Key Ideas: Opportunity Green’s Strategies
Opportunity Green invokes four main strategies to reduce greenhouse gases from aviation and shipping:
- Increasing representation from climate-vulnerable countries at international regulatory bodies, such as the International Maritime Organization and the International Civil Aviation Organization, to promote more progressive policies.
- Advocating for ambitious policies and regulations in the EU. For example, policies to mitigate contrail emissions, strengthen the EU Emissions Trading System, and accelerate the commercialization of green hydrogen and hydrogen-based fuels.
- Identifying and pursuing strategic legal action to influence policy frameworks, financial institutions, and industry.
- Facilitating a private sector coalition (the SASHA Coalition) to promote renewable hydrogen-based and zero-carbon shipping and aviation technologies, such as e-fuels, and green hydrogen and battery-electric vehicles.
Opportunity Green’s Strategies
Increasing Representation of Climate-Vulnerable Countries at International Fora to Promote More Progressive Policies
The International Maritime Organization (IMO) is a U.N. agency that regulates shipping globally and is considered an effective and comprehensive vehicle for establishing ambitious emissions standards.1 The IMO has signaled ambitions to reach net-zero emissions by 2050 through its sector targets, but it has not enacted sufficient enabling policies to achieve this target.2 In October 2025, member states voted narrowly to delay the adoption decision for a year, amid strong opposition from several oil-producing states. The IMO is scheduled to resume the adoption session in December 2026, leaving the framework’s future uncertain.3
Opportunity Green believes that to align with international climate targets, the IMO needs to incorporate stronger regulations, standards, and commitments.4 Currently, Opportunity Green is working on negotiations for the IMO’s Net Zero Framework, on which members are due to vote in late 2026. This work includes building support for the framework and raising the climate impact of regulations through advocacy for strong fuel intensity standards, revenue generation mechanisms, and life-cycle accounting methodologies.5
Opportunity Green aims to influence the IMO to set more ambitious targets by helping climate-vulnerable countries gain more representation and participation in IMO activities. Opportunity Green is one of the few NGOs providing direct legal and policy support to climate-vulnerable countries at the IMO. It engages with countries that have (i) historically been absent from IMO convenings and (ii) are disproportionately affected by climate change, such as Small Island Developing States (SIDS).6 It has supported over 20 of these countries during IMO negotiations, resulting in several instances of countries taking stronger positions. For example, it supported Costa Rica to make its first plenary intervention in five years. Based on the 2025 setback, we think the framework’s outcomes are likely to be decided by a narrow margin, and smaller delegations' positions could meaningfully influence the final outcome.
Opportunity Green claims that because these countries feel climate change more acutely, despite accounting for very few emissions, they tend to support more progressive international policies; they especially favor policies that substantially reduce emissions from the Global North and generate climate finance for adaptation.7 It thinks that increasing the number of progressive voices could help move the moderate block. Opportunity Green also works with EU Member States to increase their support for policies supported by climate-vulnerable countries at the IMO, and facilitates research on the benefits of using revenues generated from shipping levies to support climate-vulnerable countries.
As part of this work, Opportunity Green has filed a submission to the International Tribunal for the Law of the Sea (ITLOS) in support of the Commission of Small Island States’ (COSIS’s) request for the Tribunal to clarify States’ obligation to protect the marine environment from pollution, asking it to recognize countries’ obligations to regulate shipping and aviation emissions in line with climate goals to limit the global temperature increase to 1.5°C.8 The Tribunal released an advisory opinion in May 2024 that was broadly in line with the submission made by Opportunity Green. Opportunity Green also made a similar submission to the International Court of Justice, which was also reflected in the Court’s opinion. Opportunity Green is now working with aviation and shipping policymakers to ensure they understand the full legal implications of this decision, such as by supporting some climate-vulnerable countries in their submissions to the IMO on this topic.9 For example, it drew from the International Court of Justice’s ruling in its submission to the IMO, linking it to the Net Zero Framework. The advisory opinions also open avenues for future climate litigation, such as challenges against national governments.
