Thank you for reading IMO Net-Zero Framework vs. Liberia Proposal

Analyzing the IMO Net-Zero Framework and the Liberia-led alternative proposal, and the implications for LNG & global marine fuel marketsContents

2. Why the Liberia Proposal Has Become Part of the Debate

3. The Core Policy Debate: Ambition vs. Practicality

4. The Economic Mechanism Debate: Why Carbon Pricing Matters

5. What Could The Alternative Framework Mean For LNG?

6. Implications For Bio-LNG, RNG And Renewable Methane Pathways

7. 8. Outlook: The Most Likely Outcome Is Compromise

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1. Introduction:

IMO Net-Zero Framework vs. Liberia Proposal: Implications for LNG & Global Marine Fuel Markets

As the International Maritime Organization (IMO) continues negotiations over its future decarbonization framework, industry attention has increasingly focused on the differences between the IMO's draft Net-Zero Framework (NZF) and an alternative proposal put forward by Liberia, Panama and Argentina.

While these frameworks share the objective of reducing greenhouse-gas emissions from international shipping, they differ significantly in how quickly emissions reductions should occur, how compliance should be structured, and how the industry should balance environmental ambition with economic practicality.

For LNG stakeholders, these debates have implications extending far beyond regulation. The outcome could influence future fuel demand, infrastructure investment, compliance costs, bunkering strategies, renewable gas deployment and the overall competitiveness of LNG within the global marine fuel mix.

In this report, Ryan Harb shares his perspective on the policy debate, the likely direction of negotiations, and what the evolving regulatory landscape could mean for LNG, bio-LNG and renewable methane pathways.

As LNG continues to play a central role in discussions around maritime decarbonisation, many of these themes, including bunkering infrastructure, fuel availability, regulatory developments and renewable methane pathways, will be key areas of discussion at the LNG Bunkering North America Summit. Register here!

Featuring Expert

Insights From:

Ryan Harb, Board Member, American Biogas Council

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2. Why the Liberia Proposal has Become Part of the Debate

Understanding the Proposal's Influence:

The Liberia-Panama-Argentina proposal is often described as an alternative to the IMO's draft Net-Zero Framework. However, its significance may lie less in its prospects for adoption and more in the issues it has brought to the centre of negotiations.

Supporters of the proposal argue that any global fuel framework must account for real-world constraints, including the cost of compliance, the availability of alternative fuels and the pace at which supporting infrastructure can be developed. The proposal therefore places significant emphasis on affordability, availability and scalability as guiding principles for future regulation.

For LNG stakeholders, these themes are particularly relevant.

Those are the three things I think the Liberia proposal highlights particularly well: Affordability, Availability, and scalability "

Ryan Harb, Board Member,

American Biogas Council

A growing global bunkering network, an expanding LNG-fueled fleet, a well-developed international value chain and a growing supply chain for renewable methane-based fuels already support LNG. As a result, the proposal is often viewed as more accommodating of fuels that can be deployed immediately at commercial scale.

At the same time, many governments and industry groups remain concerned that the proposal, in its current form, may not provide a sufficiently clear pathway toward the IMO's long-term emissions-reduction objectives.

As negotiations continue, many observers increasingly view the debate not as a choice between two competing frameworks, but as a search for a compromise that can balance environmental ambition with practical implementation.

The IMO's Net-Zero Framework remains uncertain, while attention has increasingly focused on the alternative proposal put forward by Liberia, Panama and Argentina. For stakeholders across the LNG value chain, what are the key components of this proposal, and what challenges is it trying to address?

Ryan Harb: "I would not say support is growing for the Liberia proposal as-is. There is a group of countries that support it, but more countries currently do not support it unless changes are made. The proposal does not have enough votes to pass in its current form and will require several modifications.

That said, it introduces important ideas into the discussion. The most important is affordability. We are living in a period where inflation and rising costs are affecting consumers globally. Any framework that is too ambitious risks driving costs higher, which ultimately gets passed on to consumers and could create political backlash.

