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OceanScore reviews BIMCO FuelEU clause for time charter parties

Firm applauds BIMCO for taking this ‘admittedly difficult first step’ but noted quite a few gaps remain that individual charter party clause discussions will have to close.

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OceanScore reviews BIMCO FuelEU clause for time charter parties

The current BIMCO draft provides a foundation but leaves substantial room for improvement and charter party specific clarifications, said Hamburg-based technology platform OceanScore on Wednesday (27 November). 

The company was commenting on BIMCO recent release of its much-anticipated clause for Time Charter Parties under the FuelEU Maritime Regulation. 

“Practical solutions must address timing constraints, pooling frameworks, surplus incentives, and pricing disputes,” OceanScore said in a statement. 

“We applaud BIMCO for taking this admittedly difficult first step. The result is balanced, which is appreciated, but quite a few gaps remain that individual charter party clause discussions will have to close. It will be critical to mirror these into the Shipmans with the DOC (Document of Compliance) holders eventually being responsible.”

OceanScore added it is already working with customers to implement forward-thinking FuelEU strategies that fill these gaps, supporting smart decision making and efficient processes between the different stakeholders. 

“Our insights and solutions have demonstrated multiple pathways for turning regulatory challenges into opportunities – requiring proper understanding of these rules and quantification of different pathways,” it added. 

Here are some of OceanScore’s key observations and comments:

Key Observations and Challenges

  1. Alignment with Long-Term Charters

The solutions proposed for long-term Time Charter Parties (those covering entire reporting periods, typically a year) are broadly aligned with market expectations and appear balanced between the needs of owners and charterers. 

  1. Role of DOC Holders

Under the regulations, DOC holders are the designated responsible parties for FuelEU compliance. This means that any clauses within the Time Charter Party must also be reflected in the ship management agreement (shipman). Ensuring consistency across these agreements will be critical for seamless compliance, especially in the case of third party managers.

  1. Timing Considerations

The clause proposes providing compliance balances for the prior two years, but this won’t be feasible until at least 2027 due to the rollout timeline.

Proofs of Sustainability (POS), which are critical to FuelEU compliance, take 4–6 weeks to become available post-bunkering. The proposed 15-day reporting deadline for “verified” compliance balances can be unrealistic.

The clause proposes for the charterer to notify the owner “x days before April 30” of their intent to pool the compliance deficit. These requests should be made as early as possible., If the charterer decides to not pool but pay the “surcharge”, an earlier notification will help the owner (and DOC holder) to identify the commercially most attractive alternative – especially when it comes to finding an alternative external pool.

  1. Pooling – Incomplete Framework 

Pooling compliance balances is likely the most efficient way to secure compliance. But while the clause mentions this in the context of long-term charters, it does not offer a meaningful framework for short-term or broader application. Charterers and owners might benefit from a clear, common understanding of how pooling will be used to achieve compliance – especially as this might be the commercially most attractive choice.

  1. Compliance Surpluses – Practical Solution

The proposal on how to deal with compliance surpluses is balanced, the timing of the proposed steps practical. It will be critical to define the right applicable price (and not fall for a price at the level of the penalty in the case of compliance deficits). Given that pool prices will not be known until well into 2025 or even only when pooling starts in April 2026, it might make sense to opt for some flexibility mechanism in this proposed price for surpluses. 

  1. Pricing Compliance Balances – Unrealistic Approach

The guidance provided that compliance deficits will be compensated for at the level of the penalty (€2.400 / ton VLSFOe) is an attractive, clear solution for the owner. But we do not see this stand the test of intense C/P negotiations, as there will be cheaper ways to comply than to pay the penalty. Realistically, there will be two options: Either an adjusted surcharge below the penalty level or a flexibility mechanism reflecting the pool prices. It should be secured though that the DOC holder receives a fair compensation for his extra effort in securing compliance and for the risk he carries in doing so. 

Related: BIMCO adopts FuelEU Maritime clause for charter parties

 

Photo credit: OceanScore
Published: 29 November, 2024

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FuelEU

Marine Fuels Alliance partners with TidalIQ on website emissions calculator

Emissions calculator helps users estimate vessel or fleet compliance positions, potential penalty exposure, pooling requirements and the indicative value of surplus compliance

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Marine Fuels Alliance partners with TidalIQ on website emissions calculator

Marine Fuels Alliance (MFA) on Friday (3 July) said it has connected with TidalIQ, which has provided an emissions calculator for its website.

MFA said the FuelEU Maritime has turned vessel emissions performance into a commercial issue. Operators now need to understand whether their fleet is in surplus or deficit, what that means financially, and whether pooling can reduce cost or create value.

“The emissions calculator helps users estimate vessel or fleet compliance positions, potential penalty exposure, pooling requirements and the indicative value of surplus compliance,” the alliance said in a social media post.

From there, the TidalIQ platform helps users move from calculation to action: managing fleet compliance, identifying pooling opportunities, generating standardised documentation and maintaining a clear audit trail for verifiers and internal records.

“For operators facing deficits, TidalIQ helps identify a more cost-effective route to compliance. For operators with surplus, it creates a clearer path to monetising better-performing vessels,” it added.

“FuelEU compliance is no longer just a regulatory task. It is a commercial decision – and TidalIQ helps the market make that decision confidently.” 

Note: The emissions calculator can be found here

 

Photo credit: Marine Fuels Alliance
Published: 6 July, 2026

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Port & Regulatory

EmissionLink calls for clarity as EU moves to prevent double carbon charges

The emissions management firm welcomed EC’s commitment to avoid duplicate emissions charges but says shipping urgently needs practical guidance on how EU and IMO carbon regimes will work together.

