2.1 Scope and Country Coverage
The analysis covers the period 2028–2050, corresponding to the NZF’s
implementation trajectory. Results are presented at three time points —
2030, 2040, and 2050 — consistent with the CIA Task 3 snapshot years.
Analytical confidence is highest at 2030, where NZF design parameters
are most constrained by the adopted regulatory text, and decreases at
2040 and 2050, where all policy scenarios converge as the fleet
transitions to lower-emission fuels.
The primary economic indicators are GDP, consumer prices (CPI), and
trade flows (imports and exports), consistent with the CIA. Food price
exposure is assessed as a component of CPI impact, given the
significance of food imports in several African economies and the
explicit reference to food security in the draft revised MARPOL Annex VI
(regulation 41).
The model supports analysis of all economies and economy groupings
with individual breakouts in the CIA Task 3 results — over 100
individual GTAP economies plus composite groupings that together provide
global coverage. The framework can be applied to any country or grouping
for which the CIA provides baseline results, without structural
modification.
The initial analysis focuses on five African economies selected for
their diversity of economic structure, trade exposure, and vulnerability
profile: Ghana, Kenya, South Africa, Egypt, and Ethiopia (the “five
African reference economies,” AF5). Ghana and Kenya represent mid-sized,
trade-exposed economies with significant maritime import dependence and
high food-import shares. South Africa provides a comparator as the
continent’s most industrialised economy. Egypt combines high import
dependence with a unique position as a maritime transit economy.
Ethiopia is represented through the “Rest of landlocked economies in
Africa” GTAP aggregate, which includes thirteen countries with Ethiopia
as the dominant component (~46% of GDP). The aggregate’s trade structure
reflects blended East African, Southern African, and West African
shipping corridor exposure. Results labelled “Ethiopia” should be
interpreted as representative of landlocked African economies
generally.
The analysis additionally reports results for fourteen African
economies (the “fourteen African reference economies,” AF14), adding
Algeria, Cameroon, Côte d’Ivoire, Gabon, Madagascar, Mauritius, Morocco,
Nigeria, and the United Republic of Tanzania. Both AF5 and AF14 are
reported as GDP-weighted averages of independently computed country
results. For comparative purposes, results are also presented for
Brazil, China, India, Viet Nam, Bangladesh, Trinidad and Tobago, and the
SIDS aggregate, as well as the CIA’s standard economy groupings (World,
Developed economies, Developing economies, SIDS + LDCs).
2.2 Methodological Framing and Complementarity
The CIA was designed to evaluate pre-defined policy packages, not to
decompose the contribution of individual design choices within those
packages. Each scenario represents a fixed combination of GFI
stringency, levy level, and compliance mechanism. The results cannot
directly answer questions such as: “If the reward setting mechanism
produces outcome X rather than outcome Y, how does this change the GDP
impact on Kenya?” These are the questions that African delegations face
in the current negotiation phase, where the broad policy architecture
has been agreed but detailed design parameters remain open.
The present analysis addresses this gap with a reduced-form,
design-focused approach. Rather than re-running a global CGE model, it
takes the CIA’s Scenario 24 results as a structured reference point and
decomposes the underlying economic shocks into components corresponding
to identifiable NZF design choices. Scenario 24 models a WtW GFI with
flexibility mechanism and represents the closest analogue to the NZF’s
regulatory architecture. It serves as the anchor from which
design-driven variations are measured.
Each design choice is translated into a standardised economic
parameter that can be varied independently. The effects are expressed as
a sensitivity ratio (SR) scaling the CIA S24 reference: SR below 1.0
indicates lower costs than S24; above 1.0 indicates higher costs. This
preserves the country-specific impact structure embedded in the CIA’s
general equilibrium results while allowing transparent decomposition of
design-driven variation.
The approach offers three advantages for the negotiation context:
transparency (every result traces to a specific design assumption);
real-time comparison (alternative configurations can be assessed without
CGE simulation); and internal consistency (all calculations are anchored
to the CIA reference case).
The reduced-form approach does not capture general equilibrium
feedback effects, exchange rate adjustment, terms-of-trade effects on
export competitiveness, labour market concentration effects, or long-run
structural adjustment. It treats cost pass-through as embedded in the
CIA baseline rather than independently estimated. These omissions, their
direction of likely bias, and several interpretive considerations are
documented in Annex B. The results are best interpreted as first-order
impact estimates that capture the direct economic effects of NZF design
choices but not the full dynamic response.