The proposal also emphasizes fuel availability and scalability. If a global fuel standard is adopted, there must be enough qualifying fuel available worldwide and sufficient infrastructure to support global shipping operations.

Those are the three things I think the Liberia proposal highlights particularly well:

Affordability
Availability
Scalability

For LNG specifically, the proposal highlights LNG as one of the few alternative fuels that is already available, affordable and scalable today. LNG is available at more than 200 ports worldwide and can immediately reduce emissions. Combined with bio-LNG and e-LNG, it creates a methane-based fuel pathway that could remain relevant for decades."

Affordability

Availability

Scalability

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3. The Core Policy Debate: Ambition vs. Practicality

Where the Frameworks Differ Most:

Although both proposals seek to reduce emissions from international shipping, they approach the challenge from different perspectives.

The IMO's Net-Zero Framework is fundamentally designed to align shipping with the organization's long-term decarbonization objectives. Its structure focuses on progressively reducing lifecycle greenhouse-gas intensity while creating economic incentives that encourage investment in lower-carbon fuels and technologies.

By contrast, the Liberia proposal places greater emphasis on ensuring that future targets remain achievable based on commercially available fuels, existing infrastructure and demonstrated market adoption. Rather than prioritizing long-term ambition as the primary driver, it seeks to align regulatory requirements more closely with industry readiness.

For LNG stakeholders, the distinction is important. Under a framework driven primarily by decarbonization targets, the long-term competitiveness of LNG may depend heavily on lifecycle emissions accounting, methane-emission treatment and the recognition of renewable methane pathways.

Under a framework that places greater weight on affordability and fuel availability, LNG's existing infrastructure base and global accessibility could offer a stronger competitive advantage.

Compared with the IMO's existing framework proposal, where do you see the biggest differences in approach?

Ryan Harb: One of the biggest differences is that the Liberia proposal is not ambitious enough to meet the IMO's long-term greenhouse-gas reduction strategy.

The proposal essentially sets fuel-intensity targets using existing fuel pathways and updates them over time, but it does not provide a clear route to achieving net-zero emissions by/around 2050. Because of that, many countries believe it falls short of the IMO's objectives.

At the same time, there are still major decisions that need to be made under the Net-Zero Framework. These include any adjustments to the GFI targets, lifecycle assessment methodologies, treatment of biomethane, avoided methane crediting, and which alternative maritime fuels will ultimately qualify.

Those decisions will have a major effect on how ambitious the framework really is and how compliance costs evolve.

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A Key Difference Often Overlooked

While discussions frequently focus on fuel-intensity targets, one of the most consequential differences between the competing approaches concerns compliance economics.

The draft IMO Net-Zero Framework combines fuel-intensity requirements with an economic mechanism intended to create financial incentives for lower-carbon fuels and technologies.

Supporters argue that these mechanisms are necessary to accelerate investment and provide a meaningful pathway toward long-term decarbonization.

Critics, however, have expressed concerns regarding compliance costs, inflationary pressures, market distortion and the broader economic impact of an increasingly stringent regulatory environment.

The Liberia proposal emerged, in part, from these concerns. Its emphasis on affordability reflects a belief among some stakeholders that the industry's transition must be paced according to fuel availability and commercial viability if it is to secure broad international support.

For LNG stakeholders, the outcome of this debate could prove as important as the fuel standards themselves.

Future compliance costs may significantly influence fuel-selection decisions, vessel economics and investment priorities across the maritime sector.

4. The Economic Mechanism Debate: Why Carbon Pricing Matters

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5. What Could the Alternative Framework Mean for LNG?

This is largely because the proposal places substantial weight on characteristics that LNG already possesses today:

Established infrastructure
Global availability
Proven operational experience
Comparatively competitive pricing relative to many emerging alternatives.

