To comply with FuelEU Maritime, shipping companies have to monitor and report the greenhouse gas intensity of the energy used on board their ships and ensure compliance with established limits. This page will outline which ships, voyages, and emissions are included (=scope), who is responsible for compliance with the FuelEU Maritime regulation and who to report to.

Scope

Cargo and passenger ships of or above 5,000 gross tonnage (GT) must monitor the greenhouse gas (GHG) intensity of the energy used:

  • During voyages between European Economic Area (EEA) ports
  • During voyages from a non-EEA port to an EEA port
  • During voyages from an EEA port to a non-EEA port
  • Within EEA ports
  • At berth in an EEA port

Greenhouse Gases and Calculation

The regulation covers the following three greenhouse gases:

  • Carbon dioxide (CO2)
  • Methane (CH4)
  • Nitrous oxide (N2O)

Unlike the EU ETS, which primarily considers 'Tank-to-Wake' emissions, FuelEU Maritime uses a 'Well-to-Wake' approach. This means it accounts for the entire lifecycle of the fuel, including production, transport, and distribution, in addition to combustion on board.

Monitoring and Compliance Targets

Shipping companies must monitor their energy use under the FuelEU Maritime regulation. While the MRV regulation collects data on total emissions, FuelEU specifically regulates the GHG intensity (the amount of GHG emitted per megajoule of energy used).

The required reduction in GHG intensity is implemented according to the following schedule (relative to a 2020 reference level):

  • 2% reduction starting in 2025
  • 6% reduction starting in 2030
  • 14.5% reduction starting in 2035
  • Targets continue to increase every five years up to 80% in 2050

Onshore Power Supply (OPS)

From 2030, containerships and passenger ships have an additional obligation to connect to Onshore Power Supply while at berth in major EEA ports to reduce local emissions to zero.

Who is responsible?

The entity responsible for compliance with the FuelEU Maritime obligations is the shipping company. For FuelEU this is defined as the ISM company.

The ISM company is the organisation or person that has assumed the responsibility for the operation of the ship from the shipowner. This includes all the duties and responsibilities imposed by the  'International Management Code for the Safe Operation of Ships and for Pollution Prevention'. This means that only this ISM company could assume the responsibilities for ETS and MRV obligations from the registered shipowner.

Who to report to? (Administering State)

The reporting process for FuelEU Maritime is primarily handled through independent verifiers and the Administering State.

  • The Verifier: Shipping companies do not report directly to the government for their initial fuel intensity calculations. Instead, they submit their FuelEU Monitoring Plan and annual FuelEU Report to an accredited independent verifier via Thetis. The verifier validates the data and, if the ship complies with the intensity limits, issues the FuelEU Document of Compliance
  • The Administering State: The 'Administering State' is the Member State responsible for oversight and enforcement (including the collection of any FuelEU penalties). To ensure administrative efficiency, the administering State for FuelEU is usually the same as the administering authority for the EU ETS
  • The Netherlands: For shipping companies attributed to the Netherlands based on the European Commission's list, the Dutch Emissions Authority (NEa) acts as the Administering State

The NEa as your competent authority

For your FuelEU Maritime obligations and deadlines, we refer to the website of the European Commission and the EMSA website. It is important to note that the first deadline, the submission of your ship-specific FuelEU Report (FR), with a reporting deadline of 31 January, is earlier than the EU ETS reporting deadline of 31 March.

Compliance with the FuelEU Maritime Regulation relies heavily on private supervision by verifiers and the national accreditation bodies. 

The Dutch Emissions Authority (NEa) is the competent authority for the  following three tasks: 

  1. The NEa can perform additional checks on the monitoring plan, the FuelEU report and the verifier's compliance calculations (Article 17)
  2. The NEa collects the FuelEU penalty (where appropriate, the NEa modifies the FuelEU penalty if inaccuracies are found) and then registers the FuelEU compliance document in the FuelEU database: Article 22 and 23
  3. The NEa decides on a review application when a company disagrees with a decision of the verifier (article 26)

More detailed information

More information on the FuelEU Maritime Regulation and your obligations can be found on the website of the European Commission and the EMSA website: 

The European Commission has developed a comprehensive guidance document to support the implementation of the FuelEU Maritime Regulation. This document builds on the recommendations presented in expert reports produced by the Sustainable Alternative Power for Shipping (SAPS) Subgroup of the European Sustainable Shipping Forum (ESSF).

The European Sustainable Shipping Forum (ESSF) prepared two guidance documents providing technical expertise relevant for the implementation of the FuelEU Maritime regulation. These reports do not reflect the official view of the European Commission, nor are they legally binding:

Please refer to the Biofuels section of the NEa website for information on the requirements to prove compliance with the sustainability criteria allowing for the use of renewable and low carbon fuels in the FuelEU report.