POLICY AND PRACTICE REVIEWS article

Front. Mar. Sci., 25 February 2026

Sec. Marine Affairs and Policy

Volume 13 - 2026 | https://doi.org/10.3389/fmars.2026.1786595

Seafarers in shipping’s decarbonization: role transformation, protection deficits, and just transition pathways

  • School of Law, Shanghai Maritime University, Shanghai, China

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Abstract

The shipping industry is undergoing a critical phase of green transition, in which seafarers constitute the core driving force of decarbonization. As this transition deepens, seafarers’ roles are undergoing a dual transformation: from reliance on traditional mechanical labor to functions empowered by digital and intelligent technologies, and from exclusively shipboard operations to integrated cooperation with shore-based control and support. However, seafarers are confronted with multiple protection deficits throughout the green transition, with issues of energy justice becoming increasingly prominent. Specifically, complex combinations of alternative fuels intensify seafarers’ operational burdens, safety risks associated with clean fuels threaten their physical and mental health, and the fragmented landscape of global emissions regulations significantly heightens their exposure to legal liability. In response, this paper advocates for the Just Transition principle as the guiding framework: adopting fixed-route operation models to alleviate seafarers’ fuel-handling pressures, implementing specialized training schemes to mitigate health risks, and promoting a cautious application of criminal liability and reasonable exemptions for seafarers within evolving decarbonization-related liability regimes. This paper provides a valuable contribution to advancing the global shipping decarbonization process while balancing environmental sustainability with the protection of seafarers’ rights and interests.

1 Introduction

Decarbonization refers to the reduction of greenhouse gas emissions from the energy system by transforming the modes of energy production, transmission, and consumption (Foundation, 2023). This concept is commonly used to describe the transition of the energy mix from dependence on conventional fossil fuels to cleaner energy sources, with the ultimate aim of achieving low-carbon or even zero-carbon emissions in response to the escalating challenges of climate change. In the maritime sector, one of the key pathways to decarbonization lies in the transition of marine fuels, namely the gradual replacement of conventional fossil fuels with low- or zero-carbon alternatives such as hydrogen, biofuels, ammonia, and methanol (International-Maritime-Organization, 2021), all of which hold significant potential for reducing greenhouse gas emissions from shipping.

Currently, the global shipping industry is undergoing a profound green transformation with decarbonization at its core. In this process, technological iterations, tightening regulations, and market restructuring form the main narrative. However, the fate and well-being of seafarers, who are the cornerstone of the shipping industry, are often marginalized. Existing research predominantly focuses on the feasibility of emission reduction technologies, the compliance frameworks of international and domestic policies, and the economic cost analysis for shipowner companies. For instance, some researchers have innovatively developed a meta−heuristic algorithm embedded with a linear programming model, offering practical managerial insights for the daily operations of liner companies as well as for the formulation of green and sustainable transportation policies by governments of countries along the Northern Sea Route (Xiang et al., 2025). Further research indicates that port integration in multi-port regions can be facilitated by adjusting capacity and conducting market share transactions, thereby addressing port overcapacity and guiding the development of sustainable policies (Chen et al., 2023). However, there is a lack of systematic integrated research on the seafarers, who are the most direct bearers of the pressures from the green transformation. Specifically, little attention has been given to the role transitions they undergo in this systemic change, the multidimensional risks they face, and the challenges related to the protection of their rights and interests. This article aims to address a long-neglected yet crucial core contradiction in the process of the global shipping industry’s green transformation. Specifically, it seeks to explore how to resolve the issue of escalating systemic occupational risks and the lack of protection for the rights and interests of seafarers, who are on the frontlines, amidst the acceleration of macro-level emission reduction targets and technological policies. Specifically, the questions addressed in this article are as follows: First, what specific and profound transformations are occurring in the professional roles and working patterns of seafarers? Second, what systemic protection deficits are they facing, resulting from a combination of technological, regulatory, and market structural factors? Third, how can an effective, multi-level regulatory approach be constructed, guided by the principle of just transition, to genuinely protect seafarers’ rights and ensure the fairness and sustainability of the shipping decarbonization process?

In order to address the gaps in existing academic discussions regarding social equity and humanistic concerns, thereby making research on shipping emissions reduction more comprehensive and multi-dimensional, this article primarily adopts a research approach that combines qualitative commentary on multiple sources of texts with policy comparative analysis. Through systematic review, comparison, and interpretation of international maritime conventions, regional and national regulations, industry reports, and academic literature, the article reveals the protection deficits faced by seafarers in the green transformation and proposes corresponding solutions. Specifically, this article focuses on the strategic evolution and rule construction in the field of shipping emission reduction by two key governance bodies: the International Maritime Organization (IMO) and the European Union (EU). It systematically collects and critically analyzes industry reports, annual assessments, and specialized studies published by authoritative organizations such as the International Chamber of Shipping (ICS), the International Seafarers’ Welfare and Assistance Network (ISWAN), Det Norske Veritas (DNV), and the United Nations Conference on Trade and Development (UNCTAD). This paper successfully introduces two normative theoretical frameworks: “energy justice” and “just transition.” It critically examines the current imbalance in the distribution of benefits, costs, opportunities, and risks among seafarers and other stakeholders during the green transition of shipping. Furthermore, it establishes the principle of “just transition” as the fundamental guideline for resolving this structural contradiction, advocating that while pursuing environmental goals, it is essential to ensure that seafarers receive fair opportunities for job transition, skill enhancement, and rights protection. Figure 1 is the logic flowchart of this paper, intended to illustrate the logical structure of the entire text.

Figure 1

This paper, in Section 2, reviews the implementation process of global shipping emission reduction strategies, with a focus on analyzing the roles and impacts of the IMO and the EU in driving the decarbonization of the shipping industry. Section 3 focuses on the transformation of seafarers’ roles, particularly the changes in seafarers’ work pressure and their adjustments in work patterns due to the green transition. In Section 4, we analyze the energy justice issues faced in seafarer rights protection in the context of the green transition, and emphasize that adhering to the Just Transition principle is key to addressing energy justice issues. Section 5 identifies the protection gaps faced by seafarers in this transition, focusing on issues such as the safety risks of alternative fuels, concerns about seafarers’ occupational health, and the compliance risks brought about by the fragmentation of global shipping emission regulations. Section 6 proposes regulatory measures based on the Just Transition principle, suggesting the adoption of fixed-route operation models to alleviate seafarers’ fuel management pressures, reducing seafarers’ health risks through professional training, and making cautious adjustments in the application of criminal liability to mitigate the various challenges seafarers face during the green transition. Finally, Section 7 summarizes the main conclusions of the paper.

2 The implementation process of global shipping emission reduction strategies: IMO mechanism and EU mechanism

Since the 1997 Kyoto Protocol explicitly called upon its Parties to pursue, through the IMO, the limitation or reduction of greenhouse gas emissions from marine bunker fuels not controlled by the Montreal Protocol (UNFCCC, 1997), the challenge of how to effectively regulate emissions from ships operating on the high seas beyond the jurisdiction of any single State has gradually emerged as an urgent global concern. This reality has further urged the international community to prioritize promoting the decarbonization of shipping as a key measure to ensure the sustainable development of the global shipping industry.

2.1 The implementation process of the IMO shipping emission reduction strategy

In order to mitigate the adverse impacts of shipping on climate change, the IMO began, in the early 21st century, to explore improving ship energy efficiency through technical and operational measures. In 2011, through amendments to Annex VI of the MARPOL Convention, the IMO formally incorporated the Energy Efficiency Design Index (EEDI) and the Ship Energy Efficiency Management Plan (SEEMP) into its regulatory framework for energy conservation and emission reduction. According to these amendments, the EEDI requirements are progressively tightened every five years to reflect advances in technology and emission-reduction measures, with the ultimate objective of mandating a 30% reduction for applicable ship types by 2025 and thereafter. It is noteworthy that the EEDI initially applied primarily to several categories of newly built ships with the highest energy consumption and largest tonnage in the global merchant fleet, including oil tankers, bulk carriers, liquefied natural gas (LNG) carriers, general cargo ships, container ships, refrigerated cargo ships, and combination carriers. By 2014, its scope had been further extended to LNG carriers, ro-ro cargo ships, ro-ro passenger ships with non-conventional propulsion, and cruise passenger ships. As a result, ships responsible for approximately 85% of global shipping-related carbon emissions were formally brought within the ambit of the international regulatory regime (IMO, 2023b).