However, the longer-term outlook remains dependent on eventual regulatory design.

Even if a compromise framework emerges, important questions remain unresolved.

These include greenhouse-gas fuel-intensity calculations, lifecycle accounting methodologies, methane-emission treatment and the qualification of renewable methane pathways such as bio-LNG and e-LNG.

Consequently, LNG's long-term competitive position may ultimately depend less on which proposal prevails and more on how these technical details are resolved within the final framework.

LNG pricing is generally competitive with conventional marine fuels, it is already available globally and the infrastructure exists today.

Ryan Harb, Board Member, American Biogas Council

^{Assessing LNG's Relative Position}

From an LNG perspective, it could create a more favorable operating environment than the current draft Net-Zero Framework.

Looking specifically at LNG, would the alternative framework create a more favorable operating environment than the current IMO proposal?

Ryan Harb: "Probably.

The Liberia proposal is built around affordability, availability and scalability, and LNG performs strongly on all three measures. LNG pricing is generally competitive with conventional marine fuels, it is already available globally, and the infrastructure exists today.

As the proposal stands, LNG is probably the clearest winner.

However, I do not think the Liberia proposal will pass as written. The most likely outcome is a compromise that incorporates elements of both proposals.

We need practical solutions that can reduce emissions immediately, and LNG is one of those solutions. There are already more than 1,000 LNG-fueled vessels operating today. Finding a balanced framework that incorporates the best ideas from both approaches would be the most realistic outcome."

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6. Implications for Bio-LNG, RNG, & Renewable Methane Pathways

The Importance of Lifecycle Accounting

While much of the policy debate focuses on conventional LNG, the most significant long-term implications may involve renewable methane pathways.

Bio-LNG, renewable natural gas (RNG) and future e-methane solutions have the potential to utilize existing LNG infrastructure while delivering substantially lower lifecycle emissions.

What factor will have the greatest impact on the competitiveness of bio-LNG and renewable methane fuels over the next decade?

Carbon-intensity (CI) accounting methodology
Recognition of avoided methane emissions credits
Fuel production cost and availability
Regulatory approval and certification frameworks
Expansion of LNG infrastructure and vessel adoption

As a result, they are increasingly viewed as potential bridge fuels between today's LNG market and the shipping industry's longer-term decarbonization objectives.

Their future competitiveness, however, will depend heavily on regulatory treatment.

Issues such as carbon-intensity calculations, biomethane certification, methane accounting methodologies and avoided methane-credit recognition could significantly influence project economics and investment decisions.

Small changes in these rules may have outsized effects on the relative attractiveness of different fuel pathways.

For LNG suppliers, vessel operators and infrastructure developers, monitoring these technical discussions may prove just as important as following the broader political negotiations.

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Beyond conventional LNG, what implications could these competing frameworks have for bio-LNG, RNG and other lower-carbon gas pathways?

Ryan Harb:

"Ultimately, shippers will use whichever fuels provide the lowest cost of compliance.

Bio-LNG could be extremely competitive, particularly if lifecycle accounting recognizes avoided methane emissions and allows very low or negative carbon-intensity (CI) scores.

However, competitiveness depends on several factors: CI values, fuel availability, production costs, and which fuels are ultimately recognized under the framework.

If certain alternative fuels are excluded or given harsher treatment on their CI scores, demand for bio-LNG could increase significantly.

Those decisions will shape investment signals and influence which projects move forward.

The good news is that LNG infrastructure already exists, and LNG-fueled vessels are continuing to be ordered.

That gives LNG, bio-LNG, and renewable methane pathways a strong foundation."

Competitiveness depends on several factors:

- Carbon Intensity Values

- Fuel Availability

- Production Costs

- Fuels Recognized Under the Framework

Ryan Harb, Board Member,

American Biogas Council

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From Export Leader to Marine Fuel Hub?

