Comments by International Chamber of Shipping (ICS) Our full comments can be found here: https://www.ics-shipping.org/wp-content/uploads/2020/11/Inception-Impact-Assessment-for-the-proposed-Amendment-of-the-EU-Emissions-Trading-System-Directive-2003-87-EC-1.pdf The International Chamber of Shipping (ICS) appreciates this opportunity to comment on the Inception Impact Assessment for the proposed Amendment of the EU…
ICS
International Chamber of Shipping
Industry association · United Kingdom · EU Transparency Register 90104608462-14not in register snapshot
This register number is the organization’s own declaration on its submission. It is not in the 15 Oct 2026 snapshot of the EU Transparency Register, so we neither link to it nor use it to identify this organization.
4
positions filed
in the 665 files tracked
3
legislative files
of 665 tracked
1
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,800 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
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Their record over time
International Chamber of Shipping filed 4 positions between 18 Jul 2017 and 10 Sept 2025, across 3 of the 665 legislative files tracked here, attaching a full position paper 1 time.
2017 · 1 filed2020 · 1 filed2025 · 2 filed
What they argued
Unfortunately, the punctuation on our previous submission was lost when pasting into the online form,. Therefore, please also find attached a copy of the original file. It is the same text as previously submitted, but hopefully is easier to read, with all the punctuation and formatting in place.
The International Chamber of Shipping welcomes the European Commissions consultation on this matter. We offer the following comments: This initiative is focused on CO2 capture and geological sequestration. Indeed , this is currently the most mature technological pathway for shipping and is well suited to the liner trade where ships regularly operate on one or more set routes.
ICS welcomes revising the EU Shipping MRV Regulation in order align the EU MRV with the global IMO Data Collection System (DCS). The shipping industry is encouraged by the positive statements from the European Commission acknowledging the significant progress made by IMO Member States towards addressing GHG emissions from international shipping.
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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