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Shipping EU ETS

  • Comply with EU ETS obligations for shipping and avoid risks of fines and delays
  • Receive independent verification and practical support for EU ETS compliance
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Shipping EU ETS compliance for maritime emissions 

As part of the European Fit for 55 climate package, the EU Emissions Trading System (EU ETS) has been extended to the maritime sector. Since 1 January 2024, shipowners and operators must monitor, report and surrender EU emission allowances (EU Allowances – EUAs) for verified emissions. 

This obligation is introduced gradually: 

  • 2024: 40% of emissions fall under EU ETS  
  • 2025: 70% of emissions  
  • 2026 and thereafter: 100% of emissions  

All ships of 5,000 GT or larger calling at EU ports fall under this scheme. The regulation applies to: 

  • 100% of emissions from voyages within the EU/EEA  
  • 50% of emissions from voyages between EU and non-EU ports  

In addition, EU ETS includes three greenhouse gases: 

  • CO₂ (carbon dioxide)  
  • CH₄ (methane)  
  • N₂O (nitrous oxide)  

Till 2025 : Consideration of CO₂ emissions only for EUAs 

2026 and thereafter : consideration of CO₂, CH₄, N₂O  emissions as CO2 equivalent for EUAs 

Normec Verifavia supports maritime organizations with accredited verification and compliance solutions for EU ETS. 

Exceptions and exemptions within Shipping EU ETS 

Within EU ETS for shipping, exemptions or deviations from emissions obligations apply in specific situations. These exceptions are intended to take account of operational circumstances and regional transport needs. 

Ice-class ships 

Ships with a certified ice-class IA, IA Super or an equivalent classification qualify for a 5% discount on their annual obligation to surrender emission allowances. This scheme takes account of the additional energy required for operations in ice conditions. 

Container transshipment ports 

To prevent shipping companies from avoiding EU ETS obligations by calling at nearby transshipment ports outside the EU, such ports are not considered an official “port of call” when they meet specific criteria. 

A port is regarded as a neighbouring transshipment port when: 

  • More than 65% of container traffic (TEU) consists of transshipment  
  • The port is located outside the EU but within 300 nautical miles of an EU port  
  • The country concerned does not have a comparable emissions trading system  

These ports are listed in Implementing Regulation (EU) 2023/2297. Currently, East Port Said (Egypt) and Tangier Med (Morocco), among others, are on this list. The list is revised every two years. When a voyage calls at such a port, the ETS-relevant leg is calculated between the last port before the transshipment port and the EU/EEA port (or vice versa). 

EU outermost regions (OMR) 

According to Commission Implementing Decision (EU) 2023/2895, emissions are exempt from EU ETS when a ship sails between: 

  • An EU outermost region  
  • And a port in the same EU Member State  

This exemption also applies to emissions arising when the ship is alongside during these voyages. 

Exemption for small islands 

A temporary exemption applies for certain passenger ships and Ro-Pax ferries when they operate under transnational public service obligations between two EU Member States. 

In addition, Member States may apply a temporary full exemption until 31 December 2030 for non-cruise passenger ships and Ro-Pax ferries sailing between: 

  • Small islands without a road or rail link to the mainland  
  • And a port on the mainland  

This applies to islands with a permanent population of fewer than 200,000 inhabitants. The European Commission will publish an official list of islands and ports that fall under this scheme. 

Our approach 

EU ETS compliance requires accurate emissions data, reliable monitoring and correct reporting processes. Normec Verifavia helps organizations at every step of this process. 

Our services include, among other things: 

  • Assessment of Monitoring Plans (MP)  
  • Verification of EU MRV emissions reports  
  • Support with EU ETS verification and compliance  
  • Guidance on data collection and reporting processes  

Our verification is carried out according to internationally recognized standards such as: 

  • ISO 17029  
  • ISO 14065  

Normec Verifavia is accredited by: 

  • COFRAC (France)  
  • UKAS (United Kingdom)  
  • SAC (Singapore)  

This enables us to independently verify emissions claims according to international standards. 

Normec Verifavia's expertise 

Normec Verifavia  has years of experience with maritime emissions regulations, EU MRV verification and EU ETS compliance. 

Our auditors combine in-depth knowledge of: 

  • Emissions measurements and fuel reporting  
  • EU ETS and MRV regulations  
  • Alternative fuels and emissions calculations  
  • Operational processes within the shipping sector  

We work closely with your team to provide practical support with monitoring, reporting and verification. 

