The first data on FuelEU Maritime compliance is now emerging, following the first year of reporting against greenhouse gas (GHG) intensity targets for shipping companies trading in the EU.
To better understand what the early results show, we spoke with Joe Bettles, Climate Policy Manager and author of the Countdown newsletter at the Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping (Center). The Center recently published its analysis of the first reporting year in the article "What did we learn from the first year of FuelEU?"
Under the regulation, shipowners have several options for compliance, including:
A. The pooling mechanism, which allows vessels with a compliance surplus to trade it with other vessels.
B. The borrowing mechanism, which allows companies to defer a compliance deficit to the following year for a 10% surcharge.
C. Meet the target by using low GHG intensity fuels.
D. Pay the FuelEU penalty (penalty).
Pooling becomes the preferred option
The first year of reporting indicates that pooling has quickly become the preferred choice. According to data from the European Commission, 92% of vessels used the pooling mechanism, while only 2% used borrowing. The remaining vessels either paid the penalty or met the target by using LNG or other low-GHG energy sources.
Commenting on the findings, Joe Bettles says: "Our insights from the first year of reporting indicate that shipping companies were able to comply with the targets, with most using the pooling mechanism. This shows that FuelEU is working as intended. As we approach the IMO's upcoming discussion on the Net-Zero Framework (NZF), FuelEU demonstrates that it is possible for the global fleet to comply with a GHG intensity regulation using existing fuels and providing incentives for the uptake of cleaner energy sources."
A developing market for compliance surplus
The Center's article also reviews the different pooling platforms available to shipping companies seeking to meet their obligations under the regulation. The price of compliance surplus, averaging around EUR 208/tCO₂eq, remained relatively stable, suggesting that the market matured early, with buyers generally able to find sellers.
On the development of the pooling market, Joe notes: "The prices for trading compliance surpluses remained well below the EUR 640/tCO₂eq penalty for VLSFO, making the pooling mechanism significantly more attractive than paying the penalty."
Fuel choices remain central to compliance
The role of fuel choice is also important. Looking at fuels supplied to the FuelEU market, the Center estimates that 3.22 million tCO₂eq of reductions, relative to an all-VLSFO fleet, will be required to meet the 2% reduction target between 2025 and 2029. Based on analysis of previous years' fuel consumption, the Center indicates that LNG may have contributed around one-third of the required reduction. Biofuel blends account for the remainder, with biodiesel and bio-LNG dominating the low-GHG fuel mix.
Joe highlights how the pooling mechanism can help extend the impact of lower-GHG fuels across the fleet: "Although LNG is not a drop-in replacement for VLSFO, the pooling mechanism under FuelEU allows an LNG-fuelled vessel to share its over-compliance with other vessels that cannot physically use LNG. Depending on the engine type in the ship, LNG can remain compliant with the 14.5% reduction target through 2039 and can further extend its compliance through banked surplus or by using liquified biomethane."
Three early lessons from FuelEU Maritime
Drawing on the first year of reporting, Joe Bettles and the Center identify three lessons that may also be relevant for the IMO in the future.
First, the results indicate that a fuel standard for shipping can work. FuelEU's first year has created incentives for the use of alternative fuels and a market for those who prefer to pay for emissions compliance.
Second, regulations should include mechanisms that support a broader mix of energy sources. Lower-maturity alternatives, such as wind-assisted propulsion, e-fuels and onshore power, still represented a limited share of the mix.
Third, policy stability and clear reduction pathways can help reduce uncertainty for shipping companies and support the business case for investment in cleaner alternatives.
Supporting knowledge sharing across the maritime value chain
Skuld is a Mission Ambassador to the Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping, supporting its work as a platform for collaboration, knowledge sharing and practical insight across the maritime value chain.
"The Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping is a highly valuable forum for us at Skuld. It provides access to a broad network of industry stakeholders and helps us stay close to the challenges shipowners face in meeting regulatory requirements and reducing emissions. Just as importantly, it serves as a platform for dialogue and knowledge sharing across the maritime value chain" – Matias Bøe Olsen, Decarbonisation and transition risk lead, Skuld.
You can read the full article on FuelEU's first-year experiences here: https://www.zerocarbonshipping.com/news/countdown-what-did-we-learn-from-the-first-year-of-fueleu