Introduction
As the Arctic warms and snow and sea ice melts, hitherto inaccessible parts of the Arctic Ocean are opening up, with important implications for the shipping sector generally and the cruise ship industry specifically. Thus far, international regulation has failed to keep pace with the environmental impacts of increasing cruise ship activity, in particular black carbon (BC) emissions and underwater radiated noise (URN). The absence of binding international regulation on BC and URN reflects a widening regulatory gap at precisely the moment when legal intervention is most needed to mitigate escalating and potentially irreversible environmental impacts.
Cruise vessels have operated in Arctic waters for decades, but their numbers have increased sharply in recent years: seventy-seven unique cruise vessels operated within the Polar CodeFootnote 1 area in 2013, compared with roughly five hundred in 2023, with further growth anticipated as sea-ice decline continues.Footnote 2 The most frequently visited cruise routes are concentrated around Iceland and Norway,Footnote 3 while substantial cruise tourism activity also occurs in the coastal waters of Greenland and Canada.
The increase in cruise ship activity is being driven by both climatic and socioeconomic forces. The opening of the Arctic makes routes physically possible, but demand is also fueled by what scholars describe as “last chance tourism,” a trend in which visitors are motivated to experience environments they believe are at risk of disappearing.Footnote 4 The melting of sea ice facilitates such visitation geographically and symbolically.Footnote 5 Proponents describe Arctic cruises as encounters with a pristine landscape, emphasizing local revenue and community development.Footnote 6
However, the growth in the Arctic cruise industry carries mounting risks, including environmental stress on fragile ecosystemsFootnote 7 and increasing burdens for small and remote communities already navigating rapid climate-induced change.Footnote 8 Among the environmental harms associated with cruise traffic, BC emissions and URN are particularly acute. BC accelerates regional warming by darkening snow and ice surfaces, reducing albedo (a measure of how much sunlight (solar radiation) a surface reflects back into space rather than absorbing), and accelerating melt, while URN disrupts marine mammals that rely on sound for migration and communication.Footnote 9 These effects are especially pronounced in pristine, highly sensitive polar ecosystems.
Significantly, both BC and URN are pollutants for which reductions would yield rapid and measurable environmental benefits, making them comparatively “low-hanging fruit” for regulation.Footnote 10 Despite this, regulation remains markedly underdeveloped. Currently, the regulatory landscape is fragmented.Footnote 11 Progress at the international level has been incremental and largely non-binding,Footnote 12 while regional institutions like the Arctic Council lack authority to impose binding environmental obligations. This has resulted in a tendency toward industry self-regulation through operator-led associations,Footnote 13 raising questions of legitimacy, accountability, and effectiveness. In this sense, the challenge is not merely the increase in Arctic cruise traffic, but the persistent misalignment between accelerating environmental impacts and the slow regulatory pace.
Drivers of Arctic Cruise Growth
The sharp increase in cruise activity in the Arctic is rooted in physical changes to the region’s geography and navigability. Rising temperatures have led to a rapid decline in both the extent and thickness of sea ice, opening passages for longer portions of the year and enabling vessels to enter areas that were previously inaccessible. These changes are not merely expanding possible routes; they are transforming the risk calculus for operators, lowering insurance and navigation costs, and making itineraries more predictable.
Yet navigability alone does not explain the surge in the Arctic cruise industry. The accessibility created by warming has intersected with powerful tourism-market dynamics, especially the rise of “last chance tourism,” in which travelers seek to visit sites perceived as fragile or vanishing.Footnote 14 Scholars note that the Arctic, like Antarctica before it, has become a “destination,” marketed explicitly through the specter of climatic vulnerability.Footnote 15 The promise of witnessing a pristine and changing ecosystem, combined with the symbolic appeal of “remote” or “untouched” spaces, has proven commercially potent, driving demand for itineraries deeper into sensitive polar waters.
