Voyages 

The regulation applies to:

• The entirety of the energy used on voyages from a port of call under the jurisdiction of a member State to a port of call under the jurisdiction of a member State.

• The energy used at berth within a port of call under the jurisdiction of a member State.

• Half of the energy used on voyages departing from or arriving at a port of call under the jurisdiction of a member State, where the last or the next port of call is under the jurisdiction of a third country. 

Greenhouse Gases 

The FuelEU Maritime Regulation covers GHG emissions from WtW. For the TtW, regulation considers not only carbon dioxide (CO₂) emissions but also methane and nitrous oxides. Methane and nitrous oxides are subsequently converted into CO₂ equivalents, multiplied with Global Warming Potential of 100 years (GWP100) which is equal to 28 for methane and 265 for nitrous oxides respectively, as defined in Regulation (EU) 2020/1044.

Penalties

Ships with a higher GHG intensity than the threshold must pay a remedial penalty proportional to their compliance deficit. The compliance deficit is the difference between the reference GHG intensity and the actual one, multiplied with the energy consumption, which is calculated by multiplying the mass of the fuel along with the lower calorific value (LCV) and the electricity delivered at ship. 

Ship Types

FuelEU Maritime applies to all ships above 5,000 gt that serve the purpose of transporting passengers or cargo for commercial purposes.

[EUR FuelEU Penalty= (Compliance Balance / GHGIEactual * 41000) * 2400]

Subsequently, the compliance balance deficit is converted to energy, being divided with the actual GHG intensity of the vessel. The non-compliant energy as calculated, is finally multiplied with a penalty of EUR 2,400 per tonne very low sulfur fuel oil (VLSFO) equivalent energy which is equal to around EUR 0.058 per MJ of non-compliant energy.  

Ships that do not meet the subtarget for RFNBOs shall pay a remedial penalty equivalent to the compliance balance of RFNBOs which is calculated as the difference between the 2 percent of the total energy used on board minus the total energy that comes from RFNBOs, multiplied with the price difference between RFNBOs and fossil fuel compatible per tonne VLSFO. Penalties will be increased for ships that have compliance deficits for either GHG intensity or RFNBOs target for two or more consecutive years.

Noncompliance with OPS requirements imposes a remedial penalty equivalent to EUR 1.5 multiplied with the established total electrical power demand at berth and by the total hours of noncompliance at berth.

Banking/Borrowing/Pooling of compliance 

Banking of Compliance

In case that a ship has a compliance surplus either on the GHG intensity or the subtarget for RFNBOs, the company may bank that compliance balance and use it for the same ship in the following reporting period. In addition, in case the vessel has a compliance deficit in a reporting period, the company may borrow an advance compliance surplus of the corresponding amount from the next reporting period. In the next reporting period, the borrowed compliance surplus must be multiplied by 1.1 and be subtracted from the same ship’s balance. Borrowing of advance compliance is not possible if:

• The compliance balance exceeds more than 2 percent of the threshold GHG intensity multiplied with the energy consumption of the ship.

• Used for two consecutive reporting periods.

Pooling of Compliance

The compliance balance for GHG intensity and subtarget of RFNBOs can be pooled. Pools can consist of vessels of the same or different company, but the allocation of the compliance shall be verified by the same entity. Two different pools can be used for compliance with the GHG intensity target and RFNBOs subtarget. A pool is only possible if:

• Total pooled compliance is positive.

• Ships that had a compliance deficit do not have a higher compliance deficit after the allocation of the pool.

• Ships that had a compliance surplus do not have a compliance deficit after the allocation of the pool. 

Monitoring, Reporting and Compliance

Monitoring and Reporting

The entity responsible for monitoring, reporting and payment of remedial penalties remains the shipping company as defined in Article 3, point (w) of Directive 2003/87/EC. Due to the fact that the purchase of the fuel and the operation of the ship — determining the cargo carried, the route and the speed of the ship — might be assumed by a different entity than the shipping company, the regulation foresees the liability of the latter to be reimbursed for the payment of the remedial penalties.

Shipping company means the shipowner or any other organization 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. 

GHG Intensity of the Fuels

Annex II of FuelEU Maritime Regulation contains default emission factors for fossil fuels, biofuels and RFNBOs. For fossil fuels, the WtT emission factors shall be the default values contained in the relevant Annex. For the TtW phase, companies can either use the default values for methane and nitrous oxides or actual values certified by means of laboratory testing, whereas for CO₂ only the default values.

