+33 143 227 194 [email protected]
Building Trust: Independent Emissions Verifier

Shipping EU ETS

Shipping EU ETS 

As part of the European Commission’s Fit for 55 legislative package, the EU Emissions Trading System has been amended to incorporate maritime emissions. Effective from 2024, shipowners are required to monitor, report, and surrender EU Allowances for verified GHG emissions. The compliance obligation is being phased in: 

  • 40% of total GHG emissions in 2024 
  • 70% in 2025 
  • 100% by 2026 

Normec Verifavia provides accredited EU ETS verification and compliance solutions, supporting maritime stakeholders in regulatory alignment, efficiency, and sustainability.
 

Request quote

Why choose Normec Verifavia?

  1. Effortless Compliance: Normec Verifavia’s experienced verifiers stay ahead of the Layered EU ETS regulations and updates, ensuring your monitoring plans and emission reports are fully compliant. This proactive approach helps minimize the risk of non-compliance penalties and reporting delays.
  2. Unbiased Expertise: Benefit from Normec Verifavia’s independent, impartial, and regulation-compliant verification services, delivering accurate assessments that ensure full alignment with EU ETS standards.
  3. Human Touch, Backed by Expertise: Our auditors work closely with your team, offering practical guidance and support to ensure compliance with evolving EU ETS regulations, while helping you meet critical reporting deadlines with confidence. 

As of January 2024, the European Union officially included the maritime sector in its Emissions Trading System (EU ETS), marking a pivotal step toward reducing greenhouse gas emissions from shipping. All vessels of 5,000 gross tonnage or more calling at EU ports must now monitor, report, and verify their GHG emissions, with obligations extending to 100% of emissions from intra-EU voyages and 50% from international routes. While this move aligns with the EU’s climate goals, it introduces several challenges for ship operators: 

  • Administrative Burden: Operators must update their Monitoring Plans (MPs) and ensure consistency across MRV (Monitoring, Reporting, Verification) and FuelEU Maritime documentation. This includes detailed procedures for calculating emissions from conventional fuels, biofuels, and RFNBOs (Renewable Fuels of Non-Biological Origin. 
  • Financial Impact: Companies are required to purchase and surrender EU Allowances (EUAs) equivalent to their emissions. With a phase-in period—40% of 2024 emissions in 2025, 70% in 2026, and 100% by 2027—the cost of compliance will steadily rise. 
  • Technical Complexity: Accurately measuring and reporting emissions, especially from alternative fuels, demands robust data systems and verification processes. 
  • Market Uncertainty: Fluctuating EUA prices and evolving regulatory frameworks create uncertainty in budgeting and long-term planning. 

To support shipowners through this transition, Normec Verifavia provides accredited, end-to-end compliance support, enabling operators to meet their obligations with efficiency and confidence. From MRV verification to ETS allowance management, their expertise ensures smooth navigation of the regulatory landscape. The inclusion of shipping in the EU ETS is a bold stride toward a greener future—one that demands collaboration, innovation, and accountability across the global maritime community. 

Phase-in Requirements 

A gradual phase-in applies during the first three years of implementation. 

  • 2024: 40 percent of EU MRV-verified emissions are subject to surrender
  • 2025: 70 percent of EU MRV-verified emissions are subject to surrender
  • 2026 onwards: 100 percent of EU MRV-verified emissions are subject to surrender

The EU ETS covers three greenhouse gases: carbon dioxide (CO₂), methane (CH₄), and nitrous oxide (N₂O). 

Scope of Emissions 

The EU ETS applies to both intra-EU voyages and voyages connecting EU ports with ports outside the EU. 

  • 100 percent ofGHGemissions from voyages and port calls within the EU/EEA 
  • 50 percent ofGHGemissions from voyages entering or leaving the EU/EEA 

To avoid evasive practices, emissions from container ships calling at transshipment ports located outside but within 300 nautical miles of the EU/EEA must also be included in the ETS calculation. 

Derogations and Exemptions 

Certain exemptions are applied under specific conditions. 