In October 2016, at its 70th session, the IMO Marine Environment Protection Committee (MEPC) adopted Resolution MEPC.278(70), which provides that, from 1 January 2019, all ships of 5,000 gross tonnage and above are required to systematically collect data on fuel oil consumption and other relevant parameters, and to record and report such fuel consumption on a mandatory basis. This measure is intended to provide essential data support for the development of further measures to enhance ship energy efficiency. In 2018, the IMO MEPC further adopted the Initial IMO Strategy on Reduction of GHG Emissions from Ships, which clarified the instruments for implementation, the timeline for progress, and the guiding principles for emission reduction (IMO, 2023c), and established the first sector-wide reduction target, namely that by 2050 the total annual greenhouse gas emissions from international shipping should be reduced by 50% compared with 2008 levels. Subsequently, in June 2021, at its 76th session, the MEPC adopted amendments to Annex VI of the MARPOL Convention, which further required ships to implement technical measures as short-term mandatory carbon reduction measures, specifically including the calculation of the EEXI for existing ships, and the establishment of an annual operational CII and corresponding rating system (IMO, 2021). Building on the ongoing emission reduction policies, in 2023, the IMO officially adopted the 2023 IMO Strategy on Reduction of GHG Emissions from Ships at the 80th MEPC meeting (IMO, 2023a). This strategy is an update and upgrade of the 2018 initial strategy, adding objectives to address harmful emissions from shipping and providing a clear action framework for member states. The 2023 IMO Strategy on Reduction of GHG Emissions from Ships clearly states that the international shipping industry should strive to achieve net-zero greenhouse gas emissions around 2050, marking the entry of the global shipping decarbonization process into a more systematic and defined new phase. For the detailed development process of the 2023 IMO strategy on the reduction of GHG emissions from ships, please refer to the Supplementary Material.

In conclusion, although the shipping industry has not been directly included within the framework of the Paris Agreement due to its high degree of internationalization, a series of actions by the IMO have, in effect, aligned the global shipping industry’s emission reduction trajectory with the 1.5 °C temperature goal of the Paris Agreement. It is evident from the development trends that since 2011, the IMO has continuously advanced ship energy efficiency improvements and emission reduction regulatory frameworks, progressively raising decarbonization requirements for the global shipping industry by expanding the scope of regulation and accelerating the emission reduction process, and ultimately, in the 2023 IMO Strategy on Reduction of GHG Emissions from Ships, has explicitly set the ambitious goal of achieving net-zero emissions around 2050.

2.2 The implementation process of the EU shipping emission reduction strategy

To specifically implement the emission reduction targets of the Kyoto Protocol, the EU established the European Climate Change Programme (ECCP) in 2000 (European-Commission, 2000), marking the official establishment of the EU’s low-carbon policy. In 2005, the EU officially launched the world’s first international emissions trading system—the EU ETS (European-Commission, 2025b). In 2012, the EU included the aviation sector in the EU ETS, and discussions were initiated regarding the inclusion of the shipping industry in the carbon emissions trading system. In 2013, the European Commission released the official policy document Integrating Maritime Transport Emissions in the EU’s Greenhouse Gas Reduction Policies (European-Commission, 2013), which proposed the establishment of a monitoring, reporting, and verification (MRV) system for greenhouse gas emissions in the maritime sector. The EU Regulation (EU) 2015/757 was introduced, which was adopted in 2015 and established the MRV system for all ships with a gross tonnage of over 5,000. The regulation stipulates that, starting from January 1, 2018, ships calling at ports in the EU and the European Economic Area (EEA) are required to implement carbon emission monitoring and reporting systems (European-Parliament & Council-of-the-European-Union, 2015). In 2021, the European Commission introduced the Fit for 55 package—a series of proposals aimed at reforming the EU’s climate and energy policies, including the EU ETS, as part of the Green New Deal. A key reform within the EU ETS is the inclusion of the shipping industry in the EU carbon emissions trading system (European Commission, 2025a). In 2023, the EU Council and the European Parliament successively approved several key pieces of legislation in the Fit for 55–2030 emission reduction package, including the reform legislation to include the shipping industry in the EU ETS (European-Parliament & Council-of-the-European-Union, 2023). Table 1 shows the key EU ETS legislation.

Table 1

Main EU ETS legislation
TimeDocument
2023-06-05ETS Directive (consolidated text).
2023-05-10Directive 2023/959 amending Directive 2003/87/EC establishing a system for greenhouse gas emission allowance trading within the Union and Decision (EU) 2015/1814 concerning the establishment and operation of a market stability reserve for the Union greenhouse gas emission trading system.
2018-03-19Directive (EU) 2018/410 amending Directive 2003/87/EC to enhance cost-effective emission reductions and low-carbon investments, and Decision (EU) 2015/1814.
2009-04-23Directive 2009/29/EC amending Directive 2003/87/EC to improve and extend the greenhouse gas emission allowance trading scheme.
2008-11-19Directive 2008/101/EC amending Directive 2003/87/EC to include aviation activities in the scheme for greenhouse gas emission allowance trading.
2004-10-27Directive 2004/101/EC amending Directive 2003/87/EC establishing a scheme for greenhouse gas emission allowance trading.
2003-10-13Directive 2003/87/EC establishing a scheme for greenhouse gas emission allowance trading and amending Council Directive 96/61/EC.

Main EU ETS legislation.

Subsequently, the EU has advanced its emission reduction process through the phased implementation of the MRV system and the EU ETS. The details are shown in the table below. In 2024, the regulatory scope of the EU ETS will officially be extended to the shipping industry.

As time progresses, it is evident that the EU’s emission reduction strategy has gradually become more stringent and tightened. From the initial Kyoto Protocol to the recent Fit for 55 plan, the EU has consistently strengthened its efforts to address climate change, continually raising its emission reduction targets and policy measures. According to the EU’s emission reduction process, in 2018, the EU began implementing the MRV mechanism for cargo ships and passenger ships exceeding 5,000 GT, requiring these vessels to monitor and report greenhouse gas emissions. Over time, the EU has increased its regulatory efforts on ship emissions. By 2024, the EU will include certain ships in the EU ETS system, further enhancing carbon emission control and oversight. This move marks the tightening of the EU’s shipping emission reduction strategy, signaling that the EU, in the process of meeting the Paris Agreement’s emission reduction goals, is gradually holding the shipping industry accountable for greater responsibility.

3 The transformation of seafarers’ roles in the green transition of shipping

Seafarers are the cornerstone of the shipping industry. Since the establishment of the International Labor Organization, it has consistently committed to safeguarding the rights of seafarers, recognizing the uniqueness of their profession and the harsh working conditions they face (Khan et al., 2025). As the global shipping industry’s emission reduction process advances, the work pressure and work patterns of seafarers have quietly undergone changes.

3.1 Work pressure

Seafarers face unique psychological, social, and physiological pressures that are unmatched by land-based work (Carotenuto et al., 2012). Research indicates that the primary sources of stress faced by seafarers include prolonged separation from home, social isolation, high work intensity, and environmental stress related to life aboard the ship (Slišković and Penezić, 2015). As the global wave of emission reductions accelerates, the shipping industry is undergoing a profound and lasting green transformation. As mentioned earlier, organizations such as the IMO and the EU have successively introduced and tightened emission reduction policies. The global emission reduction targets are progressively cascaded down, ultimately falling on seafarers, translating into tangible operational burdens in their daily work.

Taking the EU carbon emissions mechanism as an example, for seafarers on the frontlines, this increasingly stringent regulatory framework means that their work pressure has shown a significant upward trend over time. According to Annex I of Regulation (EC) No 336/2006 of the European Parliament and of the Council, the responsibility for complying with EU ETS obligations lies with shipping companies (European-Parliament & Council-of-the-European-Union, 2023). However, these obligations are, in practice, passed on to the seafarers. Since 2015, ships with a gross tonnage of over 5,000 entering EU ports are required to comply with the EU’s MRV regulation. These ships must monitor their carbon dioxide emissions and report them to the European Maritime Safety Agency (EMSA) through the THETIS-MRV database. The information that seafarers need to report includes the ship’s identification and type, greenhouse gas emission sources on board the ship, emission factors for each fuel type used, the total consumption of each fuel type and its corresponding emission factor, the distance traveled, and the time spent at sea (European-Parliament & Council-of-the-European-Union, 2023). In 2024, with the tightening of policies, such ships will be included in the EU ETS, and carbon dioxide emissions will be officially linked to quota costs. At the same time, methane and nitrous oxide will be incorporated into the monitoring scope. This means that seafarers will not only need to accurately measure multiple greenhouse gases but also integrate cost control awareness into their navigation decisions. Their job responsibilities will shift from purely operational tasks to comprehensive emissions management. By 2025, the scope of emission reductions will expand further, with large offshore vessels joining the MRV system, bringing more groups of seafarers into the regulatory network. By this point, the emission reduction pressure faced by seafarers has evolved from initial adaptation and learning to mid-term technical challenges of monitoring multiple gases and ship types, and will ultimately evolve into the management burden of controlling emission costs and ensuring compliance. The gradual advancement of the EU’s emission reduction strategy over time has, in effect, been internalized into seafarers’ daily work, becoming a concrete, ongoing, and increasingly heavy occupational burden. Table 2 shows the development process of the EU carbon emissions mechanism.

Table 2

The development process of the EU carbon emissions mechanism
Stage202320242025202620272028+
Ships
Cargo & Passenger Ships (5000+ GT)MRVMRV+ EU ETSMRV+EU ETSMRV+EU ETSMRV+EU ETSMRV+EU ETS
Offshore Ship(5000+ GT)NoNoMRVMRVMRV+EU ETSMRV+EU ETS
General Cargo Ship and Offshore Ship(400–5000 GT)NoNoMRVMRVMRVMRV
Greenhouse gases
Carbon Dioxide (CO2)MRVMRV+ EU ETSMRV+EU ETSMRV+EU ETSMRV+EU ETSMRV+EU ETS
Methane (CH4) and Nitrous Oxide (N2O)NoMRVMRVMRV+EU ETSMRV+EU ETSMRV+EU ETS
EU ETS Reporting Requirement0%40%70%100%100%100%

The development process of the EU carbon emissions mechanism.