For biofuels and RFNBOs, FuelEU Regulation refers to RED II Directive. Biofuels and RFNBOs shall meet the sustainability and GHG savings criteria contained in Article 29 of RED II. Biofuels that do not comply with the sustainability and GHG saving criteria or that are produced from food and feed crops, are considered to have the same emission factors as the least favorable fossil fuel pathway for this type of fuel. Sustainable biofuels and RFNBOs can either use the default values as provided in Annex II and RED II Directive or actual values certified under a scheme that is recognized by the commission.

The European Commission’s recent proposal COM(2026) 616 with its annexes sets out a comprehensive revision of the European Union Emissions Trading System (EU ETS), including important updates to the regulatory framework for maritime transport.

Complementing these changes, the related proposal COM(2026) 620 introduces amendments to the EU MRV and FuelEU Maritime Regulations aimed at further streamlining the regulatory framework for shipping. In particular, the proposal seeks to align compliance cycles across the EU MRV, EU ETS and FuelEU Maritime regimes, minimize duplication and regulatory divergences, and strengthen the “monitoring-and-reporting-only-once” principle. Collectively, these measures are expected to reduce the associated administrative burden and costs for shipping companies.

FuelEU Maritime Regulation

1. Single Monitoring, Reporting and Verification Framework

The proposal seeks to establish a unified MRV framework that covers both GHG emissions and the energy used on board by ships supporting compliance under EU MRV, EU ETS and FuelEU Maritime. The expanded MRV framework would include:

• Well-to-wake GHG emissions data

• Fuel and energy consumption data

• Additional FuelEU-related parameters

Shipping companies would submit a single monitoring plan and a single MRV report for each ship under their responsibility. Consequently, verified MRV data would also be used for FuelEU compliance purposes, eliminating duplicate reporting obligations.

2. Alignment of Compliance Timelines

To synchronize FuelEU with the MRV and EU ETS compliance cycle, the proposal requires companies, by 28 February of the verification period, to submit the following to the verifier:

• the MRV Report, containing GHG emissions, energy-use and other relevant monitoring data; and

• the Compliance Balance Report, containing the ship's FuelEU calculations, including the yearly average GHG intensity and the ship’s compliance balance.

This alignment forms part of the proposed "monitoring-and-reporting-only-once" approach, under which MRV, EU ETS and FuelEU Maritime would operate through a common monitoring, reporting and verification framework.

3. Alignment of Responsible Entity

The proposal would align the entity responsible under FuelEU Maritime with the company responsible under the EU MRV and EU ETS frameworks.

This would remove the current divergence between compliance entities and establish a single accountable company across all three regimes.

Next Steps

Both legislative proposals, COM(2026) 616 (EU ETS) and COM(2026) 620 (EU MRV/FuelEU Maritime), will proceed through the ordinary legislative procedure and require adoption by both the European Parliament and the Council before entering into force. The "One Europe, One Market" Roadmap identifies the first quarter of 2027 as a target for agreement on the EU ETS review. Given that COM(2026) 620 is designed to complement and align with the ETS review, the two proposals are expected to be negotiated in parallel. Both acts would enter into force 20 days after publication in the Official Journal.

For the MRV/FuelEU package, the main provisions are expected to apply from 1 January 2029, delivering a single MRV, ETS and FuelEU compliance framework, including a common reporting cycle, harmonized verification rules and a single administering authority structure. Certain Commission empowerment provisions would apply earlier to allow the development of delegated and implemented acts.

The European Commission has also launched a call for feedback on the proposed amendments to the MRV Regulation and the FuelEU Maritime Regulation, available here. The feedback deadline is 3 November 2026. All feedback received will be summarized by the European Commission and presented to the European Parliament and Council to support the legislative debate.

What are the rules that the FuelEU Maritime Regulation imposes?

The FuelEU Maritime Regulation imposes the following three rules:

• From 2025, the GHG intensity of the energy used on board by a ship arriving at, staying within or departing from ports under the jurisdiction of a Member State to gradually decrease over time, by 2% in 2025 to as much as 80% by 2050; 

• From 2030, an obligation for passenger ships and containerships to use on-shore power supply (OPS) for all electricity needs while moored at the quayside in major EU ports (Ten-T ports); 

• The 2% of the energy used on board by a ship from 1 January 2034, to be covered from Renewable Fuels of non-Biological Origin (RFNBOs), only if the share of RFNBOs in the energy mix for the reporting period 2031 is less than 1%

Does the FuelEU Maritime Regulation apply to the entirety of the maritime transport in the EU?