At the same time, the political economy of Arctic tourism has reinforced this growth trajectory. Arctic cruise tourism is seen by some local communities as a vehicle for revenue generation, economic diversification, and international visibility.Footnote 16 For small settlements with limited economic alternatives, port calls can represent an important income stream. But these gains are unequally distributed, and many of the costs—including environmental disturbance, pressure on infrastructure, and cultural disruption—are borne locally by communities least equipped to manage them.Footnote 17
Thus, the expansion of Arctic cruise tourism is shaped by a dual dynamic: climate change creates the material conditions of possibility, while economic and experiential incentives generate sustained market demand. This combination has produced a pace of growth that outstrips the regulatory system’s ability to keep up with the associated environmental risks.
Black Carbon Emissions and Underwater Radiated Noise
The environmental impacts of Arctic cruising are manifold, including wastewater discharge, solid waste, fuel spills, and air pollutants other than BC.Footnote 18 This essay focuses on BC and URN for two reasons: first, because of the international nature of the regulatory processes dealing with these environmental problems; and second, because reductions in these pollutants would yield immediate and measurable environmental benefits, both locally (by protecting sensitive ecosystems) and globally (through climate feedback mechanisms).Footnote 19
BC consists of fine particulate matter emitted primarily from the combustion of heavy fuel oil and diesel. When deposited on ice and snow, BC darkens the surface, reduces albedo, and accelerates melting, creating a feedback loop that intensifies regional warming. URN, produced by propellers, engines, and auxiliary machinery, interferes with marine mammals’ ability to communicate, navigate, and detect predators or prey—impacts that are amplified in polar waters where species such as narwhals, bowhead whales, and seals rely heavily on acoustic signals.
While all Arctic shipping contributes to these impacts, cruise vessels exert a disproportionate effect for several reasons. First, they often operate in ecologically sensitive and spatially complex areas, including fjords, ice margins, and coastal waters, rather than merely transiting established shipping lanes. Second, unlike cargo or tanker vessels, cruise ships frequently travel slowly or remain stationary for sightseeing and wildlife observation, increasing BC emissions per unit distance and maintaining a near-continuous acoustic footprint. Third, cruise itineraries often involve repeated visits to the same locations within a season, magnifying cumulative stress on fragile ecosystems. For example, repeated URN exposure in fjords and coastal areas can disrupt marine mammal migration and feeding patterns in ways transient shipping traffic does not. The combination of deep-ice access, low-speed operation, and repeated visitation make cruise ships uniquely significant actors in the Arctic.
Regulating BC and URN from Arctic Cruises
In regulating BC emissions and URN from Arctic cruise ships, the International Maritime Organization (IMO) is the central actor. Its regulatory framework governs international shipping activities, including cruise vessels operating in Arctic waters. Key instruments include the International Convention for the Prevention of Pollution from Ships (MARPOL) and the Polar Code.
MARPOL Annex VI, which addresses air pollution from ships, could be used to regulate BC emissions. However, despite growing recognition of BC’s disproportionate impact in the Arctic, IMO has yet to adopt binding measures specifically targeting BC emissions reduction. Current IMO BC efforts remain limited to emission measurement and reporting,Footnote 20 and voluntary guidance on the use of cleaner fuels under the 2021 IMO Resolution MEPC.342(77), which encourages the reduction of BC emissions.Footnote 21 Discussions continue within the Marine Environment Protection Committee (MEPC) and its Sub-Committee on Pollution Prevention and Response (PPR) on possible amendments to MARPOL Annex VI that could introduce mandatory control measures.Footnote 22
In the case of URN, regulatory efforts are even less advanced. While IMO has recognized underwater noise as a significant stressor for marine life, there are no binding international standards in place. In 2014, IMO adopted the Guidelines for the Reduction of Underwater Noise from Commercial Shipping to Address Adverse Impacts on Marine Life, which are voluntary and primarily recommend design, maintenance, and operational practices to minimize noise.Footnote 23 Recently, IMO has revised and strengthened these guidelines;Footnote 24 however, they remain hortatory in nature and are thus non-binding. An IMO working group explicitly recognized this limitation, concluding that the voluntary character of the guidelines, rather than their technical feasibility, was a key barrier to their broader uptake.Footnote 25
While the adoption of the Polar Code was an important step in establishing safety and environmental requirements tailored to polar shipping conditions, it does not address BC or URN, nor does it specifically focus on cruise ships. This gap exposes a structural weakness in the existing regulatory regime: although IMO’s framework applies to Arctic cruise ships, its instruments are not yet adapted to the unique environmental impacts of Arctic cruise ship tourism.