3.2 Work patterns

3.2.1 From manual labor to digital and intelligent empowerment

Digitalization and automation technologies are widely regarded as key drivers in propelling the shipping industry toward a cleaner, greener, and more efficient future. Although in the short term, there may be practical trade-offs in capital allocation, such as during the COVID-19 pandemic, when the sharp decline in fuel prices temporarily weakened industry investment in energy efficiency projects, it unexpectedly accelerated the digital transformation of shipping (Ölçer et al., 2023). However, from a long-term perspective, the digital and green development of shipping is not separate, but a dual transformation that evolves in tandem. The fundamental reason for this is that smart and automated ships are, in themselves, energy optimization platforms. The deep digitalization of ships provides the technological foundation for the flexible application of various clean energy sources, enabling ships to dynamically adjust their energy usage strategies based on navigation status and environmental conditions. At the same time, the introduction of big data analytics allows for the real-time and precise monitoring and assessment of the ship’s overall energy consumption and emissions, continuously identifying efficiency bottlenecks and optimizing operational processes. This data-driven, refined management not only enhances the overall energy efficiency of ship operations but also provides a clear path for continuously reducing carbon emissions and achieving the green shipping goals. Therefore, digital and intelligent empowerment is a crucial support for the green transition in shipping, while the green goals also guide the digitalization process. The synergistic development of both will jointly build a sustainable future for the shipping industry.

It is important to note that this synergistic transformation is not only reflected at the technological level but also fundamentally reshapes the labor structure and professional significance of seafarers. Traditionally, seafarers’ labor has emphasized physical effort, mechanical operations, and experience-driven emergency response capabilities, such as ship maneuvering, cargo stowage, and equipment inspection. With the gradual adoption of intelligent management systems, remote monitoring platforms, and automated energy efficiency scheduling algorithms in the shipping industry, seafarers are no longer merely operators of equipment, but increasingly serve as managers of systems in more and more scenarios.

On one hand, the decision-making process of ship operations is undergoing a digital transformation. For example, the bridge must be familiar with the intelligent navigation decision support system, while the engine department must become familiar with the energy consumption monitoring and emissions reporting systems. This has directly led to the weakening of traditional job role boundaries, replaced by a collaborative understanding of the entire ship’s digital ecosystem. In this context, cybersecurity risks on ships have become an integral part of daily ship management. Seafarers’ safety responsibilities are no longer confined to traditional tasks such as ensuring the safety of the ship, personnel, and cargo, including fire prevention, explosion protection, and oil spill response, but have extended to safeguarding information and control systems security. Research shows that, compared to physical attacks, cyberattacks on integrated navigation systems are easier to execute. For instance, falsifying a ship’s position in the Electronic Chart Display and Information System (ECDIS) could lead to the vessel running aground, triggering a serious navigational incident without direct physical collision (Hutchins et al., 2011). Cyber intrusions, data tampering, and navigation signal interference can all transform into tangible navigational risks during a voyage, potentially leading to environmental navigation incidents.

On the other hand, this shift has also significantly altered the way seafarers’ liability in maritime accidents is determined. Traditionally, the determination of seafarer liability has focused on the seafarer’s reasonable skill and care. However, when a vessel’s core operations rely on highly autonomous intelligent navigation systems provided by external vendors, the cause of an accident may stem from design flaws in the system or errors in the algorithmic logic. For example, an AI navigation program might make incorrect collision avoidance decisions based on biased chart data, ultimately leading to a ship collision. In such scenarios, if the seafarer has conducted regular monitoring according to approved procedures and failed to identify system anomalies within a reasonable timeframe, it would be unfair to place the entire responsibility on the seafarer. In this case, liability determination will inevitably extend upstream, touching upon the realm of product liability. In response to this, the European Commission, in its Report on the Safety and Liability Implications of Artificial Intelligence, the Internet of Things, and Robotics (European-Commission, 2020), published on February 19, 2020, pointed out that, as part of the subsequent legislative proposals under the EU’s existing product safety framework, automated decision-making and software have been explicitly considered as independent products. Subsequently, in October 2024, the EU adopted Directive (EU) 2024/2853 (European-Parliament & Council-of-the-European-Union, 2024), replacing the outdated 1985 Product Liability Directive. One of the major changes was the expansion of the definition of products to include software. In Article 13, it is explicitly stated that operating systems, firmware, computer programs, applications, or AI systems should be considered as software, which naturally includes maritime operating systems and AI navigation systems. This means that investigations into maritime accidents will require more cross-disciplinary technical support to determine whether the root cause of the incident was due to seafarer error or inherent flaws in the system itself. Furthermore, as the shipping industry undergoes digital transformation and vessels become increasingly intelligent, the situational awareness and decision-making processes of smart ships depend on algorithmic reasoning that integrates sensor data with prior experiences. Shore-based operators can no longer directly observe the system’s execution but can only access abstracted results through information interfaces. The black-box nature1 of autonomous systems prevents shore-based operators from assessing the ship’s current control logic and the specific actions to be taken next in real time. In this context, determining the liability of seafarers indeed presents an unprecedented level of complexity.

3.2.2 From shipboard operations to shore-based operations

Shore-based operations refer to all existing professional activities conducted on land that provide support and management for vessel operations, as well as the shore-based professional positions that arise during the shipping industry’s green transformation process, focusing on new energy, the application of new technologies, and compliance with emission reduction regulations. As the green transition of the shipping industry deepens, some traditional seafarer roles will extend to shore-based positions, and seafarers’ careers at sea may become shorter, with new green jobs emerging on the shore-based side (UN-Global-Compact, 2022). Firstly, the promotion and widespread adoption of new energy ships will itself generate new job demands and functional transformations on the shore-based side. Risk assessment for alternative fuel bunkering, on-site supervision, and other tasks will mostly be handled by port and shore-based professionals, the construction of shore power and berth connection systems will also create long-term engineering and operations positions on the port side, thus leading to an increase in shore-based jobs within the port and supply chain sectors. Secondly, as the scale of new energy and clean energy ships continues to expand, these vessels, as carriers of emerging technologies, may face various emergency situations during their operation, requiring strengthened shore-based communication and remote support, which in turn places higher demands on shore-based emergency response and technical support teams. Finally, against the backdrop of increasingly stringent shipping emission reduction policies, shipping companies are increasingly shifting tasks related to emission reduction compliance to shore-based operations, with companies coordinating the energy consumption and emissions data for the entire fleet, compiling and verifying it annually, and submitting compliance documentation to the relevant authorities, which has, in turn, objectively driven the development of a more systematic and professional shore-based support infrastructure.

The green and low-carbon transformation of the shipping industry is driving a profound change in seafarers’ work patterns, and the shift of functions from sea-based to shore-based roles is not only fostering the diversification of seafarer job structures but also raising higher demands for the knowledge structure and skill development of future maritime talent. Therefore, proactively building a corresponding shore-based talent development system has become crucial for supporting the industry in achieving its green transition.

4 Regulatory pathways for seafarer issues in the context of shipping green transformation

In the context of the global green transformation of shipping, the issue of energy justice has gradually become a key topic. In the pursuit of sustainable development, energy justice not only focuses on the fair distribution of the benefits and costs of energy services but also involves the different impacts borne by various social groups during the transition process. Particularly in the green transition of the shipping industry, seafarers, as a directly affected group, face direct impacts on their working conditions and quality of life due to the introduction of new technologies, the implementation of emission reduction measures, and changes in compliance requirements. Therefore, this paper, in discussing energy justice within the green transition of shipping, places particular emphasis on the distribution of benefits and the allocation of risks faced by seafarers in this process.

4.1 The energy justice issue in the green transition of shipping

Energy justice, as an integral part of sustainable development theory (Guruswamy, 2010), centers on establishing a global energy decision-making system that follows principles of fairness and justice, ensuring that the public shares the benefits of energy services and bears the costs of energy provision (Benjamin and Michael, 2014). According to the foundational research by scholars such as Darren McCauley, the framework of energy justice analysis is composed of distributional justice, procedural justice, recognition justice, and energy restorative justice (McCauley et al., 2013). Among them, distributional justice, as the ultimate goal of energy justice, directly concerns the social distribution of costs and benefits during the energy transition process (Ning and Yang, 2022b). Specifically, it aims to address a core question: how the positive impacts of the energy transition, such as a cleaner environment, job opportunities, and energy security, can be fairly distributed among different social groups, regions, and even generations, as well as the negative impacts, such as unemployment, community disintegration, and environmental pollution transfer, to ensure that the benefits of the transition are shared by society as a whole.