2.3 Design-Cluster-Based Assessment Framework
The NZF encompasses design topics spanning incentive calibration,
lifecycle accounting, fuel certification, registry architecture, fund
governance, compliance mechanics, and revenue allocation. Not all
materially influence near-term macroeconomic outcomes in African
economies. A structured approach is required to identify the subset
warranting quantitative treatment, organise those topics to prevent
double-counting, and maintain a transparent audit trail from the full
design space to the reduced analytical scope.
2.3.1 Identification and Classification of Economically Material
Design Topics
Drawing on the draft revised MARPOL Annex VI, the report of ISWG-GHG
20, and pre-session submissions to MEPC 84, 48 design topics were
identified across six groupings: the IMO Net-Zero Fund (1.1–1.8), ZNZ
definition and reward (2.1–2.9), fuel certification (3.1–3.8), GFI and
compliance approaches (4.1–4.8), the IMO GFI Registry (5.1–5.11), and
the LCA framework (6.1–6.9).
Each topic was evaluated against two criteria:
Criterion A: Macroeconomic Materiality. Does the
topic plausibly affect, within 2028–2050, the magnitude of global
compliance costs, the timing of cost realisation, the incidence of costs
between carriers, exporters, consumers, and governments, or the
magnitude or usability of fiscal transfers to States?
Criterion B: Reduced-Form Parameterisability. Can
the topic’s effect be represented as a standardised economic shock
parameter — a cost level, cost timing adjustment, or transfer magnitude
— without requiring a change in model class?
The intersection generates three buckets:
- Bucket X — Material and Reducible. Topics
satisfying both criteria. These form the quantitative core: 8
topics.
- Bucket Y — Material but Not Reducible. Topics
satisfying Criterion A but not B. Incorporated through a structured
overlay framework: 18 topics.
- Bucket Z — Not Material to Macroeconomic Outcomes.
Excluded from economic modelling: 22 topics.
2.3.2 Clustering of Design Topics by Economic Transmission
Mechanism
Among the eight X-topics, several act on the same underlying economic
variable. Topics are grouped if they (a) affect the same standardised
economic shock parameter, (b) cannot be varied independently without
implicit assumptions about each other, and (c) correspond to a coherent
negotiation-relevant lever.
Design Cluster 1: Effective Compliance Cost Path.
This cluster determines the magnitude and trajectory of the freight cost
shock transmitted to the global trading system. It is the primary driver
of CPI and trade impacts, and the single most consequential set of
design choices for African states. Included topics: reward basis and
reference line (2.3), reward setting mechanism (2.4), reward
responsiveness (2.5), RU/SU interaction (2.7), SU supply constraints
(4.7), and SU multipliers for ZNZ fuels (5.10). The cluster is
represented through parameters that jointly determine the sensitivity
ratio \(\text{SR}(t)\).
Design Cluster 2: Net Fiscal Offset to African
States. This cluster determines the extent to which NZF revenue
is returned to African economies in forms that mitigate the domestic
cost burden. Cluster 1 determines the shock magnitude; Cluster 2
determines the offset magnitude. Included topics: disbursement
categories, eligibility, and allocation logic under regulation 41 (1.7);
financing instruments and access modalities (1.8).
Treatment of Bucket Y Topics. Eighteen topics are
classified as material but not reducible. Analysis reveals heavy
clustering around two vulnerability points:
- Fund delivery risk (topics 1.1–1.4). Implemented as
a scenario toggle setting the effective usability factor to zero (\(\omega_{\text{effective}} = 0\)) at
2030.
- Certification and LCA bottleneck risk (topics 3.5, 3.7, 3.8,
6.3, 6.4). Captured through the effective Tier 2 compliance
price parameter (\(T_2\)), which
determines the two-tier adjustment factor \(\alpha\).
2.4 Quantification: The 7-Step Reduced-Form Model
The quantification proceeds in six analytical steps, implemented as a
7-step computation chain. The NZF Design calculator implements the
identical computation chain described here.
2.4.1 Baseline and Impact Envelope
CIA Scenario 24 (WtW GFI with flexibility mechanism, no levy, no
feebate) is adopted as the reference point. S24 is a policy scenario,
not a no-policy baseline — all outputs are relative to the CIA’s BAULG
scenario. S24 does not model the NZF’s two-tier RU structure, reward
mechanism, or revenue recycling; these NZF-specific features are what
the reduced-form decomposition adds.