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Philippos Ioulianou, EmissionLink

The following is a commentary by Philippos Ioulianou, Managing Director of EmissionLink, on how the maritime sector needs clear guidance on how how EU and IMO regulations will be reconciled to avoid duplicate carbon costs for shipowners:

The European Commission’s commitment to prevent shipping companies from being charged twice for the same emissions is a welcome step, but the maritime sector now needs clear guidance on how this will work in practice, according to integrated emissions management service EmissionLink.

The principle of avoiding double charging is clear, but the practical reality is far more complex. Shipping is already navigating a crowded regulatory landscape. EU ETS and FuelEU Maritime are now in force, while the IMO is moving towards its own global Net-Zero Framework. Each system has a different scope, timeline, calculation method and commercial logic. Without detailed guidance, avoiding duplicate carbon costs will not be straightforward.

A vessel trading into Europe may be exposed to EU ETS, FuelEU Maritime and future IMO carbon rules. However, the obligations will not always sit with the same party, emissions data may not always be calculated in the same way, and costs may not be recoverable under existing charterparty terms. 

According to EmissionLink, the risk for shipowners is not only paying twice for the same emissions. It also includes reporting twice, calculating twice and building parallel compliance processes that increase cost, complexity and confusion.

“The industry needs to know how EU and IMO obligations will be reconciled, how equivalent payments will be recognised, and what evidence shipowners will need to prove that the same tonne of emissions has not been penalised more than once,” said Philippos Ioulianou, Managing Director of EmissionLink. “This will determine whether carbon regulation is seen as a fair transition tool or simply another cost burden.”

Accurate and auditable emissions data will be more important than ever, but data alone is not enough. Owners and operators also need the expertise to interpret that data across different regulatory schemes and make informed commercial decisions. EmissionLink has already supported the delivery of accurate FuelEU emissions data for more than 600 vessels, giving it first-hand insight into the complexity of compliance across different vessel types and operating profiles.

“Every vessel has a different operating profile, every voyage has a regulatory consequence, and every compliance decision can affect cost exposure, penalties, pooling options, charterparty recovery and future planning,” said Mr Ioulianou. “The challenge is no longer simply submitting the right figure into the right system. It is understanding how current and future emissions schemes interact, how they affect the business, and how to avoid double penalties, duplicated processes and unnecessary costs.”

The company also highlights that carbon pricing will only retain credibility if revenues are clearly directed back into maritime decarbonisation. Speaking at a ShipEnergy forum during Posidonia, Mr Ioulianou argued that EU member states must set out a clear pathway for the use of revenues generated through EU ETS and FuelEU-related mechanisms.

“These funds should be directed back into the maritime sector,” he said. “They should not become a general revenue stream for governments. Demanding that shipping pays more while failing to invest in the infrastructure needed to make decarbonisation possible is not a transition strategy. It is taxation with a green label.”

Whilst the European Commission is right to recognise the risk of duplicate carbon costs, the industry now needs practical, transparent and enforceable rules that support compliance while helping shipping transition to lower-carbon operations.

“Shipping cannot decarbonise on promises alone,” said Mr Ioulianou. “The sector needs clarity, consistency and confidence that regulation will support the transition rather than simply adding cost and complexity.”

 

Photo credit: EmissionLink
Published: 30 June, 2026

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FuelEU

Hafnia Pools surpasses 170 vessels, achieves FuelEU Maritime compliance

In announcing the company’s Q1 2026 financial results, it said five vessels joined Hafnia Pools during the first quarter of the year, bringing the total number of Pool Partners to 24 across segments.

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Hafnia Pools surpasses 170 vessels, achieves FuelEU Maritime compliance

Singapore-headquartered tanker operator Hafnia on Wednesday (24 June) the company closed Q1 2026 with more than 170 vessels trading across its pool platform.

In announcing the company’s Q1 2026 financial results, it said five vessels joined Hafnia Pools during the first quarter of the year, bringing the total number of Pool Partners to 24 across segments.

Since November 2025, vessels entering the Pools have had an average age of six years or younger, further strengthening the competitiveness and earnings capability of the platform. 

This continued inflow of modern tonnage supports Hafnia’s focus on maintaining an efficient and attractive fleet profile, while enhancing the long-term value proposition for Pool Partners.

In Hafnia’s MR Pool, six owners now each have three or more vessels committed.

During Q1 2026, Hafnia Pools successfully met the EU’s FuelEU Maritime requirements for 2025. Across the Pool, 108 vessels collectively exceeded the emissions limits; however, by working together under a “pooling” system, this was balanced out. By using cleaner vessels, biofuel, and purchased emissions credits, the Pools avoided penalties and achieved meaningful cost savings for partners.

This outcome reflects strong collaboration across Hafnia’s commercial, operational, and compliance teams, as well as constructive engagement with all Document of Compliance holders as regulations such as FuelEU come into full force.

In June 2026, Hafnia Pools further strengthened Partner engagement and alignment through its bi-annual Pool Board meeting, taking place during Posidonia in Greece.

Peter Kolding, VP Chartering Regional Trades & Pool Management, said: “As we move further into 2026, our focus remains on delivering consistent commercial results, strengthening the value proposition for all Pool Partners, and continuing to build on the close cooperation between our Chartering and Operations teams that underpins the success of the Hafnia Pools.

“I am encouraged to see that our commercial performance and efforts in staying close to our partners are paying off as we enjoy growing support from many of those same partners. It indicates that we are on the right path and energizes us to continue doing everything we can to improve even further.”

 

Photo credit: Hafnia
Published: 26 June, 2026

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