When applying this theory to explain the green transition of global shipping, if the focus is only on the state-industry-enterprise level, it risks obscuring a key fact: one of the direct bearers of the green transition is the seafarer. The technological pathways, compliance rules, and operational process changes in shipping emission reductions will ultimately be translated into specific impacts on the work and lives of seafarers through channels such as skill requirements, work intensity, and occupational safety risks. Therefore, the discussion of energy justice in this paper, within the shipping context, does not end with abstract cost-sharing but focuses on the distribution of benefits and risks for seafarers in the green transition: who gains the benefits of the transition, who bears the costs, and why this distribution becomes embedded in institutional and power structures.

We have noticed that it is evident that the global green transition of shipping inherently contains a core paradox: the acceleration of the transition process does not necessarily lead to a higher level of social justice. The green transition of shipping, as a justice-driven endeavor aimed at promoting sustainable development for humanity, while driving systemic social, political, economic, and cultural reforms, is also bound to trigger a series of social justice issues. Firstly, the economic restructuring triggered by the green transition directly impacts the labor market, creating a green unemployment group (Ning and Yang, 2022a). As traditional carbon-intensive operational models are gradually phased out, the structure of seafarer jobs is undergoing profound transformation. On one hand, the demand for seafarers with expertise in traditional heavy fuel engine technology will significantly decline; On the other hand, there is a sharp increase in the demand for technical seafarers with the skills to operate and manage new energy systems. This reversal in supply and demand not only poses a potential reduction in the number of seafarer jobs but also exacerbates the unemployment risks brought about by the imbalance in skill matching. Secondly, behind the noble social benefits pointed to by the green transition of shipping, there lies a high and unevenly distributed social cost. With the introduction of new emission-reducing technologies and mandatory reporting procedures, seafarers must adapt to entirely new workflows, master complex systems, and follow stricter operational standards. For example, mastering new equipment often requires additional time and effort for training and certification, and the increased monitoring, maintenance tasks, and compliance procedures required to adhere to new environmental regulations during the transition also subtly increase their workload and psychological pressure.

4.2 Addressing energy justice issues through the just transition principle

The Just Transition principle originated in 1993, proposed by American labor and environmental activist Tony Mazzocchi, with the primary aim of addressing the potential conflict between environmental protection and workers’ employment (Mazzochi, 1993). Since then, this principle has gradually evolved, and its practical application has expanded from the field of environmental protection to encompass the entire green transition process (Ning and Yang, 2022a). In its revised 2023 IMO Strategy on Reduction of GHG Emissions from Ships, the IMO states that it should help ensure a just transition for seafarers and other maritime workers, ensuring that no one is left behind in the process (IMO & MEPC, 2023). Accordingly, the Just Transition principle, as a justice principle that should always be upheld during the green transition process, refers to ensuring that, during the shipping industry’s shift to a green, low-carbon economy, all affected groups, particularly seafarers and other maritime workers, are able to transition fairly into new work environments and gain new employment opportunities. This principle aims to balance environmental goals with social fairness, avoiding the creation of inequality in resource endowments as a result of the green transition.

The Just Transition principle provides an important theoretical framework and practical pathway for addressing energy justice issues. At the international level, the Paris Agreement has established the Just Transition principle as a key strategic approach to addressing climate change. At the interregional level, the EU’s European Green Deal clearly aims to make the EU the world’s first climate-neutral continent, incorporating the Just Transition principle into its core policy (European-Commission, 2019), and plans to establish a Just Transition Fund with nearly €20 billion in funding, primarily supporting groups affected by the transition, by creating green jobs, providing retraining opportunities, and promoting the widespread use of clean, affordable, and safe energy to facilitate an equitable transition (European-Commission, 2024a). At the national level, South Korea’s Basic Act on Carbon Neutrality and Green Growth for Responding to Climate Crisis established a specific chapter on Just Transition to fully implement the Just Transition principle, emphasizing the need to achieve a social sharing of transition costs and minimize negative impacts on vulnerable groups. The above practices indicate that when an economy has strong financial capacity, a well-established social security system, and a centralized and unified governance structure, the principle of a just transition is more likely to be institutionalized into a policy mix that integrates financial support, employment services, and social security.

However, we must acknowledge that directly transplanting the above experiences into the shipping industry, especially in low- and middle-income countries (LMICs) that supply a large number of seafarers, may face structural barriers. For many low- and middle-income countries, replicating the EU-style funding arrangements or the South Korean comprehensive legislative framework is not a matter of lack of will, but rather is constrained by practical issues such as limited fiscal space, weak vocational education and maritime training infrastructure, inadequate coverage of employment services and social security, and the heavy reliance on remittances for labor exports. In the absence of stable funding sources and cross-border responsibility-sharing mechanisms, a just transition may remain at the level of value declaration, making it difficult to translate into sustainable institutional provisions.

In this regard, to accelerate the just and equitable transition of shipping in developing countries, Denmark’s project document for the IMO development assistance program (Ministry-of-Foreign-Affairs-of-Denmark-(Danida), 2024) points out that many developing countries urgently need external support to unlock the green transition’s development potential, leverage large-scale investments, and establish a policy framework to promote zero-emission shipping. Without this support, it will be difficult for these countries to keep up with the maritime sector’s green transition. If the global South is excluded, the IMO’s climate goals will also be hard to achieve, which underscores the need to promote a just and equitable transition. In a similar vein, on November 11, 2024, as part of the EU-ASEAN Sustainable Connectivity Package (SCOPE), the European Commission funded a technical assistance project for 2024 between the EU and the Philippines. The project aims to strengthen the Philippines’ education, training, and certification system for seafarers through external funding and technical assistance, ensuring that Filipino seafarers can continue to work in international markets (European-Commission & Government-of-the-Philippines, 2024). This demonstrates that shipping operators in underdeveloped countries need external support to adapt their maritime systems to zero-emission technologies (Gilliam et al., 2024).

In the long run, implementing the Just Transition principle is not only to address the short-term challenges brought by the green transition but also to ensure the healthy development of the shipping industry, maintain social stability and fairness, which concerns not only the personal interests of seafarers but also the long-term sustainable development of national and shipping labor markets, which in turn can promote broader social equity and environmental justice. However, at the same time, the principle of a just transition in the shipping industry should not be understood as a set of automatically effective magic solutions, but should be concretized into a series of actionable institutional arrangements. As the shipping industry moves towards a green, low-carbon economy, we cannot overlook the dual challenges that seafarers may face in terms of skills and employment, nor can we ignore the differences between countries or regions in terms of fiscal capacity, governance structure, and industrial development. Therefore, the principle of a just transition in the green transformation of the shipping industry must reflect differentiation and accessibility. On one hand, special attention should be given to the capacity constraints of developing countries, least developed countries (LDCs), and small island developing states (SIDS); on the other hand, financial, technical, and training support should be provided to enable them to actively participate in and benefit from the green transition.

5 The protection deficit of seafarers in the green transition of shipping

To assess the impact of decarbonization regulations and technologies on the work and mental health of seafarers and shore-based workers, the International Seafarers’ Welfare and Assistance Network (ISWAN) conducted a survey between June and September 2023 (ISWAN, 2023), to help relevant stakeholders better understand and address the challenges faced by seafarers in the zero-carbon transition process. This survey collected valid feedback from 400 seafarers of 29 different nationalities and 55 shore-based staff. Among the respondents, 97% were male, which is primarily due to the industry’s relatively traditional work model and higher operational risks, with female workers often facing more potential risks in the workplace (He and Chang, 2020). As a result, the number of male seafarers in the shipping industry is significantly higher than that of females. In terms of nationality distribution, respondents from India (42.8%) and the Philippines (15.6%) made up a large proportion, showing a trend towards concentration in countries that supply fewer seafarers. This distribution characteristic is closely related to ISWAN’s numerous offline institutions and strong local communication networks in these two countries. The study showed that, although most seafarers support the shipping industry’s decarbonization goals, the rapid application of new technologies and the increasingly complex regulations have had a significant impact on their workload, psychological stress, and fatigue levels. It is worth noting that in the job distribution chart of the report, the two largest groups of survey samples are engine officers (42.5%) and deck officers (39.4%), together accounting for more than 80% of the total study subjects. However, the proportion of trainees is too small. This structural bias means that the conclusions of the report largely reflect the perspectives of experienced seafarers and do not adequately capture the real challenges faced by less experienced groups, especially in dealing with new technologies and complex operations. The actual situation may be more severe than what the study results suggest.

5.1 The fuel mix plan intensifies seafarers’ operational burden

Currently, alternative fuels available for ship propulsion mainly include LNG, methanol, ammonia, hydrogen, and biofuels. Among them, LNG holds a dominant position in current applications, but its potential for reducing greenhouse gas emissions as a marine fuel is relatively limited, with a short opportunity window (Wang et al., 2022), and the methane slip issue in LNG applications cannot be overlooked, as any significant methane leakage could offset LNG’s relative advantage in terms of Global Warming Potential (GWP). Therefore, in the medium to long term, given that LNG cannot meet the deep decarbonization requirements of shipping (Wang et al., 2025), it seems more suitable to be regarded as a transitional fuel. From an socio-economic cost perspective, hydrogen, methanol, and ammonia are currently the most compatible alternative options (ben Brahim et al., 2019). However, the initial investment cost of zero-carbon ammonia fuel remains highly dependent on the development of hydrogen production technology. Currently, the lifecycle cost of ammonia fuel for ships is still high, approximately twice the cost of traditional diesel (Perčić et al., 2023). Hydrogen fuel, on the other hand, is limited by its lower energy density, making it primarily suitable for inland cargo ships, small cruise ships, and sightseeing barges. If hydrogen fuel cells are used as a power source, it is recommended to combine hydrogen with other energy sources as an auxiliary power system (Perčić et al., 2020). In terms of methanol fuel, both coal-based methanol (Huang et al., 2022) and natural gas-based methanol (Wang et al., 2022) do not significantly improve the lifecycle greenhouse gas emissions of ships. Regarding the supply of green methanol, there is currently a severe shortage globally, and China is no exception. The vast majority of green methanol projects are still in the preparatory or theoretical validation stages, with very few projects actually reaching production.

