According to the work plan, the draft 2020 EGCS guidelines should have been approved at MEPC 75. Since the meeting was conducted remotely and lasted only four hours a day, however, the IMO secretariate had to prioritize within the agenda. To make a long story short, the result was that anything related to EGCS was postponed.

It’s now expected that the draft 2020 EGCS guidelines will be handled at the next meeting, MEPC 76. This meeting will also be held remotely, taking place in the 2nd week of June 2021.

At MEPC 76, there will be other EGCS topics on the agenda besides the update of the 2020 EGCS guidelines. Those include consequential amendments to the circular regarding EGCS breakdown, MEPC.1/Circ.883 and the draft terms of reference on the agenda item nicknamed “Harmonisation of discharge water regulations”.

Here’s a bit of guessing from my side as well. At MEPC 75, some issues were handled through correspondence a few weeks prior to the meeting. I think it’s likely that we’ll see this same model used for the EGCS-related issues prior to MEPC 76. Realizing that it desperately needs to finalize work in relation to the IMO GHG strategy, the MEPC is down-prioritizing the work PPR needs to be doing in relation to “harmonization”. (All the MEPC needs to do is to endorse the draft terms of reference.) So, if an agreement can be reached through correspondence prior to the MEPC 76 meeting, this would keep progress aligned with the work plan. Let me emphasize again that this is guesswork on my part.

If my guesswork is correct, then with a bit of luck we will have the draft 2020 EGCS guidelines and MEPC.1/Circ.883 approved in conjunction with MEPC 76, plus approval of the draft terms of reference for the work on “harmonization” to be carried out at PPR 9 (early 2022).

An alternative outcome might be that stakeholders don’t want to close the EGCS guidelines before the agenda item concerning “harmonization” has been handled. In this event, an application to reopen the EGCS guidelines for amendments would not be needed. (An application to reopen takes an additional 1–2 years.) However, this could be mitigated by issuing an MEPC circular, as in the case of MEPC.1/Circ. 883. This outcome would entail the terms of reference for “harmonization” being approved in conjunction with MEPC 76 and deferred to PPR 9. However, the draft EGCS guidelines and MEPC.1/Circ.883 would then be “sleeping documents” until the work on “harmonization” has been concluded.

So, in short, we might have the 2020 EGCS guidelines and MEPC.1/Circ.883 approved by the upcoming summer MEPC meeting (after those having been delayed by one meeting). Most probably, we will also be able to provide PPR 9 with terms of reference to continue the work on “harmonization” – albeit delaying the outcome of this work by at least two years in the process. Remember, though, these are only speculations!