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DNV: How FuelEU Maritime is changing commercial negotiations

DNV offers a look into its partnership with Exmar Ship Management to navigate FuelEU Maritime risks as the regulation reshapes commercial negotiations, exposing independent ship managers to new financial risks.

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DNV: How FuelEU Maritime is changing commercial negotiations

Classification society DNV on Thursday (27 November) published a Maritime Impact article highlighting Exmar Ship Management’s partnership with DNV and Veracity to navigate FuelEU Maritime risks as the regulation reshapes commercial negotiations, exposing independent ship managers to new financial risks. 

By using Emissions Connect as a single source of verified data, Exmar streamlined compliance, improved risk management, and built greater trust with owners and charterers: 

The FuelEU Maritime regulation differs from the EU Emissions Trading System in terms of reporting responsibilities and financial liabilities. DNV’s Emissions Connect can function as a trusted single source of truth for all stakeholders that supports fair cost allocation.

The reporting requirements stipulated by the FuelEU Maritime (FEUM) regulation add another level of complexity to emission management. While under the EU Emissions Trading System (EU ETS), shipowners must submit annual emissions reports, the new FEUM regulation in effect since 1 January 2025 assigns the emissions reporting responsibility to the ship manager as the holder of the document of compliance (DoC), with consequences for the business relationship between the owner, charterer, and independent ship manager (ISM). Nevertheless, Arne Lippens, Head of Technical Compliance at Exmar Ship Management, believes that monetarizing emissions is a good thing: “It finally opens up the dialogue between the partners,” he says. “In the past, there was always a split incentive: the charterer was paying the fuel costs, whereas any investments by the owner in efficiency improvements or fuel and emission monitoring technology would benefit the charterer, not the owner. 

Document of compliance holder has legal responsibility

Shipowners with ship management divisions of their own can handle the consequences relatively smoothly, but third-party, independent ship management companies (ISM) are exposed to the full financial risk arising from emissions liabilities, a fact that needs to be addressed in their commercial negotiations with owners, who must monitor and manage the FEUM compliance balances for specific charter periods. This constellation must be adequately accounted for in the charter party negotiations between the owner and charterer to achieve fair allocation of the financial exposure.

There are far-reaching implications for the legal relationship between the contractual parties involved in the ownership and operation of a vessel. “Charter parties rarely line up with the annual compliance cycle,” explains Helge Hermundsgård, Head of Business Development for DNV’s Emissions Connect services. “This means that charter parties must ensure that the incurred liabilities are addressed as charters start and end during the reporting year.” The ISM in charge at year’s end is responsible for compliance with the reporting requirements during the entire calendar year – a responsibility that cannot be assigned to a third party.

Charter parties must reflect “polluter pays” principle

However, the ISM has virtually no influence on the factors determining FuelEU Maritime exposure, such as the fuel used and the ship’s trade, continues Hermundsgård. “ In other words, the financial consequences should be assigned to the party that can influence those factors, based on the principle that the polluter pays.”

The FEUM regulation leaves the contractual details of these arrangements up to the commercial partners. On 19 December 2024, the Baltic and International Maritime Council published a FuelEU Maritime clause for its SHIPMAN standard contract, which is widely used as a basis for ship management contract negotiations. Other bodies are offering similar contract amendments.

Charter parties must clearly allocate financial responsibilities

There are certain intricacies and details that the SHIPMAN FEUM or similar clauses cannot cover. “Independent ship managers, charterers, and owners must understand the regulations clearly and find ways to allocate the financial consequences in their charter parties fairly, including provisions for hypothetical events or situations,” explains Lars Nyfløt, Global Sales Manager Emissions Connect Business Development at DNV. “They need a clear understanding of who is in charge of what.” Questions such as how the responsibility for FEUM will be reallocated to the owner and how the ISM is guaranteed compensation for any additional liabilities must be answered in advance. “An ISM must be highly aware of its risk and ensure that the commercial agreement with the owner provides for suitable mechanisms to manage that risk,” says Nyfløt.

For companies like Exmar, which manages its own fleet as well as third-party vessels as an ISM, there is a silver lining to this, says Arne Lippens, because the need for the commercial partners to cooperate more closely gives the ISM a stronger position as a provider of regulatory know-how and related services: “The emission penalties resulting from EU ETS, FEUM, and the forthcoming IMO regulation might double the cost of fuel in the foreseeable future, making it crucial for the party paying the bill that their operational expense and fuel spend are managed well. So they have to reach out to us, which creates an extra bond, a new level of trust between ourselves and our partners, and an enhanced role for us as an ISM.”

Contracting parties need a trusted common source of emission data

Nyfløt, who held various commercial functions in the shipping industry on both the shipowners’ and the charterers’ side for about 30 years and took part in countless charter party negotiations before joining DNV, says it is crucial for all players in the value chain, including the technical manager, the owner, the charterer, the cargo owner if different, the management company, and others, to have a clear picture of how emissions affect pricing. “This will support good-faith negotiations with the understanding that all parties are ultimately in the same boat, as it were, bearing a shared responsibility for compliance, each side with its own part to play.

“In my experience,” adds Nyfløt, “one of the most important assets in charter negotiations is a trusted source of emission data. Proper documentation and a single source of truth accepted by all stakeholders are key to negotiations that deliver satisfactory results.”

Note: The full article by DNV can be read here

 

Photo credit: Exmar Ship Management
Published: 1 December, 2025

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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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