In addition to IMO representation, Opportunity Green is ramping up similar work to empower climate-vulnerable countries in the International Civil Aviation Organization (ICAO).
Facilitating a Private-Sector Coalition to Promote Low-Carbon Aviation and Shipping
Opportunity Green established the SASHA Coalition to unite companies across maritime shipping, aviation, and alternative fuel production to advocate for policies that facilitate the commercial-scale production of ships, aircraft, and fuels based on low-carbon battery-electric and renewable hydrogen energy. For example, this includes ships using e-ammonia or e-methanol, aircraft powered by e-sustainable aviation fuels (e-SAFs) or hydrogen, and battery-powered ships and aircraft.10 Policy goals include increasing the ambition level of e-fuel targets in EU climate regulations (the Fit for 55 package) and ensuring safeguards against reliance on biofuels and liquefied natural gas (LNG).11 To achieve these goals, Opportunity Green develops policy recommendations, builds shared priorities across the value chain, facilitates meetings between SASHA members and policymakers, and coordinates the drafting of public and private letters.
SASHA was established in 2023, focusing on U.K. and EU companies and policy. As of October 2026, the coalition has 27 members, including leading innovators such as ZeroAvia and Norsk e-Fuel. The Sustainable Shipping Initiative, Zero Emissions Ship Technology Association, PtX Lab Lausitz, and the Green Hydrogen Organisation have also joined as knowledge partners. In 2025, the SASHA Coalition co-hosted its first Parliamentary event, along with two members of the European Parliament (MEPs), also attended by the Commission’s aviation director.12 It co-hosted a booked-out roundtable with another MEP in 2026, focused on ending international flights’ exemption from the ETS, ahead of its revision.
Advocating for Ambitious EU Policy
In 2024, Opportunity Green opened its Brussels office to deepen its EU policy engagement, now with five team members. The EU is an important strategic region for aviation and shipping policies because its regulations are arguably the most ambitious in the world.13 Opportunity Green’s policy advocacy works alongside its other strategies, such as its legal challenge against the European Commission’s green investment taxonomy and hosting SASHA Coalition events at the European Parliament.
A major focus of Opportunity Green’s EU work has been the revision of the EU ETS for aviation. Opportunity Green published policy guidance and had several engagements with EU policymakers ahead of the July 2026 ETS revision, which includes the world’s first contrail mitigation policy framework and expands the ETS’s geographic scope beyond domestic flights to cover flights departing the European Economic Area (EEA) to destinations within 5,000 kilometers of Frankfurt, from 2029.14
Opportunity Green’s input on the review has been sought by the MEP in charge of the ETS review, which we see as an indicator of its growing recognition and credibility in the field. Opportunity Green has also discussed ETS revisions with the Commission departments for Climate and Transport.
The SASHA Coalition gave briefings on the competitiveness case for an expanded ETS, a joint letter with Carbon Market Watch urging the EU to include international flights, and a policy proposal on aviation’s non-CO2 effects shared with the Commission and MEPs.15 Opportunity Green reports that SASHA is the only form of industry supporting the extension of the ETS to international flights, and we think its industry representation carries additional weight beyond arguments just from NGOs.16 We have been impressed by Opportunity Green’s contributions to major EU policies, like the ETS, given that its presence in Brussels is still new. The proposal is scheduled to be finalized in the first quarter of 2027.17
Complementing this work, Opportunity Green is working to build a minilateral coalition of willing countries to reduce contrail emissions. We think this could usefully complement the ETS while ICAO remains slow to act on non-CO2 effects, though it is at an early stage.
Opportunity Green has also used its presence in Ireland to engage ahead of Ireland’s Presidency of the Council of the EU, which runs from July to December 2026 and coincides with negotiations on the ETS revision. The Presidency of the EU is also the first EU member state to speak in the IMO, making it important to ensure that Ireland’s position remains ambitious. Opportunity Green claims to be the first nonprofit in Ireland working to reduce aviation emissions, and we think it is well-positioned to contribute to discussions on the ETS revision as negotiations continue.