Overall, there is currently no single alternative fuel solution that is ideal in all aspects. Each fuel faces different challenges and limitations in terms of emission reduction potential, technological maturity, energy reserves, infrastructure, and operational costs. In this context, the practical industry generally believes that adopting flexible hybrid solutions is the more realistic and feasible path at present. This trend is clearly reflected in recent ship ordering data. New ship orders for 2024 show that dual-fuel-powered vessels have become the mainstream choice in the market, particularly in the container shipping sector (UNCTAD, 2025), in order to maintain greater operational flexibility and compliance space during the energy transition process.

However, this coexistence of multiple fuels as a transitional solution has also created new challenges, which marks a clear departure from the traditional shipping practice of using a single fuel type. The most direct manifestation of this is the higher demands placed on seafarers, seafarers not only need to master the operation of traditional fuel systems but must also be familiar with the storage, bunkering, handling, and emergency response procedures for fuels with different characteristics, such as LNG and methanol. Taking methanol and ethanol fuels as an example, the IMO’s Interim Guidelines for the Safety of Ships Using Methyl/Ethyl Alcohol as Fuel require ships to be equipped with suitable instrumentation devices to allow local and remote readings of essential parameters, thereby ensuring the safe management of the entire fuel system, including bunkering. Additionally, before conducting bunkering operations, pre-bunkering verification must be completed, which includes verifying all communication methods, operation of fixed fire detection equipment, operation of portable gas detection equipment, readiness of fixed and portable fire-fighting systems and appliances, operation of remote-controlled valves, and inspection of hoses and couplings. These regulations will significantly increase the operational burden on seafarers. According to the survey results, the Storage and use of different grades of fuel is seen by seafarers as one of the most challenging negative factors in the green transition of shipping. The data shows that approximately 26.3% of respondents indicated that the changes in fuel types involved in decarbonization regulations have had a significant negative impact on their daily work (ISWAN, 2023). The significant differences in the physicochemical properties, safety risks, and operational standards of different fuels make it challenging in the current context, where the technical routes and fuel choices are still unclear, to effectively enhance seafarers’ overall skills and ensure their ability to work in a multi-fuel environment, which has become one of the key issues that the shipping industry must address in moving towards a decarbonized future.

5.2 Safety hazards of alternative fuels threaten seafarers’ physical and mental health

Alternative fuels demonstrate significant potential in advancing the energy transition; however, their widespread application still faces a series of safety challenges that cannot be ignored, including flammability, explosion risks, and toxicity. For example, hydrogen, as an alternative fuel, presents significant challenges in liquid storage due to its extremely low boiling point. If a leak occurs in a confined or semi-confined space and is ignited, it could lead to a catastrophic explosion, potentially causing explosive overpressure strong enough to damage the entire ship’s structure and equipment. Ammonia fuel, on the other hand, presents risks such as high toxicity, complex combustion characteristics, nitrous oxide emissions, and the potential for ammonia escape, all of which increase the safety hazards associated with its practical application. Methanol, as a common alternative fuel, also presents a high fire risk, with a wide flammability range from 6.7% to 37%, and a high latent heat of vaporization, allowing it to remain flammable even in aqueous solutions. Its auto-ignition temperature is as high as 464 °C, further increasing the difficulty of safety management (DNV, 2024b). A survey conducted by Det Norske Veritas (DNV) involving 527 seafarers aligns closely with this reality, with approximately 42% of respondents believing that, compared to traditional fuels such as Marine Gas Oil (MGO) and Heavy Fuel Oil (HFO), the safety of new fuels is lower (DNV & SMF, 2023). This reflects the widespread concern among industry practitioners about the potential risks of alternative fuels and highlights the urgency of strengthening safety standards and risk prevention during the promotion of these technologies.

In addition to the fuel characteristics themselves, the application of new fuels on existing ships faces a series of technical challenges and potential safety hazards. For example, engineers have pointed out that on ships carrying a mix of ultra-low sulfur fuel oil (ULSFO), very low sulfur fuel oil (VLSFO), and low sulfur marine gas oil (LSMGO), the fuel switching process significantly affects the operational state of the ship’s mechanical systems, and after switching to marine diesel, the change in fuel temperature characteristics, combined with equipment aging and other factors, can lead to fuel leakage issues. The fundamental issue lies in the fact that the engine systems on existing ships were not fully optimized during the design phase for the use of clean fuels (ISWAN, 2023).

Since the transition from traditional fossil fuels to alternative fuels is a crucial means for the decarbonization of the shipping industry, the international community has adopted a gradual approach to the use of clean fuels. For example, the previous International Code for the Construction and Equipment of Ships Carrying Liquefied Gases in Bulk (IGC Code) explicitly prohibited the use of toxic gas cargoes as fuel. However, later, IMO MSC 109 approved amendments to Chapter 16 of the IGC Code, lifting the ban on using toxic products as fuel, allowing certain toxic gases to be used as fuel, provided they meet the same safety level as methane and comply with the guidelines set by the IMO (MSC, 2024). However, it is worth noting that the unique physical and chemical properties of these clean fuels also come with specific risks. These ongoing safety hazards not only directly threaten the physical health of seafarers but also impose a heavy burden on their mental well-being. On one hand, seafarers are constantly exposed to environments with flammable, explosive, and even toxic fuels, significantly increasing health risks. On the other hand, this constant concern about potential accidents requires seafarers to remain highly vigilant in their daily work, further exacerbating their work-related stress and sense of insecurity, which can easily trigger psychological issues such as anxiety and insomnia. Over time, this accumulation may even lead to occupational burnout. Therefore, in advancing the green transition of shipping, developing a compliance system for ship operations that balances both technical safety and the physical and mental health of seafarers has become an urgent issue that the industry cannot avoid.

5.3 Fragmentation of shipping emission regulations increases seafarers’ compliance risks

As the IMO’s global net-zero framework for shipping greenhouse gas emissions is still in the process of institutional development, a pioneering governance paradigm led by individual countries or regional alliances has quietly emerged, with various jurisdictions implementing diverse regulatory systems and competing to devise localized carbon pricing and regulatory mechanisms, leading to the shipping industry, which relies on global operations, being forced to confront the increasingly fragmented and geopolitically driven carbon regulatory landscape. Specifically, the EU took the lead by launching the European Green Deal in 2019 (European-Commission, 2019). 2 In 2024, the regulatory scope of the EU ETS was officially extended to the shipping industry. Meanwhile, due to the policy adjustments resulting from Brexit, the UK Emissions Trading System (UK ETS) plans to officially include the shipping industry under its regulation on July 1, 2026, with the scope covering all ships operating in domestic UK waters and in port (UK-Government, 2025). Compared to the EU ETS, the UK ETS started in 2021 with an emission cap 5% lower than the preset level under the previous EU system, and by 2025, its cap will fully align with the IMO’s net-zero emissions target (Hub, 2025). In addition, Djibouti launched a national carbon pricing mechanism for international shipping on March 13, 2023 (eJO, 2023), which is now fully implemented. This mechanism is the first of its kind in Africa, specifically targeting greenhouse gas emissions from international shipping, and aims to establish a carbon contribution mechanism and a national carbon registry. Given Djibouti’s strategic location at the Bab-el-Mandeb Strait, which controls the key passage between the Suez Canal and the Indian Ocean, and considering Djibouti’s geopolitical advantages, this emission reduction policy has garnered widespread attention from the international community.

Since the entry into force of the Paris Agreement in 2016, it is evident that global climate governance has entered a new paradigm, with different jurisdictions, based on their respective stages of development, industrial interests, and geopolitical considerations, successively introducing diversified carbon pricing, carbon markets, and carbon border adjustment mechanisms. These overlapping and diverse regulatory systems, with varying rules and standards, have increasingly highlighted the trend of geopolitical and fragmented global carbon governance.

For example, with regard to monitoring and reporting mechanisms, the EU revised the MRV Maritime Regulation in 2023, imposing obligations on shipping companies to monitor, report, and ensure the possession of compliance documents on board (European-Commission, 2024b). From January 1, 2025, the revised EU MRV Maritime Regulation will cover general cargo ships of 400 to 5,000 GT and offshore vessels of 400 GT and above (DNV, 2024a), while the IMO’s Data Collection System (DCS) applies to ships of 5,000 GT and above engaged in international voyages, highlighting a clear difference in the scope of application between the two (IMO, 2024b). Additionally, from January 1, 2024, the EU MRV mechanism, in addition to monitoring carbon dioxide, will also require the monitoring and reporting of methane and nitrous oxide, which are potent greenhouse gases or byproducts prone to leakage during the use of alternative fuels such as LNG (European Commission, 2025c), In contrast, the core focus of the IMO DCS remains on fuel consumption, namely carbon dioxide emissions, and generates a global uniform carbon intensity indicator based on this (IMO, 2024a). Table 3 shows the comparison between EU MRV and IMO DCS.

