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EU ETS

Law firm WFW shares EU ETS and FuelEU compliance and exemptions checklists

Watson Farley & Williams’ Nick Walker and Valentina Keys present a guide for shipping companies to navigate through complexities of EU ETS and FuelEU Maritime regulation.

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Watson Farley & Williams LLP London Partner Nick Walker and Counsel Valentina Keys on Monday (2 September) published an article to guide shipping companies on the European Emissions Trading Scheme and FuelEU Maritime regulation: 

Since 1 January 2024, shipping companies have been subject to the expanded European Emissions Trading Scheme (“EU ETS”), have had to monitor their emissions, open trading accounts (see below) and been tasked with formulating more efficient fuel and route compliance strategies in preparation for the submission of their first reports in March 2025. This briefing and the bespoke compliance and exemptions checklists we have prepared will help guide you through the complexities of the EU ETS and FuelEU Maritime Regulation (“FEMREG”).

EU ETS and MOHAs

Shipping companies will be required to surrender their EU ETS allowances for the first time on 30 September 2025. For an analysis of the commercial and legal implications of EU ETS for shipowners, managers, charterers and other maritime participants see here and here. Against this backdrop, little progress has been made with the opening of Maritime Operator Holding Accounts (“MOHAs”) with only 940 or so MOHAs having been opened by shipping companies thus far¹. 

We understand that registries in various member states are struggling to manage the large volumes of applications that have been made. The fact that the EU ETS has only been partially implemented in member states (only a handful have so far implemented the EU ETS Directive 2023/959) does not help and the lack of understanding amongst registry staff of the complexities of the maritime industry stands as perhaps the biggest hindrance to the timely and effective opening of MOHAs. 

With this in mind, WFW has both prepared bespoke clauses to be inserted into charterparties, ship management agreements and MOAs and launched its own EU ETS/FEMREG risk management agreement in order to fill in the gaps that the regulations simply do not address (e.g., the EU ETS costs clause and dispute resolution mechanisms).

First Fuel EU deadline

In the meantime, importantly, the first of many compliance deadlines has just passed pursuant to FEMREG. FEMREG poses an even greater challenge due to its technically complex and pernickety nature with shipping companies required to submit their Fuel EU Monitoring Plans by 31st August 2024 (see our insight here). The European Commission has now released the long awaited FuelEU Monitoring Plan Template to assist with the submission (see here).

FAQs

Whilst the European Commission (“EC”) has now published FAQS for both EU ETS and FEMREG, it is important to remember that these are guidelines only and not legally binding. Nor do they delve into the level of detail that many in the industry are seeking. With a view to shedding more light on the missing detail and particularly on the scope and mechanics of both EU ETS and FEMREG,  WFW has prepared a compliance toolkit consisting of a compliance deadlines checklist; and a table of exemptions that apply under both EU ETS and FEMREG (which you can download here), as well as bespoke EU ETS and FEMREG clauses and agreements. It is important for shipping companies and their investors to be alive to these deadlines as well as to the exemptions when assessing applicability and preparing their compliance strategies.

Exemptions

The list of potentially available exemptions is far from straightforward. Whilst some apply under both EU ETS and FEMREG, others may only be available under one or the other. WFW’s checklist table covers all the available exemptions and divides them into three categories: (1) vessel size and class; (2) voyage types; and (3) maritime activity and ports of call. It can be particularly daunting to work out what constitutes a “small island” exemption, or that of an “Outermost Region”.  Six exemptions are available under (1); ten exemptions are available under (2) and (3). You can view the table of exemptions by downloading our Compliance Toolkit here.

Key Compliance Deadlines

We have also prepared an EU ETS and FEMREG Compliance Deadlines Checklist to assist the industry with their internal planning and budgeting strategies. To access our EU ETS and FEMREG Compliance Deadlines Checklist, download our Compliance Toolkit here.

[1] Full list of MOHAs available here

 

Photo credit: CHUTTERSNAP from Unsplash
Published: 4 September, 2024

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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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Alternative Fuels

KPI OceanConnect: Market volatility reshapes case for alternative bunker fuels

Jesper Sørensen shares how changing market dynamics are reshaping the commercial case for alternative fuels and highlighting the value of fuel flexibility in an increasingly uncertain environment.

