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Clyde & Co: EU Proposals to include Shipping in the Emissions Trading Scheme – what do we know?

The EU Commission on 14 July, 2021 proposed legislation to amend the European Union Emissions Trading Schemeto include shipping emissions.

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International law firm Clyde & Co LLP on Tuesday (30 November) published an insight focusing on the EU proposal to include shipping in the emission trading scheme.

On 14 July 2021, the EU Commission proposed legislation to amend the European Union Emissions Trading Scheme (EU ETS) to include shipping emissions (the Proposal). In this article, we will consider what is known about the scheme and how it is expected to function in practice.

Who will be responsible for compliance with the new scheme?

The most likely position is that the party responsible for compliance with other international schemes like the MRV Regulation and the ISM Code will also be the one responsible for compliance with the EU ETS regime.

More specifically, under the Proposal, the person or organisation which is responsible for compliance with EU ETS will be the “shipping company”, which is defined as“the shipowner or any other organisation or person, such as the manager or the bareboat charterer, that has assumed the responsibility for the operation of the ship from the shipowner and that, on assuming such responsibility, has agreed to take over all the duties and responsibilities imposed by the International Management Code for the Safe Operation of Ships and for Pollution Prevention, set out in Annex I to Regulation (EC) No 336/2006 of the European Parliament and of the Council.”

What about time charters?

Under time charters, the “shipping company” may not necessarily be the one who is responsible for crucial operational decisions regarding emissions. 

The EU Commission has anticipated that owners and charterers may wish to account for this in their charterparties, saying:

“In line with the polluter pays principle, the shipping company could, by means of a contractual arrangement, hold the entity that is directly responsible for the decisions affecting the CO2 emissions of the ship accountable for the compliance costs under this Directive. This entity would normally be the entity that is responsible for the choice of fuel, route and speed of the ship.”

It remains to be seen how parties will account for this in practice – arguably both the owner and the time charterer have significant influence over the overall emissions profile of the vessel.

In the meantime, the European Community of Shipowners’ Associations (“ECSA”) has been considering the effect on the industry and how the Proposal might be amended to remove uncertainty about which party should pay. On 2 November 2021, ECSA produced a policy paper which proposed, among other things:

  1. The introduction of a dedicated Maritime Climate Fund intended to stabilise the (currently volatile) carbon price and support the energy transition of maritime sector.
  2. Making the “commercial operator” (in many cases, the time charterer) rather than the “shipping company” responsible for ETS compliance; or, alternatively
  3. Introducing a binding public law requirement that ETS costs be “passed through” from shipping companies to commercial operators.

It remains to be seen whether these proposals will be considered by the EU, or whether there is popular support for them within the wider industry.

What about spot charters/freight rates?

It is inevitable that the costs of buying allowances will have a knock-on effect on freight rates and add volatility to an already volatile market. The European Energy Exchange (“EEX”) has identified this as an issue and has responded by creating the EEX Zero Carbon Freight Index, which is intended to give traders an idea of how the cost of carbon emissions could affect freight prices.

What will shipping companies have to do?

Monitoring, reporting and verification

Shipping companies will be required to put in place systems to monitor and report their emissions, which must be approved and then verified by an administering authority (about which, see below). As mentioned above, most shipping companies to be covered by EU ETS will already be subject to the MRV Regulation and should thus have these systems in place. 

The Proposal suggests that the intention is supplement the MRV Regulation obligations to ensure that all the necessary data is captured, rather than to introduce entirely new systems.

Surrender of carbon allowances

At the end of a reporting period, the shipping companies will then be required surrender allowances (often colloquially known as ‘carbon credits’) in respect of their aggregated emissions for all of the applicable voyages during the period. There do not appear to be any plans to allow allocation of “free allowances” to shipping companies, so they will have to purchase all of the allowances that they need, either at auction or on the open market via exchanges like EEX or ICE.

How much will it cost?

The Commission anticipates that the new scheme will capture emissions of about 90 million tons of Co2 (or equivalent) a year. At the current market price of ~EUR 55 per ton of Co2, this would require shipping companies to surrender total allowances in the order of EUR 5 billion per year.

However, the main concern for shipping companies will be carbon price uncertainty: from Oct-20 to Oct-21, for instance, the carbon price jumped between EUR 24 and EUR 62.

Ultimately, if enacted, the shipping emissions scheme will be phased in (see below), so costs will not reach these levels until reporting year 2026.

What penalties are there for non-compliance?

If shipping companies fail to comply with their obligations to monitor, report and verify emissions, and then surrender allowances, they can be fined.