Identifying and Pursuing Strategic Legal Action
Opportunity Green sees litigation and non-judicial legal action and legal advocacy as complements to policy advocacy, especially for sectors where policy efforts have lagged. It claims that climate litigation, legal action, and advocacy have historically focused on governments and that increasing legal pressure on corporations is important. Opportunity Green has defined the scope of its legal strategy as “cases that seek broader systemic outcomes and social impacts, in contrast to traditional litigation that prioritises the immediate aims of an individual claim.”
Opportunity Green identified aviation, shipping, steel, agriculture, and finance as key sectors for strategic climate legal action. As an example, it identified aviation as a key sector for the following reasons:
- The International Civil Aviation Organization (ICAO), the entity tasked with governing aviation internationally, is not considered an effective lever for standards setting or implementation.18
- Without strong global policies, countries are less likely to take action independently, given the sector's inherently international nature.
- A legal victory against one major multinational corporation in the private sector could significantly impact the entire industry.
- Aviation’s direct client-facing nature makes reputational damage a powerful lever to influence industry behavior change.
In 2024, Opportunity Green and four other NGOs launched a legal case against the EU Taxonomy rules for aviation and shipping.19 The Taxonomy rules, as currently drafted, would give a ‘green’ label to ships and planes that run on fossil fuels, raising concerns over greenwashing. Opportunity Green achieved partial victory, with the European Court of Justice ruling in September 2026 that the European Commission had acted unlawfully by not setting a quantifiable limit on methane leakage from liquefied natural gas (LNG)-powered ships that qualify as sustainable investments.20 However, the court rejected the case’s other arguments, leaving the aviation criteria and most of the shipping criteria in place.21 Opportunity Green reports that this is the first time NGOs have won on any point in a challenge of this kind against the Commission, and that the decision sets a positive precedent for additional legal challenges on other LNG and gas uses beyond shipping, as well as for other taxonomies beyond the EU.
Opportunity Green has also undertaken legal work in the maritime shipping sector and has conducted a similar scoping exercise to identify potentially impactful legal actions. In 2023, it compiled a report highlighting the cruise industry’s misleading claims about the climate benefits of LNG and filed complaints with the U.K.’s Advertising Standards Authority (ASA).22 The overall purpose was to delegitimize investment in LNG as a ‘transitional’ fuel in the shipping industry. As a result, the ASA ruled that advertising LNG as “eco-friendly” constitutes greenwashing and required MSC Cruises to recall its adverts. More recently, it has begun working to highlight the human rights impacts of pollution in ports caused by shipping emissions.
Emerging Areas for Opportunity Green
In 2025, Opportunity Green expanded its work to steel by filing a complaint under the Organisation for Economic Co-operation and Development (OECD) Guidelines for Multinational Enterprises, arguing that ArcelorMittal, Europe’s largest steel producer, lacks a robust, science-based climate strategy. Opportunity Green is also developing workstreams in agriculture and data centers.
