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Rethinking the London Convention and Protocol Governance of mCDR in Light of New International Rulings and Landmark International Climate Agreements

Washington, D.C., August 12, 2025 – Ocean Visions, a science-based nonprofit working to accelerate ocean-based climate solutions, is proud to have provided the financial support for the development of a new white paper by the Sabin Center for Climate Change Law at Columbia University. The paper, International Legal Guidelines for Marine Carbon Dioxide Removal Governance under the London Convention and London Protocol, offers timely and fresh thinking on how parties currently apply, and how they could more effectively apply, relevant international legal principles and guidelines — precaution, prevention, due diligence, and environmental impact assessments — to the emerging arena of marine carbon dioxide removal (mCDR). 

Climate change is an existential threat to civilization and the greatest threat to ocean health. Driven in large part by excess carbon dioxide, the advancing crisis has fueled a growing international urgency to explore all potential carbon dioxide removal pathways, side by side with deep emissions reductions. The ocean is particularly vulnerable to acidification and warming driven by excess carbon. And as the planet’s largest carbon sink, the ocean also holds significant potential to help clean up carbon pollution. To fully determine what that potential is requires accelerated mCDR research and development, guided by robust legal frameworks and environmental safeguards. 

The London Convention and Protocol (LC/LP) was created to prevent pollution of the sea by regulating dumping of wastes and other matter. MCDR came onto the LC/LP agenda in response to early experiments with a singular mCDR pathway, ocean iron fertilization, which was addressed as pollution rather than a potential climate mitigation technique. For nearly two decades, LC/LP parties have worked to develop rules addressing further development of this mCDR approach. And in the past few years, the parties have expanded their purview to include other mCDR pathways, such as ocean alkalinity enhancement and the sinking of biomass at sea, as well as marine cloud brightening, which is not an mCDR pathway, but rather a technique to potentially increase reflectivity of clouds to reduce global heating.   

The Sabin Center paper draws on recent jurisprudence from the International Court of Justice (ICJ) and International Tribunal for the Law of the Sea (ITLOS) to recommend that the LC/LP adopt a more integrated, climate-conscious approach that is aligned with the goals of the United Nations Framework Convention on Climate Change (UNFCCC), Paris Agreement, and the United Nations Convention on the Law of the Sea (UNCLOS). 

We hope that the white paper will serve as a valuable resource to inform both immediate and longer-term actions under the LC/LP, offering a strong foundation of international law and principle that if incorporated into LC/LP frameworks could lead to: 

  • Advancing mCDR research and development at scale in the face of scientific uncertainty 
  • Weighing the potential climate benefits of mCDR alongside environmental risks in a balanced and transparent manner 
  • Ensuring governance of mCDR research, development, and demonstration is science-based and aligned with all relevant international agreements to limit climate change 
  • Designing impact assessments that consider both local ecosystems and global climate objectives 

“Ocean-based climate solutions have to be on the table in the race to reverse the escalating threats of climate change and its impacts on the ocean,” says Brad Ack, CEO of Ocean Visions. “This succinct paper provides compelling legal foundations for rethinking how potential climate mitigation efforts in the ocean are assessed, based on internationally accepted definitions of precaution, due diligence, and appropriate consideration of both ecosystem risks and the accelerating urgency of climate change.” 

As the climate crisis deepens and risks to society continue to grow, courts at all levels are increasingly affirming governments obligations to act on climate change. This paper offers timely insights for States navigating their responsibilities under multiple international agreements—including conventions that were not created to focus on climate challenges, like the LC/LP. 

Part of the global climate agenda must involve expeditiously facilitating research into emerging solutions like mCDR that might be part of the carbon removal need for any path to net zero, and beyond.   

“Sabin Center’s white paper outlines a path to apply cutting-edge legal rulings and principles into real-world regulation of mCDR,” says Ack. “We agree with the paper’s recommendation that parties to the London Convention and Protocol are obligated to take a broader view of these potential solutions, and not simply consider them as “dumping.” By reframing how we look at potential actions as mitigation rather than dumping, as potential solutions rather than only risks, we can better advance development of responsible, scalable ocean-based climate solutions.” 

Ocean Visions is committed to supporting science-based innovation—and the legal frameworks needed to govern it—to ensure that potential ocean-based climate solutions are both effective and responsible. 

 

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About Ocean Visions 

Ocean Visions was created to develop and advance solutions to protect and restore the ocean. We focus on the biggest driver of dangerous change – the climate disruption that is increasing ocean temperatures and levels of acidification. We mobilize a diverse network of collaborators and leverage cutting-edge science and innovative technologies to build ocean-based solutions that reduce climate stressors and restore ocean ecosystems. In short, we work to stabilize the climate and regenerate ocean health.