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Jesper Sørensen, Global Head of Alternative Fuels and Carbon Markets at KPI OceanConnect

Recent market volatility, geopolitical disruption and tightening carbon regulations are challenging the perception that conventional fuels offer the safest path for shipowners. 

Jesper Sørensen, Global Head of Alternative Fuels and Carbon Markets of KPI OceanConnect, shared with Singapore-based bunkering publication Manifold Times how changing market dynamics are reshaping the commercial case for alternative fuels and highlighting the value of fuel flexibility in an increasingly uncertain environment:  

For years the case for conventional bunker fuels has rested, in part, on familiarity. Owners know how to procure it, use it and build voyage economics around it. Alternative fuels, by contrast, have required a leap of faith – underdeveloped supply chains, high costs and a siloed regulatory backdrop. It’s a familiar tension for many ship owners where the scales have consistently favoured conventional fuels. It was, after all, the safe, known pathway while the green transition matures at its own pace.

Recent market conditions, however, have shown that conventional fuels carry their own version of uncertainty, one that is easy to underestimate in quieter times. Since the Iran War began at the end of February, export terminals across Iraq, Oman, Bahrain and the UAE came under threat and were struck or evacuated within days of each other. The Strait of Hormuz, which carries around a fifth of global oil, has been effectively closed for over a month. Over this time, Brent crude – the global oil benchmark – has traded across a $46 range, between $73 and $119. ICE Gasoil front-month swung more than $400 per tonne in a fortnight. LSMGO briefly disappeared from the Singapore spot market. This is the broader market context every owner has been navigating. It is a difficult environment by any measure but is worth pausing on, because it also changes the conversation around alternative fuels.

Biofuel and methanol markets were also affected. But they moved within a materially narrower range and were largely decoupled from the specific geopolitical shocks driving conventional supply disruption. This meant that the spread between alternatives and conventional fuel narrowed considerably. When EU ETS and FuelEU Maritime compliance costs are also factored in, that spread reduced further still, to the point where alternatives have looked competitive on an all-in basis during this time. That is a different commercial conversation from the one the industry was having even six months ago.

Across the supply chain, the consistent feedback from suppliers, traders and charterers is that the window to lock in biofuel or methanol on terms more favourable than any point in the past eighteen months remains open. Disruption and uncertainty are likely to affect the conventional fuel market for many months after the conflict is resolved – indeed the longer disruption continues, the longer the post-conflict recovery will take – and yet most owners have not seized the biofuel opportunity open to them. 

LNG also warrants attention as the alternative fuel with the deepest fleet commitment. Disruption to Qatari export infrastructure is a significant setback, with a recovery timeline that will be measured in years rather than months. This equation is balanced however, by significant new US export capacity coming online in 2026 and 2027, which will help rebalance availability for European and Asian buyers. The harm done to LNG users highlights an issue that is less about LNG specifically and more broadly about resilience and independence from any single fuel source. Owners with flexibility across fuel types – LNG alongside biofuels, methanol and conventional – will be better equipped to absorb supply shocks wherever they arise.

New fuels are initially expensive, but as production scales, supply chains mature and regulation creates demand certainty prices can be expected to come down. We have watched this curve play out in solar power, in batteries and in biofuels for road transport. Marine alternative fuels are at an earlier stage of the same pathway, but the direction of travel is unambiguous. Today’s premiums reflect a market in its early stages of development, not the cost of a system at scale.

Carbon regulation in the maritime industry has advanced quickly, and while it faces fragmentation and disruption, it warrants attention. Under EU frameworks carbon compliance is no longer a future liability, but a direct cash cost to be settled annually, drawn from the same credit lines that fund bunker procurement and working capital. Managing that cost actively, through alternative fuel procurement during periods of narrow spreads, can have a direct impact on the carbon procurement bill. Active management will free up credit capacity and, in many cases, convert a compliance liability into a surplus that can be traded through FuelEU Maritime pooling. Finance teams need to appreciate this strong commercial argument for pursuing the energy transition now.