Table 3

Comparison between EU MRV and IMO DCS
Comparison dimensionEU MRVIMO DCS
Legal BasisEU Regulation 2015/757 (as amended and integrated into EU ETS).MARPOL Annex VI, Regulation 22/22A [MEPC.278(70)].
ObjectiveTo monitor, report, and verify emissions from the maritime sector, providing data for EU carbon governance (including EU ETS).To collect fuel consumption data to support the IMO’s development of global emission reduction measures.
Applicable Ship SizeGeneral cargo ships between 400 and 5000 GT, as well as offshore ships of 400 GT and above.Ships of 5,000 GT and above.
Scope of ApplicationApplies to voyages from or/and to ports in the European Economic Area (EEA) for transporting for commercial purposes cargo or passengers.Applies to all international voyages.
Applicable activitytransport of goods and persons.Any activity carried out by ships in the marine environment.
Monitoring ContentCarbon dioxide (CO2); Methane (CH4); Nitrous oxide (N2O).Each type of fuel oil they use as well as other specified data.
Data Units & Reporting MethodRequires detailed data for each voyage according to a mandatory template.The aggregated data is first reported to the flag State after the end of each calendar year.
Monitoring Plan TemplateMust follow a mandatory template; monitoring plan must be verified by an independent verifier.IMO provides a recommended template; the specific arrangements are executed by the flag state.
Verification SystemNational Accreditation Bodies (NABs) are the sole competent bodies in Member States that can grant accreditation to legal entities performing verification activities pursuant to the MRV Maritime Regulation.Verification is carried out by the flag state or authorized organizations according to national procedures.
Data TransparencyData is publicly disclosed.IMO’s database is anonymized.
ExemptionWarships; naval auxiliaries; fish-catching or fish-processing ships; ships not propelled by mechanical means; government ships used for non-commercial purposes.Not mentioned.

Comparison between EU MRV and IMO DCS.

As different countries or regions implement their own independent carbon emission regulatory frameworks, seafarers are required to cope with increasingly complex compliance requirements. This not only includes understanding and operating within different regulatory systems but also frequently adjusting according to the rules of different regions during voyages. Taking the aforementioned EU MRV mechanism and IMO DCS mechanism as examples, the EU MRV requires the collection of detailed activity data for each voyage, such as actual cargo load, fuel consumption, and the ports of departure and arrival, with records made and subsequently summarized. This requires onboard systems to have more detailed recording functions and demands that seafarers strictly follow the MRV reporting template to submit data and verify various raw data. In comparison, the IMO DCS places more emphasis on annual fuel consumption data and does not require detailed records by individual voyage. Since the EU requires more precise ship behavior data, seafarers must devote more time to daily record-keeping, labeling, and verification, while also preparing and submitting various documents within a limited operational window. For ships docking in EU ports, seafarers need to meet both the EU MRV and IMO DCS reporting requirements within the same voyage, but differences in data formats, timelines, and indicator definitions between the two systems can lead to redundant work. As the EU MRV expands to include greenhouse gases like methane and nitrous oxide, ships using LNG and other low-carbon alternative fuels need to install and maintain additional monitoring equipment. In addition to daily navigation tasks, seafarers must also understand and operate sensors, monitoring modules, and data acquisition systems used to measure these gases, ensuring data accuracy. This requires seafarers not only to master traditional fuel data recording skills but also to possess professional knowledge in handling emissions data related to alternative fuels, which was not commonly required under the IMO DCS system that primarily focused on fuel consumption. Ultimately, this is due to the fact that although the IMO officially directs national administrative bodies, these bodies operate within independent jurisdictions. Even when dealing with the same rule, the implementation may vary depending on the legislative intentions of different countries (Knudsen and Hassler, 2011).

According to the survey, faced with the lack of standardized and coordinated environmental legislation, a large number of respondents reported experiencing significant compliance pressure when undertaking cross-regional voyages, as each port has different rules regarding fuel use. Nearly one-third (32.8%) of seafarers clearly stated that the multiple rule changes brought about by the decarbonization process have made them more concerned about facing criminal penalties due to administrative oversight or inadvertently violating overlapping environmental regulatory systems. Nearly one-third (32.8%) of seafarers clearly stated that the multiple rule changes brought about by the decarbonization process have made them more concerned about facing criminal penalties due to administrative oversight or inadvertently violating overlapping environmental regulatory systems (ISWAN, 2023).

A more profound issue is that the legal uncertainty arising from the fragmentation of regulatory systems is reshaping the professional risk structure for seafarers. On one hand, the potential risk of criminal penalties significantly increases the decision-making burden on seafarers in their daily operations. On the other hand, the inconsistency in regulatory enforcement and penalty severity across jurisdictions makes it difficult for seafarers to establish stable compliance expectations. When seafarers adopt a conservative stance toward emerging low-carbon technologies due to concerns about personal legal liability, the entire industry’s green transition process is bound to be hindered.

6 The regulatory path for seafarer rights protection under the just transition principle

In the context of the green transformation of the shipping industry, how to effectively protect seafarers’ rights has become an urgent issue. To ensure that seafarers can fairly benefit from this transition, relevant policies and legal measures are particularly important. This paper will delve into the three issues raised above and explore, under the guidance of the Just Transition principle, how to effectively safeguard the rights of seafarers and ensure their smooth adaptation to this transformation.

6.1 Adopting fixed trading patterns to reduce seafarers’ fuel handling pressure

The fixed trading patterns referred to in this paper does not specifically denote the established liner shipping, but rather emphasizes an operational philosophy aimed at exploring relatively stable and predictable routes and fuel supply solutions for specific fleets or trade corridors during the green transition period. In traditional shipping models, seafarers often need to frequently switch fuel types based on the fuel demands of different routes, which not only increases the requirements for seafarers’ fuel knowledge and operational skills but also presents greater challenges in fuel storage, bunkering, and emergency handling. In contrast, the application of fixed trading patterns in shipping, especially during the decarbonization process, can effectively alleviate the burden on seafarers in fuel operations. Survey results show that, due to the limited variation in fuel types encountered by seafarers under the fixed trading patterns, the issues related to storing and using different grades of fuel are simplified. Seafarers using fixed trading patterns fewer negative impacts in their work, particularly with significantly reduced pressure on fuel management. Data indicates that only 23.5% of seafarers on fixed trading patterns report negative impacts on their work, while the percentages are 47.1% and 34.1% in partially fixed trading patterns and no fixed trading patterns, respectively (ISWAN, 2023). The fixed trading patterns helps reduce the operational complexity faced by seafarers due to frequent fuel changes, thus alleviating the associated operational burden.

Currently, the fixed trading patterns has not been widely adopted, primarily due to the economic considerations of shipping companies. The demand for fast transportation from consumers and the tendency of retailers to cut costs have reduced shipowners’ willingness to invest in the fixed-route model. Shipping companies typically rely on flexible route designs to optimize cargo loading and better respond to market demands. Flexible routes allow shipping companies to adjust transport routes based on different needs, maximizing cargo utilization and meeting customer demands. However, studies have shown that two key variables affecting the economic efficiency of ship navigation—fuel consumption and speed—are approximately proportional to the cube of the speed (De et al., 2021). If the scheduling and fuel replenishment strategies can be systematically optimized in combination, there is potential for a significant improvement in economic efficiency within the framework of the fixed-route model. Current studies have shown that if ports offer cooperation agreement terms such as multiple time windows, multiple start and end times, and improved loading and unloading efficiency, it will provide shipping companies with greater flexibility in adjusting sailing speeds and scheduling, thereby helping to reduce operating costs and optimize fuel consumption (Li et al., 2022).

In summary, the widespread adoption of fixed trading patterns will provide seafarers with greater operational stability and predictability, reducing the emergency pressure caused by unexpected fuel issues. Its economic disadvantages are also expected to be mitigated through optimized scheduling and fuel replenishment strategies. Therefore, in the context of multiple fuels coexisting, the fixed trading patterns undoubtedly offers seafarers a more comfortable and efficient working environment, helping them better adapt to the challenges brought about by the decarbonization transition.

6.2 Reducing seafarers’ health risks through professional training

LNG, batteries, and biofuels are likely to become key transitional options for shifting ship propulsion energy from traditional fossil fuels to emerging clean fuels such as ammonia, hydrogen, and methanol. However, DNV’s survey data reveals a significant gap between seafarer skills and this energy transition trend, with most respondents admitting a lack of practical experience with emerging fuels, and over 75% clearly stating the need for systematic training on LNG, batteries, or synthetic fuels. For more advanced ship fuels such as ammonia, methanol, and hydrogen, the skills gap is even wider, with nearly 87% of respondents believing they need partial or even comprehensive training (DNV & SMF, 2023). The reason is that these new fuels are still relatively limited in actual ship applications, but this also means that, once these clean energy sources are fully introduced in the future, a lack of timely and comprehensive seafarer training systems could potentially become a barrier to the implementation of technology and even pose a threat to navigation safety.

