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                                    tanker does not pick up cargo in one regulatory universe and delivers it in another %u2014 it operates across jurisdictions continuously, and it needs a single, coherent set of rules to operate against. When you have FuelEU Maritime and the EU ETS sitting alongside each other, potentially diverging from whatever framework eventually emerges from the IMO, you create an unpredictable environment with a heavy administrative burden and a confused overall signal to the market.That said, I want to be careful here. We are not dismissing the EU%u2019s ambitions; it would be great to see some of the funds generated funnelled back into maritime decarbonisation, and we are actively engaging with the European Commission. But our strong preference %u2014 and our advocacy at every leve %u2014 is for the IMO to deliver a global framework, avoiding regulatory fragmentation and enabling long-term investment in decarbonisation solutions. Regional measures are, independent of the region, at best a fallback and at worst a competitive distortion.How do you assess the implementation of SIRE 2.0 so far? Do you believe it is achieving its objective of enhancing safety and transparency without creating disproportionate operational or administrative burdens for compliant tanker operators?From an industry perspective, the implementation of SIRE 2.0 represents a significant, largely positive step toward strengthening the tanker sector%u2019s overall safety and transparency framework. The shift to a more risk-based, behaviour-focused, and evidence-driven inspection model marks a substantial evolution in how operational performance is evaluated. Based on the evidence available to us, the early outcomes indicate that the programme is broadly achieving its objectives of enhancing safety and transparency. At the same time, the additional operational demands, particularly during the transition period, have not created a disproportionate burden for compliant operators.One of the most important advancements is SIRE 2.0%u2019s departure from the limitations of the VIQ 7 regime. VIQ 7 focused heavily on hardware and documentation, without adequately assessing how procedures were applied in practice or why errors occurred. SIRE 2.0 closes this gap by embedding Human Factors into the inspection process, examining behaviours, situational awareness, communication, workload, and safety culture. This results in a more holistic assessment that captures the interaction between people, processes, and equipment, rather than treating compliance as a checklist exercise.We track SIRE 2.0 performance closely through our benchmarking tool, and the data shows that our members are engaging with the system seriously and consistently improving their performance against it. The average number of negative observations per inspection is declining. In contrast, the number of positive observations %u2014 an important addition under SIRE 2.0 and one that was not meaningfully captured by its predecessor %u2014 is rising. This matters because a system that only records deficiencies provides an incomplete picture of operational performance.In 2025, 108 member companies uploaded more than 7,200 reports covering over 3,000 ships. The average number of negative observations per inspection decreased from 6.33 at launch in late 2024 to 5.24 across 2025. At the same time, positive observations increased, offering a more balanced and accurate view of onboard performance. This is particularly significant, as a system focused solely on deficiencies cannot reflect operational reality.Performance on core questions, especially those linked to the most significant onboard risks, has been particularly encouraging, with negative observations decreasing by approximately 35%u201340% over the year. That represents a meaningful improvement in a relatively brief period and suggests that operators are not only engaging with the system but improving against it.In terms of safety enhancement, the integration of Human Factors and the use of structured, real-time documentation have created a more comprehensive and accurate picture of a vessel%u2019s operational readiness and onboard safety culture. This has improved both the depth Representation of tanker shipowners50 NX
                                
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