The reference MLC values (CIA Task 3, Table 8) are:
| Year |
MLC Increase (\(\Phi_{\text{S24}}\)) |
Interpretation |
| 2030 |
+5.78% |
Near-term; dominated by RU payments; highest confidence |
| 2040 |
+26.06% |
Mid-transition; fleet shifting to low-carbon fuels; moderate
confidence |
| 2050 |
+35.52% |
Long-term; near-complete decarbonisation; lowest confidence |
2.4.2 The Compliance Cost Channel
The MLC increase under the NZF decomposes into two additive
components: a base compliance cost and a reward
distortion.
Base compliance cost. The NZF’s two-tier RU
structure creates a fundamentally different cost profile from S24’s
single-tier flexibility mechanism. The two-tier adjustment factor \(\alpha\) captures the ratio of
fleet-weighted NZF compliance cost to S24 compliance cost:
\[\alpha(T_2) = \frac{1210 + 4.65 \times
T_2}{2301}\]
where 1210 is the fleet-weighted Tier 1 compliance cost (\(/tCO_2e\)), 4.65 is the fleet-weighted Tier
2 cost coefficient, and 2301 is the S24 fleet-weighted compliance cost
(\(/tCO_2e\)). The full derivation is
in Annex C. Key values:
| Effective Tier 2 price |
\(\alpha\) |
Interpretation |
| $380/tCO₂e |
1.29 |
SU market at RU2 ceiling; NZF ~29% above S24 |
| $300/tCO₂e |
1.13 |
Some SU supply pressure; NZF ~13% above S24 |
| $235/tCO₂e |
1.00 |
NZF cost equals S24 |
| $150/tCO₂e |
0.83 |
SU at S24 clearing price; NZF ~17% below S24 |
Base compliance cost is:
\[\text{base\_MLC}(t) =
\Phi_{\text{S24}}(t) \times \alpha(T_2) \times \pi\]
where \(\pi\) is a fuel price factor
(0.85–1.15) reflecting exogenous uncertainty identified in DNV’s
sensitivity analysis.
Reward distortion. Rewards are internal transfers
from the Net-Zero Fund to ship operators using ZNZ fuels. Under
efficient price discovery, each reward dollar approximately covers the
cost gap between the ZNZ fuel and the ship’s next-best alternative,
inducing a switch that would not otherwise occur.
\[\text{reward\_distortion} = \frac{R}{M}
\times \sigma \times \eta \times \varphi \times \mu\]
where \(R\) is total NZF revenue
(~$10 billion/year at 2030); \(M\) is
total global maritime logistics cost (~$800 billion); \(\sigma\) is the reward budget share
(0.20–0.80); \(\eta\) is reward
calibration efficiency (0.55–0.88); \(\varphi\) is a fuel scope factor
(1.00–1.05); and \(\mu\) is an SU
market factor (1.00–1.06).
\(R/M \approx 1.25\%\) establishes
the scale: the maximum possible reward distortion (all revenue to
rewards) would be ~1.3% of MLC.
The parameters \(\eta\), \(\varphi\), and \(\mu\) capture design choices within the
reward and compliance mechanism. Their ranges are narrow because the
underlying analysis demonstrates small effects on near-term compliance
cost:
- Fuel scope (\(\varphi =
1.00\text{–}1.05\)). Under a fixed reward budget, restricting
eligibility increases the per-unit cost gap but decreases ZNZ volume
purchased per reward dollar — effects that largely offset.
- Reward calibration (\(\eta = 0.55\text{–}0.88\)). \(\eta\) captures the fraction of reward
budget that bridges actual cost gaps vs. the fraction flowing as
windfall to inframarginal producers. The lower bound reflects a
flat-rate mechanism; the upper bound reflects a competitive pay-as-bid
auction.
- SU market design (\(\mu =
1.00\text{–}1.06\)). The 2030 SU market is supply-constrained, so
SU prices converge toward the $380 ceiling regardless of design.
Sensitivity ratio. The total MLC increase and
sensitivity ratio are:
\[\text{total\_MLC}(t) =
\text{base\_MLC}(t) + \text{reward\_distortion}\]
\[\text{SR}(t) =
\frac{\text{total\_MLC}(t)}{\Phi_{\text{S24}}(t)}\]
At default values (\(\sigma =
0.50\), \(\eta = 0.88\)) for
2030: \(\text{total\_MLC} = 7.48\% + 0.55\% =
8.03\%\); \(\text{SR} = 8.03\% / 5.78\%
= 1.39\).