Beyond IMO, regional, domestic, and industry-driven initiatives have attempted to fill some of these regulatory gaps. At the regional level, the Arctic Council, through its working and expert groups, has advanced several measures, including the Framework for Action on Black Carbon and MethaneFootnote 26 and Arctic URN management strategies.Footnote 27 However, the Arctic Council is not able to adopt binding rules and its influence remains limited.
In terms of domestic regulation, a harmonized approach to regulating cruise ship tourism is largely absent, meaning that the Arctic countries all have different approaches, which reflect their national priorities and governance structures. Norway, for example, combines its National Tourism Strategy 2030 with bans on heavy fuel oil (HFO) around SvalbardFootnote 28 and zero-emission requirements for cruise ships in UNESCO-listed fjords from 2026, explicitly linking cruise tourism to climate mitigation.Footnote 29 Iceland addresses cruise ship emissions through its National Climate Action Plan, which targets carbon neutrality by 2040 and indirectly phases out HFO via strict sulfur limits on marine fuels, complemented by cruise passenger taxes aimed at supporting sustainability.Footnote 30 Denmark’s Arctic cruise governance is primarily exercised by Greenland, which exercises self-government over environmental matters yet lacks a dedicated national climate strategy and instead aims to promote (sustainable) cruise tourism growth for economic development.Footnote 31
In parallel, industry self-regulation, particularly through the Association of Arctic Expedition Cruise Operators (AECO), has emerged as a complementary mechanism. AECO develops and implements voluntary operational standards and environmental guidelines for its members, covering issues such as fuel use, waste management, and wildlife disturbance.Footnote 32 While these initiatives demonstrate industry awareness and a willingness to act, they raise legitimacy and accountability concerns, as the standards are defined by industry actors rather than public authorities, and compliance depends on reputational incentives rather than formal oversight. Moreover, their voluntary nature underscores the broader regulatory gap: the absence of mandatory, enforceable standards specifically tailored to the environmental realities of Arctic cruise ship tourism.
Conclusion
The warming Arctic is creating a widening gap between the pace of environmental change and the pace of regulation. Cruise tourism is a case in point. It is growing rapidly, as a result of retreating sea ice (which has opened up places previously difficult or impossible to access), growing demand for “last chance tourism,” and local hopes for income and development. This growth is impacting fragile ecosystems with limited capacity to absorb the mounting pressure. But the regulatory response has been very limited.
In the Arctic, BC and URN are two particularly acute stressors closely tied to typical cruise operations. BC has an immediate climate impact because deposition on snow and ice accelerates melting by reducing their albedo. URN matters because many Arctic marine mammals depend on sound for basic life functions; persistent noise in confined waters can disrupt behavior in ways that are hard to reverse.
The IMO has acknowledged both issues, but progress has been slow and largely non-binding. The Polar Code and MARPOL provide an overall legal framework, but fall short. Domestic laws in Arctic states have not substantially gone beyond international regulation and remain fragmented across jurisdictions. Regional initiatives and industry standards (including AECO) remain voluntary and are unable to deliver meaningful outcomes. Even if the international community cannot stop Arctic warming, it needs to do more to limit the impacts on the Arctic’s fragile and unique ecosystem.
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