  • You avoid compliance risks and possible sanctions through timely verification of emissions data  
  • You comply with EU ETS regulations and reporting requirements for maritime emissions  
  • You receive reliable emissions data that is important for financial planning and EUA cost management  
  • You improve transparency towards stakeholders such as customers, investors and regulators  
  • You support an efficient energy transition within the maritime sector  

Prepared for the future 

The inclusion of shipping in the EU ETS is an important step towards CO₂ reduction in the maritime sector. At the same time, the regulation brings new challenges, such as: 

  • Additional administrative obligations for monitoring and reporting  
  • Financial impact due to the purchase of EU Allowances  
  • Technical complexity in emissions measurements and alternative fuels  
  • Market volatility due to fluctuating EUA prices  

By investing in reliable emissions data and verification processes in time, you ensure that your organization is prepared for future climate regulations.

Would you like to know more about Shipping EU ETS?

Frequently asked questions

EU ETS is the European emissions trading system that has also applied to the maritime sector since 2024. Ships must monitor and report their emissions and surrender emission allowances for their emissions.

All ships of 5,000 gross tonnage (GT) or more calling at EU ports fall under the regulation.

EU ETS includes three greenhouse gases: CO₂, methane (CH₄) and nitrous oxide (N₂O).

The obligation is introduced gradually:

- 40% of emissions for 2024

- 70% for 2025

- 100% from 2026 onwards

EU Allowances are emission rights that companies must purchase and surrender for the amount of greenhouse gases they emit.

Verified emissions data is essential for compliance, financial planning and transparency towards stakeholders.

When a shipping company does not comply with its EU ETS obligations, several sanctions may follow.

- If emission allowances are not surrendered on time, a penalty of €100 per tonne of CO₂-equivalent applies for the emissions for which no EU Allowances have been surrendered, in addition to the obligation to still surrender them.

- When a shipping company fails to comply with the obligations during two consecutive reporting periods, a competent authority may issue an expulsion order.

- In that case, EU Member States other than the flag state may refuse access to their ports for ships operating under the control of that shipping company.

- If a ship sails under an EU flag, the flag state may even detain the ship in port.

In addition, the names of non-compliant shipping companies may be made public, which can cause reputational damage.

Partial verification is mandatory when a ship changes operational responsibility between shipping companies during a reporting period.

According to article 11(2) of the EU MRV Regulation, the outgoing shipping company must submit a verified partial emissions report to the competent authority within three months after the transfer.

EU Allowances (EUAs) are traded on trading platforms such as the European Energy Exchange (EEX).

Only the shipping company can manage a Maritime Operator Holding Account (MOHA). In practice, EUA costs under time charter agreements are often passed on to charterers, as laid down in article 3gc of the revised EU ETS Directive. 

Many charter parties use the BIMCO ETS Clause 2024 to make arrangements regarding the allocation and transfer of EUA costs.

When a ship changes berth within the same port, this is not considered a separate voyage under EU ETS.

Because there is no change of port, this is not reported as a new voyage. Emissions arising during this movement may, however, be included in the total emissions during the stay in port, which fall 100% under EU ETS.

To recognize biofuel as sustainable within the EU regulatory framework, the bunker supplier must provide, among other things, the following documentation:

- A Proof of Sustainability (PoS) certificate from a recognized EU certification scheme (for example ISCC or RSB)

- Mass balance documentation to demonstrate traceability of the fuel in the supply chain

- Calculations of GHG emission reductions according to the RED II threshold values

- Evidence of compliance with environmental and social sustainability requirements

This documentation confirms that the fuel complies with the EU ETS and RED II sustainability criteria.

When a ship comes under a different shipping company, the new shipping company must update the Monitoring Plan (MP) and have it approved by the verifier.

If the change takes place during a reporting period:

- The new shipping company reports the emissions for the full year at the end of the year.

- The previous shipping company submits a verified partial emissions report within three months for the period during which it was responsible.

When a voyage runs across two EU ETS reporting periods:

- Emissions from departure until 31 December 2024 are reported in the 2024 reporting period.

- Emissions from 1 January 2025 until arrival are reported in the 2025 reporting period.

Stops for drydock or repairs are not considered a "port of call" under the MRV regulation.

This means that emissions during the drydock period are not counted for EU ETS obligations. The voyage is in effect temporarily interrupted and emissions reporting resumes once the ship departs again for a next operational voyage.