce transition

costs and increase customer confidence. Second,

environmental leadership if backed by credible action

can enhance brand value and competitiveness. Third,

the regulation catalyzed innovation in cleaner marine

fuels, suggesting that well-designed environmental

mandates can be constructive rather than punitive.

However, the case also highlights the limits of

voluntary action and the importance of strong

international governance. Without harmonized

enforcement, the full benefits of IMO regulations risk

being undermined by regulatory arbitrage and uneven

burdens on business. Future policy frameworks must

therefore combine ambitious targets with robust

monitoring mechanisms and financial support for

smaller operators to ensure a level playing field.

5 CONCLUSION

The implementation of the IMO 2020 sulphur cap has

brought significant changes to the global shipping

industry, particularly in balancing environmental

objectives with economic realities. This paper uses

the case study of Maersk to demonstrate how

proactive compliance strategies can deliver both

environmental and reputational benefits, despite

short-term financial burdens. Maersk's decision to use

low-sulphur fuel instead of relying on scrubbers

reflects a long-term vision in line with global

decarbonization targets. The company's experience

shows that compliance with international

environmental regulations, while costly, can drive

innovation and industry transformation.

At the same time, the uneven global enforcement

of sulphur regulations and the varying ability of

shipping companies to adapt highlight challenges in

terms of regulatory fairness and policy impact.

Smaller operators and developing flag states may

struggle to keep up, leading to competitive distortions

and reduced regulatory effectiveness. Future policy

must therefore address these inequalities through

harmonized enforcement and targeted support

mechanisms.

In conclusion, the IMO 2020 sulphur cap has

proven effective in reducing emissions, but its

success in promoting long-term sustainability

depends on broader structural reforms, investment in

alternative fuels and coordinated international

governance. The Maersk case suggests that

companies that see regulation as an opportunity rather

than a constraint are best placed to lead the shipping

industry towards a cleaner, more resilient future.

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