To establish a supporting seafarer training system, it is recommended to approach it from the following three aspects.

The first aspect is to establish a unified international training framework. Currently, the IMO has officially issued the Generic Interim Guidelines on Training for Seafarers on Ships Using Alternative Fuels and New Technologies (STCW.7/Circ.25). The guidelines aim to provide standards for the development and implementation of seafarer training on ships using alternative fuels and new technologies, offering a normative basis for the development and approval of training worldwide (IMO, 2025b). Subsequent guidelines focused on Fuel- and technology- specific interim training will be reviewed in February 2026, and are intended to form the basis of mandatory training requirements in amendments to the 1978 STCW Convention Code (IMO, 2024c). Alongside the revision of the STCW regulations, the Maritime Just Transition Task Force (MJTTF) has also released the shipping industry’s first seafarer training frameworks for ammonia, methanol, and hydrogen-powered vessels (MJTTF, 2025), which are intended as transitional practical standards to enable seafarers to operate such vessels, thereby addressing gaps in the current STCW regulations regarding training for these fuels.

The second aspect is to implement specialized training focused on fuel differentiation to reduce the health risks faced by seafarers when using new clean fuels. Specifically, ammonia is highly toxic and corrosive, and seafarers need to understand its physicochemical properties, hazard characteristics, and exposure threshold limits, as well as the demarcation of hazardous and toxic areas onboard and the personal protective equipment (PPE) requirements when working in or entering these areas. Compared to traditional fuels, methanol’s low flashpoint and high flammability require the use of new fire detection methods and safety protocols. Hydrogen fuel is highly prone to leakage and highly flammable, requiring enhanced leak and flame detection, ventilation systems, and cryogenic/high-pressure storage management, with particular attention to fuel storage to prevent the formation of combustible gas mixtures. Furthermore, unlike methanol and ammonia, compressed hydrogen or liquid hydrogen has not yet been widely used for bulk cargo transport. Therefore, the shipping industry urgently needs to focus on the particularities of hydrogen as an alternative fuel to ensure its safety as a ship propulsion fuel (MJTTF, 2024).

The third aspect is to address the lack of maritime education and training resources in developing or least developed countries. Since the beginning of the 21st century, the maritime and seafarer export industries in developing countries have grown significantly, primarily due to the lower employment costs of seafarers from these countries. To truly implement professional training for the green transition in the shipping industry, the unequal distribution of maritime education and training resources must not be overlooked. Data shows that the shipping industry employs around 2 million seafarers, with the majority coming from the Global South. If relevant new skill training is not widely disseminated in a timely manner, this group will face the risk of being marginalized by technological advancements (Reuters, 2024). This issue not only pertains to the individual career development of seafarers but also directly affects the effectiveness of the entire maritime industry’s sustainable transformation. In the future, addressing the lack of maritime education and training resources in developing or least developed countries can be advanced from two aspects. The first is to promote large-scale remote education and digital training. Remote education can overcome geographical and resource limitations, enabling seafarers from developing countries to access internationally standardized course content. This also aligns with several amendments to the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers (STCW) (Mallam et al., 2019). Existing research has shown that full-mission simulators can help seafarers find the appropriate balance between safety and energy efficiency management, potentially reducing energy consumption by an average of 10% (Surinov and Shemonayev, 2021). The second aspect is to promote the funding of professional training programs by high-income countries and international organizations. The involvement of high-income countries, regional organizations, and industry alliances in training funding and technology transfer is crucial. Currently, some companies, such as Denmark’s Maersk, have already invested significant funds in maritime education and training specifically aimed at the green transition of the shipping industry (Reuters, 2024). In addition, the IMO and the Ministry of Land, Infrastructure, Transport and Tourism of Japan (MLIT) jointly implemented a three-year Train-the-Trainer program aimed at enhancing the training capabilities of maritime trainers in Asian countries regarding LNG-fueled vessel operations and safety. The program helps training instructors from Indonesia, the Philippines, and Vietnam acquire key skills such as LNG bunkering, safe handling, leak emergency response, and firefighting techniques through practical operations and simulator courses (IMO, 2025a). Similarly, as part of the Maritime Just Transition Task Force (MJT-TF) project, the IMO commissioned the World Maritime University (WMU) to collaborate with the Maritime Technology Cooperation Centre (MTCC) Asia headquarters at Shanghai Maritime University (SMU) to successfully launch the world’s first full-scale Train-the-Trainer Programme on Alternative Fuels for Sustainable Shipping. This program aims to educate seafarers and shore-based personnel on the safe and effective use of alternative fuels. By providing in-depth training to local trainers, it seeks to develop sustainable domestic training capabilities and reduce long-term reliance on external resources. The program will benefit multiple countries, including Bangladesh, India, Indonesia, Malaysia, Pakistan, and the Philippines (World-Maritime-University, 2025).

6.3 Promoting the cautious application and reasonable exemption of seafarers’ criminal liability

Currently, the global shipping emission reduction regulatory system is experiencing deep fragmentation, which significantly increases the legal liability risks faced by seafarers in ship-source pollution incidents. In this context, it is necessary to curb the trend of generalizing seafarers’ criminal liability in ship-source pollution cases, in order to uphold fairness and substantive justice in the application of the law. According to Article 230 of the 1982 United Nations Convention on the Law of the Sea (UNCLOS), seafarers are only criminally liable for willful and serious pollution actions within the territorial waters of a contracting state; For pollution actions occurring outside the territorial waters, regardless of whether the actor had intent or whether significant damage occurred, the coastal state may only impose fines (United Nations, 1982). It is evident that the convention itself reflects a cautious stance on holding seafarers criminally liable in ship-source pollution incidents (Zhang et al., 2018). However, a review of relevant case law from various flag states, port states, and coastal states reveals that some countries have held seafarers criminally liable for environmental pollution caused by their negligence. For example, the U.S. Clean Water Act imposes strict regulations and penalties on shipborne pollution. Although the primary objective of this law is to prevent intentional and malicious pollution, in certain cases, even if a seafarer did not deliberately violate environmental protection regulations, they may still face criminal charges due to pollution incidents. In the Exxon Valdez oil spill case (United-States, 1990), the tanker Exxon Valdez struck a reef, releasing approximately 11 million gallons of crude oil into the sea, and the captain, Joseph Hazelwood, was held criminally responsible for operational negligence.

We believe that in handling ship-source pollution incidents in the marine environment, it is essential to strictly differentiate between the responsibilities of shipping companies and seafarers, implementing a differentiated liability principle. For shipping companies, strict liability should be established, emphasizing their primary obligations in vessel management, equipment maintenance, and the enforcement of regulations. In contrast, for seafarers, the scope of criminal liability for seafarers’ environmental pollution crimes should be strictly limited, adhering to the principle of criminal law restraint, and promoting a more lenient standard for criminalization. Specifically, in terms of the outcome, pollution crimes should be clearly defined as material harm offenses. That is, criminal liability should only be pursued when the seafarers’ actions result in significant pollution damage. This aims to exclude criminal punishment for technical violations or minor negligence that have not caused substantial damage, preventing criminal law from overly intervening in areas that should fall under administrative or technical regulations. Secondly, regarding the subjective element, intent must be considered an indispensable prerequisite for determining criminal liability. Maritime activities are highly specialized and unpredictable, and the marine environment is complex and variable. If the fragmented global shipping emission reduction system leads to unintentional actions by seafarers due to confusion, misjudgment, or reasonable reliance, imposing criminal liability on them will not only cause psychological pressure but also suppress their decision-making ability in emergency situations, thereby increasing the overall risks in maritime operations. Additionally, from the perspective of effectiveness in prevention and control, imposing criminal sanctions for accidental pollution caused by non-intentional or grossly negligent behavior will also fail to achieve the original goal of pollution prevention in the system (Anthony, 2006).

In this regard, we call for the establishment of a unified standard for determining the criminal liability of seafarers in maritime pollution incidents within the IMO’s collaborative framework. As the global regulatory system for shipping emissions continues to develop and fragment, there is a significant inconsistency in the legal systems of different countries regarding the accountability of seafarers. This is particularly evident in cases of ship-source pollution, where the standards for criminal liability or the application of laws to seafarers vary greatly. This not only increases the legal risks seafarers face but also negatively impacts the long-term mechanisms for marine environmental protection. To avoid excessive criminal liability for seafarers across different jurisdictions, a unified standard for criminal liability should be promoted through the IMO’s collaborative mechanism to ensure fair and reasonable legal application. One potential reference is the Guidelines on Fair Treatment of Seafarers Detained in Connection with Alleged Crimes, which stipulates that the country detaining the seafarer should provide adequate legal assistance and ensure the seafarer has access to accurate information related to the case. When seafarers are detained for suspected crimes, the adequacy of all evidence should be thoroughly assessed before formal charges are made, and whether there is reasonable and objective suspicion of a crime should be carefully considered. Additionally, the actual operational conditions and requirements of the maritime industry must be taken into account. During the detention and investigation of seafarers, fair and transparent procedures must be followed to ensure the legal rights of seafarers are properly protected (IMO, 2024a). At the same time, it is recommended to establish an international coordination mechanism under the IMO framework to accelerate consensus among countries and standardize the determination and prosecution of seafarers’ criminal liability, thereby preventing unfair treatment of seafarers due to differences in legal application.

