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The European Union's two-instrument maritime GHG regime — the EU Emissions Trading System (EU ETS) covering CO₂ + CH₄ + N₂O, and the FuelEU Maritime Regulation covering well-to-wake (WtW) GHG intensity of fuel used — has reshaped bunker cost + charter-party economics for every vessel calling an EU port since 2024. Both instruments apply to all vessels >5,000 GT calling EU ports, regardless of flag. This page covers what a chief officer + master need to know for daily voyage planning + charterer discussions.
Under Directive (EU) 2023/959, maritime activities enter the ETS from 1 January 2024 with progressive phase-in: 40% of emissions surrendered in 2024,70% in 2025, 100% from 2026. Voyages count on a scope basis: 100% of intra-EU voyage emissions + 50% of extra-EU voyage emissions (departing from or arriving at an EU port). CH₄ + N₂O added from 2026.
Who surrenders: The registered shipping company (ISM Manager) responsible for the vessel — the same entity named on the Document of Compliance. Bunker suppliers do not participate; costs pass through the ISM Manager who typically invoices back to charterer under BIMCO ETSA clause frameworks.
Verification: Vessel-level emissions reported annually via THETIS-MRV (existing THETIS platform extended) — the same emissions data already reported since 2018 under the EU MRV Regulation.
For a vessel emitting X tonnes of CO₂-equivalent under scope in year Y:
One EU Allowance (EUA) = 1 tonne CO₂-equivalent. At €80/tonne indicative pricing (2024 mid-range), a 100,000 tCO₂/year vessel faces annual ETS exposure of €3.2M (2024, 40%) → €8.0M (2026, 100%). Charter-party ETS clauses (BIMCO ETSA 2023) typically pass this cost to the time-charterer.
Regulation (EU) 2023/1805 imposes a well-to-wake (WtW) GHG-intensity limit on energy used onboard, decreasing progressively from 2025:
Non-compliance triggers a penalty of €2,400/tonne VLSFO-equivalentof over-consumption. The reduction targets are calculated on a per-company pool basis — under-emitting vessels create surplus that offsets over-emitters in the same fleet. Zero-emission berth energy (shore power / cold ironing) required from 2030 for passenger + container vessels calling EU ports >2000 passenger or 90kts.
MEPC 83 (April 2025) adopted the IMO Global Fuel Standard + economic measure (bunker levy) entering force in 2027 — see MARPOL Annex VI. EU has stated that it will review the EU ETS + FuelEU regime once the IMO instruments are operative, to avoid double-charging. Until at least 2028, EU-trading tonnage faces both regimes concurrently.