In extremis, if a company fails to comply with surrender requirements for two or more consecutive reporting periods, then the EU can issue an “expulsion order” with the result that no EU port will allow the shipping company’s vessels to enter and the vessel may even be arrested by its flag state, if that state is an EU member.

What voyages does the Proposal cover?

Shipping companies will need to purchase allowances to cover:

  1. 100% of emissions for intra-EU voyages; and
  2. 50% of emissions for voyages beginning or ending at EU ports.

Who will monitor and enforce the new ETS regime?

The EU ETS regime will be monitored and enforced by all of the EU member states, and each shipping company will be assigned an “administering authority” by which it is specifically supervised. If the shipping company is registered to an EU member state, then its administering authority will be that that member state. In most other cases the administering authority will be the member state at which the shipping company has made the most port calls in the preceding two years.

From 2024, the EU Commission will publish and regularly update the list of shipping companies and their respective administering authorities.

In practical terms it is expected that administering authorities will request the assistance of the European Maritime Safety Agency “EMSA” to carry out their obligations regarding approval of monitoring plans and verification of emissions, in line with its current work in doing so for the MRV Regulation.

How will the scheme be phased in?

The Commission proposes to phase in the requirement to purchase and surrender allowances over a four-year period, so that shipping companies must purchase allowances as follows:

  • 20 % of verified emissions reported for 2023
  • 45 % of verified emissions reported for 2024
  • 70 % of verified emissions reported for 2025
  • 100 % of verified emissions reported for 2026 and each year thereafter.

The IMO is creating similar provisions globally, like Energy Efficiency Existing Ship Index (“EEXI”) and the Carbon Intensity Indicator (“CII”). Surely this is going to doubly affect shipping companies?

The EU Commission have identified this potential problem and in response they have included a review clause aimed at considering the effect of EU ETS in combination to the global measures taken by the IMO.

In the meantime, the industry will have to watch these schemes as they develop to understand if and how they interact with each other in practice.

 

Source: Clyde & Co LLP
Photo credit: CHUTTERSNAP from Unsplash
Published: 1 December, 2021

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Interview

Interview: Alkagesta navigates risk from bunkering ops during turbulent times

As the industry navigates this period of uncertainty, the key question is no longer ‘what will fuel cost?’ but rather ‘will fuel be available?’, highlights Mithat Çiftçioğlu.

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Mithat Çiftçioğlu, Marine Fuels Director at Alkagesta, shared his opinion on risk management for bunkering operations under current geopolitical tensions through the April edition of shipping magazine Deniz Ticaret.

The maritime publication, part of the Turkish Chamber of Shipping (İMEAK Deniz Ticaret Odası), has given Manifold Times permission to republish the article:

Fueling Ships in Turbulent Times

From Oil Shock to Fuel Access Crisis: A New Risk Map for Maritime 2026

The final weeks of the first quarter of 2026 mark one of the most complex periods in recent years for global energy and maritime markets. The sharp rise in oil and refined product prices since February 28 may look like a classic energy shock at first glance, but developments in the maritime sector point to a far deeper structural rupture.

What is being debated in the market today is no longer just oil prices. For traders and shipowners operating in the maritime sector and bunker market, the real issue is not the price of fuel — it is access to fuel. The fundamental question in the market has shifted: not what will the price of fuel be, but will fuel even be available?

In light of the Force Majeure cancellations at Asian ports over the past two weeks, another question must also be considered: Will pre-agreed bunker supply contracts actually be delivered?

From Oil Prices to Logistical Reality

Tensions in the Middle East have created a strong geopolitical risk premium in the oil market. Brent crude briefly surpassed the $100 per barrel mark, triggering a search for a new equilibrium across markets. This will inevitably bring inflation and recession back onto the global agenda in the months ahead.

But the rise in oil prices does not only reflect the risk of supply disruption — it also signals the return of one of the most fragile chokepoints in global energy trade:

The Strait of Hormuz

Approximately one-third of the world’s oil trade passes through this narrow waterway. Around 20 million barrels of oil and petroleum products transit Hormuz daily. Any disruption here would therefore affect not only oil prices, but also global refined product flows and the bunker market directly.

Why Strategic Oil Reserves Are Not the Solution

A commonly proposed solution in energy crises is the release of strategic petroleum reserves. However, releasing these reserves does not directly resolve a bunker crisis. Strategic reserves consist of crude oil. To produce bunker fuel, the following chain must be completed:

Crude oil → Refinery → Product logistics → Bunker port

This process takes time. Strategic reserves can temporarily stabilize oil prices, but they cannot solve the access problem in the bunker market in the short term.

