Lloyd's anticipates regional regulatory fragmentation, in part through the European Commission/European Parliament efforts to include shipping in the European Union’s carbon market, forcing emissions cuts on ships calling at European ports, as the IMO MEPC 75 failed to codify measures to put shipping in line with the Paris Agreement targets.

MEPC has previously seen national positions divided down geopolitical lines over market-based measures that pitched developed and developing world nations into a fundamental debate regarding who foots the bill for climate change, and the IMO remains stuck on this issue, despite leaving the needs of SIDS and LDCs unaddressed.