Carbon regulation by the International Maritime Organization determines prevailing and future conditions of global regulation, so the meaningful technical progress made at MEPC 84 has provided a clearer sense of where the international framework is heading. Technical work on fuel certification, GFI methodologies and reward mechanisms moved forward, and a broad majority of member states signalled support for the Net-Zero Framework as a foundation. But the Net-Zero Fund remains undefined, key elements of energy efficiency regulation have been delayed and further negotiation is inevitable. In the meantime, the EU’s regime is already in effect. Any owner with regular port calls in Europe is operating inside a binding compliance system today, whatever the longer-term international system looks like.

Looked at this holistically, current conditions remind us that certainty is an illusion. No single fuel can be taken for granted and global regulation that would bring simplicity and clarity for the industry is years away. The owners best positioned to navigate today’s environment are those building genuine flexibility into their fuel strategy, spreading exposure across technologies, supply sources and compliance pathways. The conditions to start doing that, or to go further than they already have, are as favourable now as they have ever been.

 

Photo credit: KPI OceanConnect
Published: 25 June, 2026

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Emissions reporting

StormGeo and OceanScore link emissions data, compliance workflows

Cooperation combines StormGeo’s expertise in operational vessel and emissions data with OceanScore’s expertise in emissions compliance workflows across EU ETS, FuelEU Maritime and UK ETS requirements.

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StormGeo and OceanScore link emissions data, compliance workflows

Weather intelligence and decision support solutions provider StormGeo and Hamburg-based technology platform OceanScore on Wednesday (3 June) said they have deepened their ongoing cooperation through the signing of a collaboration agreement during Posidonia 2026 in Athens on 2 June.

The cooperation combines StormGeo’s expertise in operational vessel and emissions data with OceanScore’s expertise in emissions compliance workflows across EU ETS, FuelEU Maritime and upcoming UK ETS requirements.

Together, the companies aim to help shipping companies seamlessly navigate increasing regulatory complexity more efficiently — from emissions reporting and data validation to compliance exposure management, pooling and financial settlement.

As emissions regulation becomes an increasingly important part of commercial shipping operations, the need for reliable operational data and streamlined compliance processes continues to grow. The cooperation between StormGeo and OceanScore is designed to support shipping companies with more connected, transparent and actionable processes across operational and commercial teams.

“From the outside, companies like StormGeo and OceanScore may sometimes be perceived as competitors because both operate around emissions and compliance workflows,” said Albrecht Grell, Managing Director at OceanScore. 

“But in reality, the industry increasingly needs both perspectives working together: trusted operational emissions data on one side and commercial compliance execution on the other. Our cooperation reflects that shipping companies are no longer looking for isolated solutions — they need connected processes, automated across different systems and reliable decision-making throughout the full compliance chain.”

By connecting validated operational emissions data with commercial compliance management, the cooperation supports workflows across:

  • emissions reporting and validation 
  • compliance management across EU ETS, FuelEU Maritime and upcoming UK ETS requirements
  • exposure visibility and cost transparency
  • pooling, settlement and financial processes 

The cooperation also aims to improve commercial transparency and coordination across operational and commercial stakeholders.

“StormGeo plays a central role in helping shipping companies turn operational vessel and emissions data into trusted, decision-ready insights,” said Espen Martinsen, Chief Commercial Officer at StormGeo. 

“As emissions regulations become more complex, this data is essential for transparent and efficient compliance management. By working with OceanScore, we can help customers connect StormGeo’s validated operational data with commercial compliance processes, creating a more integrated and practical approach to emissions management.”

The signing ceremony took place at the StormGeo booth during Posidonia 2026 in Athens and was attended by representatives from both companies.

Both companies expect the cooperation to continue evolving alongside upcoming regulatory developments, including FuelEU Maritime, EU ETS, the upcoming UK ETS and future emissions-related frameworks affecting global shipping.

 

Photo credit: StormGeo
Published: 4 June, 2026

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