EU ETS + FuelEU Maritime
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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.
EU ETS — the emissions surrender regime
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.
Practical surrender-quota calculation
For a vessel emitting X tonnes of CO₂-equivalent under scope in year Y:
where phase-in = 40% (2024), 70% (2025), 100% (2026+)
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.
FuelEU Maritime — WtW GHG intensity
Regulation (EU) 2023/1805 imposes a well-to-wake (WtW) GHG-intensity limit on energy used onboard, decreasing progressively from 2025:
- 2025: 2% reduction vs. 2020 reference (91.16 g CO₂eq/MJ)
- 2030: 6% reduction
- 2035: 14.5% reduction
- 2040: 31% reduction
- 2045: 62% reduction
- 2050: 80% reduction (net-zero-adjacent)
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.
Interaction with IMO GHG regime
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.
FAQ
Who is responsible for surrendering EU ETS allowances — the ship or the charterer?
The legal obligation sits with the registered shipping company (the ISM Manager named on the Document of Compliance), not the charterer or the bunker supplier. In practice the cost is passed through to the time-charterer under charter-party clauses such as the BIMCO Emission Trading Scheme Allowances (ETSA) clause, but the company remains the entity that must surrender the allowances.
Which ships and which voyages does EU ETS cover?
All ships above 5,000 GT calling at EU ports, regardless of flag. Emissions are counted on a scope basis: 100% of the emissions of intra-EU voyages and voyages at berth, plus 50% of the emissions of voyages arriving from or departing to a non-EU port. The surrender obligation phases in at 40% of covered emissions for 2024, 70% for 2025 and 100% from 2026, with CH₄ and N₂O added from 2026.
What is the FuelEU Maritime penalty for non-compliance?
A penalty of €2,400 per tonne of VLSFO-energy-equivalent of the compliance deficit (the amount by which the ship's well-to-wake GHG intensity exceeds the limit). Compliance is pooled at company level, so an under-emitting ship can generate a surplus that offsets an over-emitting ship in the same pool.