Furthermore, the announced reserve release of 400 million barrels, to be drawn down at a rate of 2.5–3 million barrels per day, can only cover a small fraction of the estimated daily loss from the Middle East — optimistically 8–10 million barrels, pessimistically 18–20 million barrels per day.

A Historic Surge in Bunker Fuel Prices

The per-ton price of VLSFO (0.5% sulfur) bunker fuel has surpassed $1,000, reaching approximately double pre-war levels. This also represents some of the highest prices seen since July 2022.

While prices at bunker hubs such as Singapore and Fujairah are approaching $1,100 per ton, European markets have remained comparatively lower.

The Real Problem Is Not Price — It Is Fuel Access

Obtaining bunker quotes for April has become increasingly difficult, particularly at Asian ports. Even where shipowners and traders can secure quotes, the absence of supply guarantees makes pricing extremely challenging.

A senior executive at Oldendorff Carriers summarized the situation in these words:

“We cannot price cargo because we cannot calculate fuel costs; we cannot calculate fuel costs because there is no supply guarantee.”

The CEO of Maersk has compared the current situation to the pandemic era, stating that companies are attempting to source fuel through methods they have never tried before in order to keep global shipping networks supplied.

While supply is tight and prices are near their peak in Singapore and Fujairah, Rotterdam appears relatively more balanced. However, as the conflict drags on, risk perception in European markets is also rising.

The surge in bunker prices will not only increase costs — it will also affect global maritime transport capacity. Ships are expected to reduce their speeds to conserve fuel. This could lead to a reduction in effective carrying capacity, creating new logistical bottlenecks in global trade.

The importance of working with reliable, long-term partners has never been more apparent than during a crisis such as this.

The Widening Price Spread Between Fuel Types

A notable development in the bunker market in recent weeks is the rapid widening of price differentials between different fuel types. Two spreads in particular have expanded significantly:

  • Marine Gas Oil (MGO) – VLSFO
  • VLSFO – HSFO

Rising demand for distillate products, refinery production balances, and regional supply tightness are all contributing to this widening. As a result, bunker purchases have become not merely a matter of price level, but a strategic decision tied to product type and port selection.

An Unexpected Development: Biofuels Becoming Competitive

Another noteworthy development in the bunker market is that biofuels have remained at relatively competitive price levels. This creates two important opportunities for shipowners.

On one hand, biofuels remain competitively priced in certain markets. On the other, they offer a means of compliance with new regulations entering into force in Europe — particularly the FuelEU Maritime and EU ETS frameworks, which require reductions in carbon intensity. In this context, biofuels have become a strategic option for many shipowners.

Conclusion: Active Bunker Management Is The New Normal

The 2026 bunker market presents one of the most complex energy trading environments in recent years. The rise in oil prices, geopolitical risk at the Strait of Hormuz, tightness in physical fuel supply, and widening price spreads between fuel types have made bunker fuel management more critical than ever.

The prevailing view in energy markets is that as long as the risk at the Strait of Hormuz persists, turbulence in the bunker market will persist with it. As time passes, the depletion of commercial stocks may deepen the existing supply tightness further.

For this reason, the current situation is viewed not merely as an energy crisis, but as a new stress scenario testing the logistical infrastructure of global trade.

The view increasingly heard across energy markets is this:

“As long as Hormuz remains closed, it will not be oil prices but fuel access that constitutes the defining risk for global shipping.”

Finally, for shipowners and operators, bunker strategies are shifting away from a passive purchasing approach toward a model grounded in active risk management.

 

Photo and article credit: Deniz Ticaret
Published: 7 May 2026

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Analysis

T&E: Overreliance on traditional bunker fuels costs shipping USD 395 million a day due to Iran conflict

Development has made alternative fuels increasingly more competitive, states Eloi Nordé, shipping policy officer at T&E.

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The Hormuz crisis adds over 300 million a day to shippings fossil fuels bills

The European Federation for Transport and Environment (T&E) on 27 March highlighted the adoption of green marine fuels would reduce the shipping industry’s exposure to fuel price shocks in future.

It noted shipping companies are spending an extra €340 million (USD 394.74 million) a day in additional fuel costs as a result of the latest conflict in the Gulf.

As 99% of the global fleet runs on fossil fuels, the industry is directly exposed to fuel price volatility and supply disruptions. Efficiency measures, electrification and e-fuels would reduce the industry’s exposure to price fluctuations.

According to T&E, marine fuel prices have escalated rapidly, with VLSFO reaching €941 per tonne in Singapore, up 223% since the start of 2026. At the same time, LNG prices have risen by 72% since early March. Since February 28, shipping companies have incurred more than €4.6 billion in additional fuel costs.

The development has made alternative fuels increasingly more competitive. As fossil fuel prices reach record highs again, the cost gap with e-fuels is narrowing.