The United States already occupies a central position within the global LNG market and is expected to remain one of the world's leading LNG suppliers for the foreseeable future.

For maritime stakeholders, however, the larger opportunity may extend beyond exports alone.

A regulatory framework that continues to recognize LNG and renewable methane pathways could support investment across the marine fuel value chain, including bunkering infrastructure, small-scale liquefaction facilities, vessel deployment and fuel-distribution networks.

At the same time, the scale of that opportunity remains uncertain. Market demand, fuel economics, infrastructure investment and final regulatory requirements will all influence whether the U.S. evolves from a major LNG exporter into a leading global LNG bunkering hub.

As the maritime fuel transition develops, policy certainty may become one of the most important factors shaping that outcome.

7. The U.S. LNG Opportunity:

If a compromise framework were ultimately adopted, what could that mean for the U.S. LNG market specifically?

Ryan Harb: "The U.S. currently supplies more than 35% of global LNG exports, which puts it in a strong position.

A potential future opportunity is for the United States to become a major maritime fueling hub. Achieving that would require investment in bunkering infrastructure, vessel capacity, liquefaction projects, and marine logistics.

Small-scale liquefaction projects could become part of that solution, and there may eventually be opportunities for larger export terminals to participate more directly in bunkering markets.

Whether that happens ultimately depends on economics, long-term fuel demand, national maritime policies, and the final structure of the regulatory framework."

8. Outlook: The Most Likely Outcome is Compromise

What Industry Leaders Should Watch Next…

Although significant differences remain between member-state positions, the direction of negotiations increasingly suggests that a compromise outcome remains the most realistic scenario.

Neither the draft IMO Net-Zero Framework nor the Liberia proposal currently appears likely to emerge unchanged. Instead, future negotiations may increasingly focus on combining the strengths of both approaches: preserving long-term decarbonization objectives while ensuring that implementation remains economically and operationally practical.

For LNG stakeholders, several developments warrant close attention:

Future GFI reduction trajectories.
Lifecycle assessment methodologies.
Methane-emission accounting rules.
Biomethane and renewable methane recognition.
Compliance-cost structures and economic mechanisms.
Investment signals for low-carbon marine fuels.

Ultimately, the future role of LNG will be shaped not only by emissions targets themselves, but by how governments decide to balance ambition, affordability and fuel availability.

That balance may determine both the pace of maritime decarbonization and the role LNG plays within it over the coming decades.

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Looking ahead, what outcome do you think is most likely and what should LNG stakeholders be watching most closely?

Ryan Harb:

"I am optimistic that a global fuel standard will emerge.

The worst outcome would be failure to agree on a global framework, resulting in a patchwork of regional/national systems with different rules across Europe, Asia, North America, etc.

That would increase complexity and costs for everyone involved.

The challenge is balancing ambition with practicality. A framework that is too strict could become inflationary and create political resistance.

A framework that is too loose may fail to achieve emissions goals and miss the opportunity for significant investment.

If governments and industry continue working together, I think there's a genuine opportunity to build something better than either proposal standing alone.

I expect countries will continue negotiating and eventually find a middle ground. Neither the current NZF nor the Liberia proposal is likely to emerge unchanged.

The most realistic outcome is a compromise that combines elements of both approaches while keeping in-mind long-term decarbonization goals."

Neither proposal is perfect on its own. The opportunity now is to take the best elements from both approaches and create a framework that is ambitious, practical, and affordable. If we can do that, we can significantly reduce emissions without creating unnecessary economic harm."

Ryan Harb

Board Member,

American Biogas Council

Securing LNG's Future in an Uncertain Shipping Market

As LNG demand grows and North America's role in global supply strengthens, the industry must address infrastructure, certification, and regulatory challenges to secure LNG's future. Join the LNG Bunkering Summit North America to help shape the conversation and ensure LNG remains a viable, scalable marine fuel pathway.

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Date: November 16-18, 2026
Location: Orlando, Florida