EU ETS & FuelEU Maritime
Supporting EU ETS & FuelEU Maritime Compliance
We help shipowners and operators navigate Europe’s evolving maritime decarbonization regulations through practical fuel solutions, emissions support, and compliance-ready delivery.
EU ETS and the Maritime Industry
The EU Emissions Trading System (EU ETS) is the EU’s carbon pricing mechanism. It requires companies to measure, report, and verify CO₂ emissions, and surrender carbon allowances (EUAs) corresponding to those emissions.
01
One EUA = 1 tonne of CO₂
02
Emit more → purchase additional allowances
03
Emit less → lower carbon costs
From 2024, the EU ETS extends to the maritime sector, meaning ship operators must account for emissions in EU waters.
Which Voyages Are Currently
in Scope?
Voyage Coverage
Phased Implementation of EUAs
| Year / Period | Scope | Ship Size & Type | Greenhouse Gases Covered | ETS Coverage |
|---|---|---|---|---|
| 2023 | Reporting only (MRV) | Cargo & passenger ships >5,000 GT; Offshore ships >5,000 GT | CO₂ | No allowance surrender |
| 2024 | Included in EU ETS | Cargo & passenger ships >5,000 GT; Offshore ships >5,000 GT | CO₂ | 40% of emissions |
| 2025 | Expanded compliance | Cargo & passenger ships >5,000 GT; Offshore ships >5,000 GT | CO₂ | 70% of emissions |
| 2026 onwards | Full ETS coverage | Cargo & passenger ships >5,000 GT; Offshore & general cargo ships 400–5,000 GT | CO₂, CH₄, N₂O | 100% of emissions |
| 2027 onwards | Ongoing | Same as above | CO₂, CH₄, N₂O | 100% of emissions |
Exempt Port Calls
Certain operations are not counted towards EUA obligations:
- Refuelling or bunkering
- Obtaining supplies
- Crew changes (except offshore vessels)
- Dry-docking or repairs
- Assistance or distress
- Ship-to-ship transfers outside ports
- Sheltering from bad weather or search & rescue
Responsibility for EUAs
- The Document of Compliance (DoC) holder (owner or technical manager) is legally responsible for surrendering EUAs.
- Liability cannot be avoided based on flag, country of incorporation, manager, or charterer.
Exception
- Liability may be contractually transferred to a commercial charterer.
- Fuel suppliers are never directly liable unless they hold the vessel’s DoC.
How EUAs Are Calculated
Each fuel type has a CO₂ emission factor:
From 2026 onwards, EU ETS also includes CH₄ (methane) and N₂O (nitrous oxide), converted into CO₂-equivalent (tCO₂e) using Global Warming Potentials (GWP). CO₂ is the main contributor, while CH₄ and N₂O add a small additional amount.
| Fuel Type | CO₂ (t/t) |
|---|---|
| HFO | 3.114 |
| LFO | 3.151 |
| MGO | 3.206 |
01
02
03
Total CO₂-equivalent: 311.4 + 0.125 + 0.298 ≈ 311.823 tCO₂e
Apply voyage coverage (50% for EU <-> Non-EU): 311.823 × 50% ≈ 155.91 EUAs required
One EUA is surrendered per 1 tCO₂e, ensuring compliance with EU ETS obligations ¹.
¹ EU ETS requirements may change. Information accurate as at the date of publication.
- Shipping companies Must have a Union Registry Account (Trading or Maritime Operator Holding Account)
- Register with country of incorporation
- Report emissions: by 31 March for previous calendar year
- Purchase & surrender EUAs: by 30 September for previous calendar year
- Register with EU Member State where most port calls occurred (last four years)
- Must appoint an Authorized EU Representative (subsidiary, fiscal agent, or partner)
- Without this, registry accounts cannot be opened, and Uni-Fuels cannot transfer allowances
- NEa (Netherlands), DEHSt (Germany)
FuelEU Maritime:
Reducing Greenhouse Gas Intensity at Sea
FuelEU Maritime is an EU regulation designed to reduce the greenhouse gas (GHG) intensity of marine fuels from well-to-wake. While the EU ETS targets emissions through a carbon price, FuelEU Maritime requires ships to gradually reduce the carbon intensity of the fuels they use, promoting cleaner and more sustainable marine fuels.
How FuelEU Maritime Works
- Carbon Intensity Targets: Ships must meet GHG intensity limits for the fuels used on voyages to, from, or between EU ports.
- Gradual Reduction: Targets increase over time, encouraging transition from conventional fuels to alternative fuels such as biofuels, LNG, and methanol.
- Verification and Reporting: Ships must monitor, report, and verify fuel consumption and emissions intensity.
Key Differences from EU ETS:
| Feature | EU ETS | FuelEU Maritime |
|---|---|---|
| Focus | Total emissions (tCO₂) | Fuel GHG intensity (gCO₂e/MJ) |
| Compliance | Purchase & surrender EUAs | Meet carbon intensity limits; penalties for non-compliance |
| Covered Gases | CO₂, CH₄, N₂O | CO₂, CH₄, N₂O (lifecycle fuel intensity) |
| Incentive | Market-based carbon cost | Direct operational requirement to use lower-carbon fuels |
GHG Intensity Reduction Targets
- 2025
- 2030
- 2035
- 2040
- 2045
- 2050
- −2%
- −6%
- −14.5%
- −31%
- −62%
- −80%
Implications for Ship Operators
Fuel selection matters:
Operators must choose fuels with lower lifecycle emissions.
Operational planning:
Voyage routes, fuel blends, and port operations can influence compliance with intensity targets.
Penalties for non-compliance:
Authorities can impose fines or restrict port access.
How Uni-Fuels Supports Compliance
Uni-Fuels helps shipowners and operators navigate both EU ETS and FuelEU Maritime requirements:
By combining regulatory expertise, market knowledge, and lower-carbon fuel solutions, Uni-Fuels helps shipowners and operators simplify compliance, reduce risk, and optimize carbon and operational costs.