2.4.3 Complete Parameter Summary
| Parameter |
Symbol |
Value/Range |
Source |
| S24 MLC anchor |
\(\Phi_{\text{S24}}(t)\) |
5.78% / 26.06% / 35.52% |
CIA Task 3 |
| Effective Tier 2 price |
\(T_2\) |
$380 (default); $100–$380 |
UCL/UMAS (2025) |
| Two-tier adjustment |
\(\alpha(T_2)\) |
1.29 (default); 0.73–1.29 |
Derived from SU price |
| Fuel price factor |
\(\pi\) |
1.00 [0.85–1.15] |
DNV sensitivity |
| Base revenue |
\(R\) |
~$10B/year |
Fleet-wide RU payments; UCL/UMAS (2025) |
| Total MLC |
\(M\) |
~$800B |
CIA Table 13 + logistics/transport ratio |
| Reward budget share |
\(\sigma\) |
0.20–0.80 |
Negotiation space |
| Allocation scheme |
— |
Categorical (5 options) |
CIA Table 23 |
| Usability factor |
\(\omega = \delta \times
\lambda\) |
0.10–0.63 |
GCF/UNEP data; Batini et al. (2014) |
| Fuel scope factor |
\(\varphi\) |
1.00–1.05 |
Analytical derivation (Annex D) |
| Reward calibration |
\(\eta\) |
0.55–0.88 |
UCL/UMAS; IRENA (Annex D) |
| SU market factor |
\(\mu\) |
1.00–1.06 |
Analytical derivation (Annex D) |
| Investment multiplier |
\(\mu_{\text{invest}}\) |
0.8 |
Literature estimate |
2.4.4 The Fiscal Transfer Channel
The NZF generates approximately $10–12 billion per year in revenue
during 2028–2030, from fleet-wide Tier 1 and Tier 2 RU payments. A
portion is allocated to ZNZ rewards; the remainder is available for
disbursement to States. The fiscal transfer to a given country is:
\[\theta_{\text{country}} =
\frac{r_{\text{country}}}{\text{GDP}_{\text{country}}} \times
\omega\]
where \(r_{\text{country}}\) is the
country’s share of the disbursement pool (\(R
\times (1 - \sigma)\)), determined by the CIA Table 23 allocation
formula: per-capita disbursements proportional to GDP impact magnitude,
with the eligible set varying by scheme (SIDS and LDCs only, all
developing, or all countries).
The usability factor \(\omega\)
ranges across five modalities:
| Modality |
\(\delta\) |
\(\lambda\) |
\(\omega\) |
| Technical assistance |
0.35 |
0.3 |
0.10 |
| Earmarked loans |
0.55 |
0.4 |
0.22 |
| Mixed instruments |
0.65 |
0.5 |
0.33 |
| Flexible in-sector grants |
0.80 |
0.6 |
0.48 |
| Unrestricted budget support |
0.90 |
0.7 |
0.63 |
The \(\delta\) values are calibrated
from GCF disbursement-to-approval ratios, bilateral climate finance data
(UNEP, 2023), and instrument-specific evidence. The \(\lambda\) values draw on IMF fiscal
multiplier estimates for EMEs and LICs (Batini et al., 2014; Ilzetzki et
al., 2013), with SSA-specific evidence from Kimaro et al. (2017).
2.4.5 Country-Specific Outcomes
The two transmission channels combine to estimate GDP impact,
consumer price impact, and trade cost impact for each country and time
period.
GDP impact:
\[\text{net\_GDP}_i(t) =
\text{GDP\_cost}_i(t) + \theta_i\]
\[\text{GDP\_cost}_i(t) =
\Phi^{\text{GDP}}_{\text{S24},i}(t) \times \text{SR}(t)\]
This leverages the CIA’s GTAP model, which captures country-specific
trade structure, import dependence, commodity composition, and bilateral
route exposure. Country-specific pass-through rates are implicitly
embedded in the CIA results.
Cross-scenario validation. Within the model’s
operating range of \(\text{SR} \in [0.85,
1.45]\), the mean prediction error is approximately \(-5\%\) (conservative: the model slightly
overstates impact magnitude). The default operating point (\(\text{SR} = 1.39\)) falls above the highest
directly validated CIA scenario (\(\text{SR} =
1.29\)) and is interpolated from adjacent scenarios. An affine
robustness specification (Annex F) produces 6–10% less-negative GDP
estimates at the default operating point, confirming that the
proportional model’s overstatement provides a safety margin. Beyond
\(\text{SR} = 1.45\), prediction error
exceeds 10% and results should be treated with caution.
