论国际航运温室气体减排发展的新阶段:制度协调与中国因应OACHSSCD

International shipping GHG regulation is entering a new stage.This shift involves more than higher targets.Regulation now reaches beyond ship efficiency to fuel choice,life-cycle emissions and carbon costs.The proposed IMO Net-Zero Framework would combine a well-to-wake fuel-intensity standard,compliance pricing and a Net-Zero Fund,but it has not yet been adopted.The EU Emissions Trading System has covered maritime emissions since 2024,and the FuelEU Maritime Regulation has applied since 2025.The central issue is how this emerging global regime should coexist with regional rules in force. The three regimes support decarbonization but address different aspects of shipping.The EU ETS prices absolute emissions for covered voyages,while the FuelEU Maritime limits the annual average GHG intensity of onboard energy.The proposed IMO framework would apply a global fuel-intensity standard supported by remedial payments and redistribution through the Fund.Concurrent application does not automatically create a legal conflict,but it may lead to repeated reporting,inconsistent fuel certification and overlapping costs.It may also shift transition burdens to third countries and place legal responsibility on a company even when another actor controls the fuel,route or speed. Coordination should focus on regulatory function,not its legal form.The IMO regime should provide a global baseline,common accounting language and cross-border compliance platform.Regional measures may supplement it when they have a genuine port,voyage or market connection,avoid nationality-based discrimination,and deliver additional environmental benefits.Credits or adjustments should depend on whether the rules cover the same ship,fuel or emissions,overlap in time and place,perform the same function,and produce comparable effects.Carbon costs should be credited only where pricing functions overlap.Fuel-intensity standards should instead be linked through recognition of equivalent compliance or a global baseline plus regional differential. Procedural coordination can reduce burdens without merging the systems.Core data on fuel,voyages,life-cycle emissions and sustainability should be reported and verified once,while each regime retains its own calculation.Certificates should be recognized where standards are substantively equivalent,with additional checks limited to gaps.Contracts should assign costs and reporting duties to actors controlling fuel and operations.Fairness is better served by universal minimum ship duties,combined with financial support,technology transfer and capacity building,than by flag-based exemptions.China should support these interfaces and develop one reliable data chain for multiple compliance outputs.This approach can make maritime decarbonization more coherent,fair and workable without weakening emission-reduction goals.