This article provides general information, not legal, regulatory or financial advice. Requirements depend on the applicable contract, authority and jurisdiction.
The targets
FuelEU Maritime (Regulation (EU) 2023/1805) is the EU's fuel-side counterpart to the EU ETS. Where ETS prices emissions, FuelEU regulates the greenhouse gas intensity of the energy used on board, measured well-to-wake — so upstream emissions from producing the fuel count alongside what comes out of the funnel.
The reference value is 91.16 gCO₂e/MJ, representing the fleet average in 2020. The required reduction against it tightens over time:
| Period from | Required reduction | Implied limit (gCO₂e/MJ) |
|---|---|---|
| 1 Jan 2025 | 2% | ~89.34 |
| 1 Jan 2030 | 6% | ~85.69 |
| 1 Jan 2035 | 14.5% | ~77.94 |
| 1 Jan 2040 | 31% | ~62.90 |
| 1 Jan 2045 | 62% | ~34.64 |
| 1 Jan 2050 | 80% | ~18.23 |
The shape matters. The early years are gentle and the curve steepens sharply from 2035. A vessel ordered in 2026 with a 25-year life will spend most of its career on the steep part of that line, which is why fuel flexibility at build is worth paying for.
Scope
Broadly, ships above 5,000 GT calling at EU/EEA ports: 100% of energy used on intra-EU/EEA voyages and at berth in EU/EEA ports, and 50% of energy used on voyages into or out of the EU/EEA. The alignment with EU ETS scope is deliberate, though the two regimes measure different things — ETS measures emitted tonnes, FuelEU measures intensity of energy.
The penalty mechanism
Where a ship's attained GHG intensity exceeds the limit, a compliance deficit arises and a penalty is payable. The calculation converts the deficit into a VLSFO-energy equivalent and applies a fixed rate — the regulation uses a factor of 2,400 EUR per tonne of VLSFO energy equivalent, with the deficit divided by the attained intensity and multiplied by 41,000.
Two features make this sharper than it first appears:
- Consecutive-year multiplier. A ship in deficit for consecutive periods faces an escalating multiplier, so an unresolved problem compounds.
- The steepening curve. A vessel comfortably compliant in 2025 can be in significant deficit by 2030 with no change in operation.
Published worked examples for a business-as-usual containership put penalties in the region of several hundred thousand euros in 2025, rising into the millions from 2030 onward. Actual figures depend entirely on vessel size, energy consumption and fuel mix. `[VERIFY]` Do not publish a specific figure without recalculating it for a stated vessel profile.
Banking, borrowing and pooling
This is where fleet-level management creates value.
| Mechanism | How it works | Constraints |
|---|---|---|
| Banking | Carry a compliance surplus forward to a later period | Single ship only; not available for consecutive periods |
| Borrowing | Draw an advance surplus from the following period | Borrowed amount multiplied by 1.1 when subtracted next period; capped at 2% of the limit multiplied by energy consumed |
| Pooling | Combine compliance balances across multiple ships | Total pool balance must be positive; a ship using borrowing cannot pool |
Pooling is the significant one. A fleet with some low-intensity tonnage — LNG dual-fuel, biofuel-capable, or shore-power-heavy trading patterns — can offset deficits on conventional ships. The pool need not be limited to a single owner's vessels, which has created a market in compliance surplus.
The optimisation problem is genuine: which ships to pool, in what combination, against what alternative cost of penalty, given that borrowing carries a 1.1 multiplier and cannot be combined with pooling. Across a fleet of any size this is not a manual calculation.
Onshore power supply
From 1 January 2030, containerships and passenger ships above 5,000 GT must connect to onshore power supply while at quay in EU ports covered by the Alternative Fuels Infrastructure Regulation, extending to other EU ports from 1 January 2035.
Exemptions include: port calls of less than two hours, vessels using zero-emission technology on board, unavailability of shore connection, incompatibility, grid stability risk, and emergencies.
For cruise and container operators this is a capital planning item now, not in 2029 — retrofitting shore power connection equipment requires yard time and electrical design work.
What owners and managers should do
- Calculate your current attained intensity per vessel, well-to-wake, using verified fuel data. Most operators are less compliant than they assume once upstream factors are applied.
- Model the 2030 and 2035 positions on the current operating profile. That is where the decisions are.
- Decide the pooling strategy deliberately, including whether to buy or sell surplus externally.
- Do not borrow casually. The 1.1 multiplier and the exclusion from pooling make it an expensive convenience.
- Plan shore power for affected tonnage.
- Write it into charterparties. As with ETS, allocate responsibility for fuel choice and the resulting compliance cost explicitly.
- Fix the data. Fuel by type, energy content, voyage classification, at-berth periods. Everything else follows.
based on Regulation (EU) 2023/1805. Penalty examples are illustrative and depend on vessel-specific data. General information, not legal advice — confirm with your verifier. Reviewed by the Zeaclub Editorial Team, 24 August 2026.
Frequently asked questions
What is the FuelEU baseline?
91.16 gCO₂e/MJ, the 2020 fleet average GHG intensity, measured well-to-wake.
How is the penalty calculated?
From the compliance deficit, converted to a VLSFO energy equivalent, at a rate based on 2,400 EUR per tonne — with an escalating multiplier for consecutive periods in deficit.
Can compliance be pooled between different companies' ships?
Yes, subject to the rules — the pool's total balance must be positive, and a ship using borrowing cannot participate. This has created an active market for compliance surplus.
When does shore power become mandatory?
For containerships and passenger ships above 5,000 GT: 1 January 2030 in AFIR-covered EU ports, and 1 January 2035 in other EU ports, subject to exemptions.