T&E’s research shows that the cost gap between marine gas oil – one of the more expensive fossil fuels – and e-fuels has shrunk to near parity (+5%) in some ports.

Hormuz oil crisis boosts potential e fuel competitiveness

While the trend may be temporary, it shows that the volatility of fossil fuel markets offsets much of the structural cost disadvantage of clean fuels.

“Chaos in the Strait of Hormuz is putting global maritime trade under the spotlight. But it’s on the oil markets where its impact will be felt the most. The war is costing the industry millions every day,” said Eloi Nordé, shipping policy officer at T&E.

“Some governments and parts of the industry have spent the last year bashing green maritime measures as being too expensive, yet those costs pale in comparison to this super-disruption.

“If anything, this crisis should be the catalyst for more investment in European e-fuels and greater uptake of energy efficiency measures to avoid fossil fuel shocks in the future.”

 

Photo credit: European Federation for Transport and Environment
Published: 2 April 2026

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Business

Interview: Nunchi Marine believes Iran war forces a reset in bunker cargo trading

Tomas Stacy, Managing Director of Bunker Trading at oil cargo and bunker trading company, Nunchi Marine, comments on volatility, supply disruption and survival in a fractured market.

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The war involving Iran has pushed the global bunker market into one of its most turbulent periods in recent memory, with Singapore – the world’s largest bunkering hub – feeling the impact.

Once‑reliable supply chains have been disrupted, price volatility has surged to extreme levels, and bunker cargo traders are being forced to abandon long‑standing strategies in favour of defensive, risk‑driven decision‑making.

The sharp reduction in Middle Eastern supply flows has exposed structural vulnerabilities in the market, while suppliers and traders alike have tightened terms amid unprecedented uncertainty.

Against this backdrop, bunker cargo trading has shifted from margin optimisation to survival mode. In this executive interview, Tomas Stacy, Managing Director of Bunker Trading at Singapore-headquartered independent oil cargo and bunker trading company, Nunchi Marine shares how the conflict is reshaping bunker cargo trading, the challenges importers now face, and what it takes to navigate a market defined by scarcity, volatility and risk.

MT: How has the Iran war changed the bunker cargo trading landscape in Singapore?

TS: The change has been structural rather than cyclical. The market is now characterised by extreme price volatility, tighter availability, and far more defensive behaviour from both traders and physical suppliers. The conflict has disrupted a core supply artery into Asia, and that has exposed just how dependent Singapore has been on stable Middle Eastern flows. Trading today is less about optimising margins and more about managing risk and ensuring continuity of supply.

MT: What has been the most immediate impact on bunker cargo importers since the conflict began?

TS: Margin pressure and uncertainty have intensified almost overnight. The sharp drop in tanker movements through the Strait of Hormuz has effectively choked a primary supply source, and that has translated directly into price shocks. Since the war began, VLSFO prices in Singapore have more than doubled, while MGO prices have surged even more sharply. For importers, this has made forward planning extremely difficult and increased exposure on every cargo decision.

MT: Why has the market struggled to replace lost Middle Eastern barrels?

TS: The scale of the disruption is the key issue. The Middle East typically supplies around 1.2 million metric tons of fuel oil per month to Asia, and there is no simple replacement for that volume. Alternative supplies from the Americas or Russia exist, but they are constrained by high freight costs, sanctions, or limited availability. In practical terms, arbitrage opportunities into Singapore have become largely unworkable, leaving the market structurally tight.

MT: How has extreme price volatility changed trading behaviour and supplier relationships?

TS: Volatility has fundamentally altered risk appetite. At the onset of the conflict, prices were moving by as much as $100 to $150 per metric ton in a single day, which makes holding large cargo positions highly risky. In response, physical suppliers have become increasingly defensive—rationing volumes, prioritising long‑standing customers, and avoiding even short‑term term contracts. For traders, this has meant smaller position sizes, shorter, and a much greater emphasis on counterparty strength and reliability.

MT: Beyond price and supply, what risks are now top of mind for bunker cargo traders?

TS: Quality and logistics have moved sharply up the risk agenda. Recent alerts around off‑spec VLSFO in Singapore which were linked to engine damage, have added a new layer of concern for cargo procurement. At the same time, tight supply conditions are beginning to create logistical bottlenecks, with some vessels struggling to secure bunker slots and early signs of congestion appearing at major ports. In this environment, survival depends on disciplined risk management—avoiding long‑term fixed‑price exposure, strengthening supplier relationships, enforcing stricter quality controls, and building greater operational flexibility into voyage planning.

 

Photo credit: Manifold Times
Published: 31 March 2026

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