The FuelEU Maritime Regulation applies to all ships above 5,000 GT that serve the purpose of transporting passengers or cargo for commercial purposes, regardless of their flag, in respect of:

• The energy used during their stay within a port of call under the jurisdiction of a Member State;

• The entirety of energy used on voyages from a port of call under the jurisdiction of a Member State to a port of call under the jurisdiction of a Member State;

• Half of the energy used on voyages arriving at or departing from a port of call under the jurisdiction of a Member State, where the previous or the next port of call is under the jurisdiction of a third country.

• Half of the energy used on voyages arriving at or departing from a port of call located in an outermost region under the jurisdiction of a Member State.

Who will be the responsible entity for compliance with the FuelEU Maritime?

The entity responsible for compliance with FuelEU Maritime Regulation must be the entity that is responsible for compliance of the ship with the International Safety Management Code, thus the ISM Company. In practice, this entity can be either the shipowner, or any other entity organization and person, distinct from the shipowner.

Where the shipowner is responsible for compliance of the ship with the ISM Code, there is no “ISM company” distinct from the shipowner. In this case, the shipowner is also the “ISM Company” and thus the entity responsible for compliance with the FuelEU Maritime Regulation.

How are the FuelEU Maritime Regulation and the extension of the EU Emissions Trading System (ETS) linked?

Both regulatory frameworks are complementary in the sense that they address the two main approaches to reducing greenhouse gas emissions from shipping:

• The EU ETS aims to improve the energy efficiency through a cap-and-trade CO2 pricing system 
• The FuelEU Maritime Regulation aims to promote the use of decarbonized energy/low-to-zero carbon fuels

What are the differences between EU ETS and FuelEU Maritime?

The EU ETS is considered an economic Market-based Measure (MBM) and targets the Tank-to-Wake (TtW) emissions of vessels. The penalty for each tonne of CO2 emitted is not a fixed value but depends on the market dynamics, the price of EUA. 

The FuelEU is a technical measure and had three targets, to reduce the Well-to-Wake (WtW) GHG intensity of the energy used onboard, use of onshore power supply at berth for containerships and passenger ships, and increase the uptake of RFNBOs. The remedial penalty for compliance with the Regulation is based on a fixed price.

What is the definition of “port of call”?

“Port of call” means a port where ships stop to load or unload cargo or to embark or disembark passengers. Noting this, what is not considered as port of call is:

• Stops for the sole purpose of refueling, obtaining supplies, relieving the crew, going into dry-dock or making repairs to the ship, its equipment or both; 

• Stops in port because the ship is in need of assistance or in distress;

• Ship-to-Ship (STS) transfers carried out outside ports;
• Stops for the sole purpose of taking shelter from adverse weather or rendered necessary by search and rescue activities;
• Stops of containerships in a neighboring container transhipment port. By means of Implementing Acts, the European Commission shall establish a list of container transhipment ports, and update it every 2 years. A transshipment port is a neighboring container port less than 300 nautical miles from an EU port, where the share of containers, measured in 20 FEU, exceeds 65% of the total container traffic of that port during the most recent 12-month period. The first list has been published with the Implementing Regulation (EU) 2023/2297, for the purpose of the EU ETS Directive, and contains:
  •         East Port Said, Egypt;
  •         Tanger Med, Morocco.

Can a ship that received surplus through a pool, bank it for future years?

Yes, when a ship has a compliance surplus (compliance balance with a positive value) either after calculating the adjusted compliance balance for a reporting period, or after participating in a pool, the company can bank it for the subsequent reporting periods. When calculating the adjusted compliance balance, the banked compliance surplus may be added to the initial compliance balance. The following points apply to banking:

• A banked surplus does not have an expiration date, which means that it can be applied indefinitely until it's used up indefinitely.
• Banking is allowed to be done together with pooling in the same year (any remaining surplus after participating in a pool may also be banked).
• At company's request, the verifier shall record the banking of the compliance surplus in the FuelEU report.

Will the FuelEU Maritime Regulation apply to European Economic Area (EEA) countries and ports (Iceland, Norway and Lichtenstein)?

The FuelEU Maritime Regulation has EEA relevance. Following its incorporation into the EEA Agreement, the Regulation will also apply to port calls in Iceland and Norway (with the exception of ports in Svalbard, which are outside the scope of the EEA Agreement).

Norway's Ministry of Climate and Environment has announced that the Regulation may enter into force in Norway no earlier than 1 January 2028. The full announcement is available here.

Until the Regulation is incorporated into the EEA Agreement and implemented in the relevant national legislation, ports in Norway and Iceland will continue to be treated as third-country ports for FuelEU Maritime purposes.

Liechtenstein, although an EEA State, is landlocked and has no seaports. As a result, the Regulation will only be relevant to Liechtenstein where a shipping company subject to FuelEU Maritime is established there.