In summary, given the objective reality that the fragmentation of global emission reduction regulations increases the risk of legal violations for seafarers, legal accountability must remain cautious. Building a criminal liability system with the dual core of significant damage outcome and subjective intent, is key to providing necessary legal protection for seafarers and alleviating their undue psychological burden. At the same time, we call on the IMO to actively promote a unified global standard on crew criminal liability, safeguard the legal rights of seafarers, and prevent excessive criminal accountability due to differences in the application of national laws.

7 Conclusions

The green transformation of the shipping industry is a profound technological and energy revolution. However, while this transformation brings environmental benefits, it also triggers a serious deficit in seafarer rights protection. If the decarbonization goals of the shipping industry come at the expense of seafarers’ well-being and social fairness, it will deviate from the fundamental purpose of sustainable development. The main research findings can be summarized in three points:

First, in the context of the accelerated green transformation of the global shipping industry, the role of seafarers is undergoing profound and fundamental changes. This transformation is primarily reflected in the increasing work pressure, with emission reduction no longer being an abstract policy goal but a concrete burden integrated into the daily professional tasks of seafarers. At the same time, there are dual shifts in seafarers’ work patterns. On one hand, the collaborative development of digitalization and greening in the shipping industry is driving a shift from manual, experience-based mechanical operations to data-driven management relying on intelligent systems. Seafarers now need to navigate complex digital ecosystems, with their responsibilities extending into areas such as cybersecurity, and accident liability determination becoming more complicated due to the involvement of intelligent systems, potentially involving upstream product liability. On the other hand, the green transformation has fostered a significant trend towards shore-based operations. The operation of new energy vessels, emission reduction compliance management, and shore power support have created new professional roles on land, with some traditional seafarer career paths beginning to extend to land-based positions.

Second, in the process of the global shipping industry’s transition to a green, low-carbon model, the situation and rights of seafarers have become an urgent issue of energy justice. Energy justice theory emphasizes that the costs and benefits of transformation should be distributed equitably across society. In the shipping sector, seafarers face specific challenges such as changes in skill requirements, increased workload, and rising occupational risks. The green unemployment risks and uneven social costs brought about by the transformation highlight the absence of energy justice protections in the shipping industry. To address this challenge, the principle of just transition provides a crucial guiding framework. However, while international organizations like the IMO have incorporated this principle into their strategies, and the EU, South Korea, and others have made beneficial attempts through the establishment of transition funds and special legislation, the implementation of a just transition globally, especially for low- and middle-income countries that are major sources of seafarers, faces structural barriers. These countries often struggle with limited financial capacity, inadequate training systems, and insufficient social security, making it difficult to independently support the retraining and employment support systems needed for the transition. Therefore, achieving a just transition in the shipping industry cannot rely on a single model; the key path is to establish an effective international support and cooperation mechanism. This can be done through financial resources, technical assistance, and capacity-building projects to help developing countries overcome capacity constraints, enabling their seafarers and shipping systems to truly participate in and benefit from the green transformation. In the long run, implementing a just transition is not only essential for protecting seafarers’ rights and ensuring the healthy development of the industry, but also serves as the cornerstone for achieving global shipping emission reduction goals and promoting broader social and environmental justice.

Third, in the process of the global shipping industry’s green transformation, seafarers are facing an increasingly severe protection deficit, which is specifically reflected in three core aspects: operational burdens, safety hazards, and compliance risks. Firstly, the diverse combination of alternative fuel options significantly increases the operational burdens on seafarers. Since there is no perfect single clean fuel solution, the shipping industry has shifted to a flexible model dominated by dual-fuel vessels. This requires seafarers to simultaneously master knowledge of the storage, refueling, and emergency handling of both traditional fuels and various clean fuels, placing unprecedented demands on their comprehensive skill sets. To address this, it is recommended to adopt relatively stable fuel options for specific routes. This approach can significantly reduce the operational complexity and psychological pressure seafarers face due to frequent fuel type changes, providing them with a more predictable work environment. Secondly, the safety hazards associated with alternative fuels pose direct threats to seafarers’ physical and mental health. Fuels such as hydrogen, ammonia, and methanol carry specific risks related to flammability, explosiveness, and toxicity, which have raised widespread concerns among seafarers. Long-term exposure to such high-risk environments not only threatens their physical health but also exacerbates psychological pressure and insecurity due to the constant state of heightened vigilance. In response, we call for the establishment of a unified international training framework and practical training that focuses on the differentiated risks associated with various fuels. Additionally, through remote education, simulators, and international funding programs, we should prioritize addressing the lack of training resources for seafarers in developing countries, ensuring that global seafarers have equal access to opportunities for skill upgrading. Finally, the fragmentation of global emission reduction regulations has greatly exacerbated the compliance risks and legal liability uncertainties faced by seafarers. The varying and inconsistent carbon regulatory systems implemented by different jurisdictions, such as the EU, the UK, and Djibouti, force seafarers to navigate complex and overlapping compliance requirements. This not only imposes significant administrative burdens but also reshapes their professional risk structure, causing them to adopt a more conservative attitude toward new technologies due to concerns about personal criminal penalties, which could hinder the overall transformation of the industry. In response, it is crucial to strictly limit the scope of criminal liability for seafarers in pollution offenses, ensuring that subjective intent and significant consequences are indispensable elements in determining criminal liability. Additionally, we call for the promotion of a globally unified standard for seafarer criminal liability determination under the IMO framework, to prevent excessive accountability arising from differences in national laws, thereby safeguarding seafarers’ legal rights and their sense of professional security.

Indeed, this article has several limitations, but these limitations also highlight future research directions. First, this study primarily analyzes macro-level policy texts and industry reports. Future research could incorporate in-depth seafarer interviews or longitudinal surveys to obtain more individualized and dynamic micro-experience data, thereby revealing the real situations and demands of seafarers from different job positions, nationalities, and age groups in greater detail. Second, the regulatory pathways proposed in this article are mainly based on theoretical extrapolation and preliminary practices. The operational details and applicability in different types of vessels and trade models need to be examined through specific case studies, cost-benefit analysis, and simulation studies. For example, examining the excessive transition burden borne by seafarers on older vessels, as well as the role of shipowners in training investments and safety measures, along with cost-transfer mechanisms. Analyses of these specific dimensions are crucial for ensuring that the principle of a just transition is effectively implemented in practice. Third, this research focuses on individual seafarers. Future studies could expand the unit of analysis to the ship-shore collaborative model, exploring frontier legal and ethical issues, such as the division of responsibilities and liability determination between seafarers and shore-based operations centers, in the context of highly digitalized and remotely controlled future shipping scenarios.

In conclusion, whether the future shipping routes can truly be green depends not only on the clean energy stored in the fuel tanks but also on whether we build a system that fully protects seafarers’ rights and reasonably shares the costs of the transformation. The principle of just transition provides an indispensable ethical foundation and practical pathway to resolve these structural contradictions. Placing justice at the heart of the green transformation is an urgent institutional revolution, one that requires the leadership of international organizations, the responsibility of national governments, the foresight of industry capital, and the continuous critique and construction by academia. Only in this way can each green leap on the blue ocean routes be achieved without sacrificing the well-being of another group of people.

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Author contributions

JG: Writing – original draft, Writing – review & editing. JZ: Writing – review & editing, Writing – original draft.

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The author(s) declared that financial support was not received for this work and/or its publication.

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Supplementary material

The Supplementary Material for this article can be found online at: https://www.frontiersin.org/articles/10.3389/fmars.2026.1786595/full#supplementary-material

Footnotes

1.^Black-box nature refers to a system whose internal mechanisms are not visible or easily understandable to users or observers. Only the inputs and outputs can be observed, but the internal workings or processes remain opaque and unclear.

References

Summary

Keywords

alternative fuels, energy justice, green transition, just transition, seafarers’ rights

Citation

Gao J and Zhou J (2026) Seafarers in shipping’s decarbonization: role transformation, protection deficits, and just transition pathways. Front. Mar. Sci. 13:1786595. doi: 10.3389/fmars.2026.1786595

Received

13 January 2026

Revised

07 February 2026

Accepted

09 February 2026

Published

25 February 2026

Volume

13 - 2026

Edited by

Kang Chen, Dalian Maritime University, China

Reviewed by

Yen-Chiang Chang, Dalian Maritime University, China

Muneeb Khan, Dalian Maritime University, China

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Copyright

*Correspondence: Juntao Gao,

Disclaimer

All claims expressed in this article are solely those of the authors and do not necessarily represent those of their affiliated organizations, or those of the publisher, the editors and the reviewers. Any product that may be evaluated in this article or claim that may be made by its manufacturer is not guaranteed or endorsed by the publisher.

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