Consumer price impact:
\[\text{CPI}_i(t) =
\Phi^{\text{CPI}}_{\text{S24},i}(t) \times \text{SR}(t)\]
For countries with structural data, CPI is decomposed into food and
non-food components using import composition weights and
commodity-specific maritime margins.
Trade cost impact:
\[\text{import\_cost}_i(t) =
\Phi^{\text{IMP}}_{\text{S24},g}(t) \times \text{SR}(t) \times
\rho_i\]
where \(\rho_i\) is a
country-specific import composition adjustment derived from UN Comtrade
data and CIA Table 12 commodity-specific CIF-FOB margins. Values range
from 1.01 (India) to 1.43 (Côte d’Ivoire).
2.4.6 Sensitivity, Interaction, and Uncertainty
Sensitivity hierarchy. The Fund revenue split (\(\sigma\)) is the most consequential policy
lever: for Kenya, this single parameter shifts net GDP impact by ~0.04
percentage points — larger than the combined effect of all other design
parameters. Disbursement design is second-order. Reward and compliance
mechanism design (\(\varphi\), \(\eta\), \(\mu\)) collectively contributes ~0.02
percentage points of GDP variation — an order of magnitude below the
Fund revenue split.
Exogenous uncertainty. Fuel price uncertainty (\(\pi \in [0.85, 1.15]\)) generates
approximately \(\pm 1.1\) percentage
points of MLC variation around the central estimate for 2030 — roughly
comparable to the entire range of policy-variable effects.
Temporal confidence gradient. The 2030 results carry
the highest confidence. At 2040, the two-tier adjustment converges to
\(\alpha = 1.0\). At 2050, all
scenarios converge to 34.7–36.8% MLC; design choices are largely
irrelevant. Fund revenue collapses to ~$1–3 billion at 2050 as fleet
decarbonisation eliminates the RU payment base; the 2050 fiscal offset
displayed in the calculator is therefore overstated by approximately
3–10×.
Correlated negotiation outcome scenarios. Three
scenarios capture the covariance of negotiation outcomes:
| Scenario |
\(\sigma\) |
Allocation |
\(\omega\) |
\(\eta\) |
\(\varphi\) |
\(\mu\) |
| Africa-Favourable |
0.35 |
All developing |
0.48 |
0.80 |
1.00 |
1.00 |
| Compromise |
0.50 |
All developing |
0.33 |
0.70 |
1.00 |
1.00 |
| Africa-Unfavourable |
0.65 |
SIDS/LDC only |
0.22 |
0.60 |
1.05 |
1.04 |
Implementation risk. Fund delivery delay sets \(\omega_{\text{effective}} = 0\) at 2030,
eliminating the fiscal offset for the near term. The toggle has its
largest effect precisely when policy design is most favourable to
developing countries.
2.4.7 Correspondence to the NZF Design Calculator
| Calculator Control |
Paper Reference |
Parameter |
Range |
| Fund Revenue Split (Slider 0) |
§2.4.2, reward distortion |
\(\sigma\) |
0.20–0.80 |
| Disbursement Allocation (Slider 1) |
§2.4.4, fiscal transfer |
allocation_scheme |
5 options |
| Disbursement Modality (Slider 2) |
§2.4.4, fiscal transfer |
\(\omega = \delta \times
\lambda\) |
0.10–0.63 |
| Fuel Eligibility (Slider 3) |
§2.4.2, fuel scope |
\(\varphi\) |
1.00–1.05 |
| Reward Calibration (Slider 4) |
§2.4.2, reward calibration |
\(\eta\) |
0.55–0.88 |
| SU Market Design (Slider 5) |
§2.4.2, SU market |
\(\mu\) |
1.00–1.06 |
| Fuel price whiskers |
§2.4.6, uncertainty |
\(\pi\) |
0.85–1.15 |
| CIA S24 Reference overlay |
§2.4.1 |
\(\text{SR} = 1.0\) |
Toggle |
| Fund delivery delay |
§2.4.6, implementation risk |
\(\omega_{\text{eff}} = 0\) at
2030 |
On/Off |
| SU / Tier 2 price |
§2.4.2, two-tier adjustment |
\(T_2 \to \alpha\) |
$100–$380 |