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1“The global scope of the IMO presents a unique opportunity to develop consistent, comprehensive global policy solutions for decarbonization.” Global Maritime Forum, 2022
2Taken in combination with the revision of IMO’s short-term measures (carbon intensity indicators), which have been extended with new increases in stringency to 2030, the new policy is only expected to achieve approximately 10% absolute GHG emission reductions relative to 2008 GHG emissions. This is significantly lower than the ‘at least 20%’, ‘striving for 30%’ that the IMO committed to in the Revised GHG Strategy in 2023.” Smith et al., 2025
3“The Committee will resume its Second Extraordinary Session on Friday 4 December 2026” IMO, 2026; “a majority of 57 member states voted to adjourn the meeting for one year” DNV, 2025; “a forceful submission from the United States in opposition to the NZF” Blank Rome, 2026
4“The IMO’s strategy isn’t currently binding, and it lacks specific measures to achieve its stated targets. Nevertheless, it represents significant progress from previous positions. However, the absence of alignment with the 1.5° C target is a major shortfall.” ClimateWorks, 2023
5Section: Key areas for further ambition Opportunity Green, 2025
6“Opportunity Green has particular expertise in shipping policy at the international level. It specifically works with climate vulnerable countries, who are traditionally under-resourced and underrepresented at the International Maritime Organization (“IMO”), providing them with briefing notes, facilitating information sharing and networking events and hosting bilateral meetings as required to help in the preparation of countries’ positions.” Opportunity Green, 2023
7“This raises intriguing questions about how these divergent approaches will unfold. Fuel standard measures and pollution levies are of high interest to many countries because they can generate climate finance for adaptation and mitigation in countries most impacted by climate change. However, those countries aren’t necessarily in the room to help make those decisions.” ClimateWorks, 2023
8The International Tribunal for the Law of the Sea (ITLOS) is an independent judicial body established by the 1982 United Nations Convention on the Law of the Sea. The Commission of Small Island States on Climate Change and International Law (COSIS) is a UN commission with a mandate to “to promote and contribute to the definition, implementation, and progressive development of rules and principles of international law concerning climate change, including, but not limited to, the obligations of States relating to the protection and preservation of the marine environment and their responsibility for injuries arising from internationally wrongful acts in respect of the breach of such obligations.”
9See Publication: ITLOS advisory opinion — Opportunity Green for Opportunity Green’s briefing on this topic.
10We use e-SAFs to refer to sustainable aviation fuels (SAFs) that are produced using green hydrogen and sustainable CO2.
11The Fit for 55 package is an EU-level policy which aims to reduce the EU’s emissions by 55% by 2030; it contains the FuelEU maritime shipping and aviation initiatives targeted toward increasing the use of sustainable fuels.
12“Despite being very new in Brussels, we were able to secure the sponsorship of two leading Members of the European Parliament (MEPs Oetjen and Gerbrandy), and the attendance of the European Commission’s Aviation Director at the Directorate General for Transport and Tourism” Opportunity Green, 2026
13Example regulations include the EU’s emissions trading scheme, ReFuelEU aviation mandate, and FuelEU Maritime initiative
14“the EU’s fair share of certain extra-European departing flights” and “The use of contrail forecasting models to support cost-effective mitigation of contrails” European Commission, 2026, explanatory memorandum and recital 13; on the 5,000 km radius from Frankfurt, see Clyde & Co, 2026
15“OG teamed up with Carbon Market Watch to send a letter urging the EU to include international flights in its Emissions Trading System (ETS). ” Opportunity Green, 2026
16“It’s the only industry body that is supporting the critical expansion of the EU’s flagship climate policy: the Emissions Trading System (ETS) to international flights.” Opportunity Green, 2026
17“setting Q1 2027 as target for agreeing on the review of the EU ETS” European Commission, 2026
18“In the past few years ICAO has faced criticism and been seen rightly or wrongly as an outlier even in the UN system for its lack of transparency in decision-making, its lack of access to information by the media, undue influence of industry (“captured by producer interests”: The Economist), restricted involvement of civil society and independent scientists, and its political interference in the culture and workings of the Secretariat.” Centre for Aviation, 2021
19“Five NGOs – Fossielvrij, Protect our Winters, Dryade, CLAW and Opportunity Green – have launched a legal challenge against the European Commission, requesting it to review its green investment rules on aviation and shipping. This is the first step in the challenge which may lead to court action before the European Court of Justice if the Commission does not address the legal issues raised.” Opportunity Green, 2024
20“The European Union’s General Court has partially annulled the European Commission’s decision concerning the Taxonomy criteria for shipping, finding that the Commission had failed to properly address methane-slippage emissions from ships.” Safety 4 Sea, 2026
21“While the court partially annulled the Commission’s decision concerning shipping, it did not reject the aviation criteria challenged by the NGOs.” Safety 4 Sea, 2026
22“As a result of the findings in the report, Opportunity Green has also filed a series of complaints to the UK’s Advertising Standards Authority (ASA) against some of the biggest international cruise companies to try to put an end to this apparent LNG greenwashing, which is potentially misleading consumers.” Opportunity Green, 2023
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