  • Ice-class: ships certified with ice-class IA, IA Super, or an equivalent classification are eligible for a 5% dispensation on their annual emissions allowance surrender obligations 
  • Transshipment Ports: To prevent shipowners from reducing EU ETS exposure by rerouting voyages through nearby non-EEA transhipment ports, the EU ETS excludes such stops from the definition of “port of call.” This aims to discourage evasive port calls and the relocation of container transhipment operations outside the EU. A port qualifies as a neighbouring container transhipment port if:
    ➝ Over 65% of its container traffic (in TEU) is transhipment.
    ➝ is located outside the EU but within 300 nautical miles of an EU Member State port.
    ➝ Its country does not implement measures similar to the EU ETS.
    These ports are listed in Implementing Regulation (EU) 2023/2297. Currently, only East Port Said (Egypt) and Tangier Med (Morocco) are included. The list is reviewed biennially, with the next update expected between October and December 2025.
    For voyages involving these ports, the ETS-applicable segment is calculated from the last stop before the transhipment port to the EEA port (or vice versa).
  • Outermost region (OMR): As per COMMISSION IMPLEMENTING DECISION (EU) 2023/2895 Voyages between an EU outermost region and a port of the same Member State: GHGemissions generated during voyages between an EU outermost region and a port within the same Member State are exempt from the requirement to surrender allowances under the EU Emissions Trading System (EU ETS). This exemption also applies to emissions produced while the vessel is at berth during such voyages.
  • Small island exemption: Passenger ships and Ro-Pax ferries operating under transnational public service obligations or contracts established jointly by two EU Member States are exempt from the requirement to surrender GHG allowances for emissions generated during those specific voyages. There are provisions allowing Member States, by means of local legislation, to provide a temporary, total exemption from the EU ETS (until 31 December 2030) to non-cruise passenger and ro-pax ships performing voyages between small islands and ports on the mainland, where these islands have no road or rail link to the mainland and a permanent population of less than 200,000 people. The European Commission intends to publish a list of the islands and ports covered by this exemption.

Company-Level Emissions Reporting 

Shipping companies must report aggregated greenhouse gas emissions data at the company level to their designated administering authority. This reporting must comply with the methodology outlined in Annex II of Regulation (EU) 2015/757 and include emissions from all vessels under the company’s operational control. 

Cost Implications 

The EU ETS introduces substantial financial exposure, requiring shipping companies to acquire and surrender EU Allowances (EUAs) corresponding to their verified emissions. This directly impacts charter party terms, freight pricing, and cost allocation across the maritime supply chain. Accurate, auditable emissions data is critical for financial reconciliation and effective cash flow management among shipowners, charterers, and cargo stakeholders. 

Wonder what we can do for you?

Contact us
Process

  1. Submit Your Monitoring Plan

    Reach out to our team with your Monitoring Plan (MP) and all relevant supporting documentation. We will assist you through the initial submission process and ensure full compliance with the requirements for EU ETS MP Assessment. 

  2. Efficient Data Collection

    Emissions data can be transmitted efficiently via API integration or standardized EU MRV reporting templates, ensuring data integrity, operational efficiency, and full alignment with EU ETS verification and compliance protocols. 

  3. Review & Expert Evaluation

    Our verification specialists perform a comprehensive assessment of both vessel-level and company-wide emissions reports. Each submission is evaluated against EU ETS regulatory standards, applicable technical guidance, and recognized industry practices. The verification process ensures that all reported data is accurate, complete, and consistent with compliance requirements, thereby enabling transparent and reliable emissions reporting. 

  4. Final Verification & Compliance

    Upon successful verification, companies receive an official Verification Report along with a Document of Compliance (DoC), which must be retained onboard each verified vessel and made available for inspection in accordance with EU law and EU ETS regulations. These documents confirm that the submitted emissions data has undergone independent assessment and meets all applicable EU ETS compliance requirements.

Downloads

Regulation (EU) 2023/957 amending EU MRV regulation Amendment to EU ETS directive Commission Implementing Regulation (EU) 2023/2297 of 26 October 2023 identifying neighbouring container transhipment ports Commission Implementing Regulation (EU) 2023/2449 for templates for monitoring plans, emissions reports, partial emissions reports Commission Delegated Regulation (EU) 2023/2776 for the rules for monitoring greenhouse gas emissions and other relevant information from maritime transport Commission Implementing Decision (EU) 2023/2895 for list of transnational public service contracts or transnational public service obligations Commission Implementing Decision (EU) 2024/411, on the list of shipping companies specifying the administering authority
FAQ

Find answers to the most commonly asked questions

What are the Penalties for non-compliance?

Failure by Shipping Companies to comply with their EU ETS obligations can result in penalties, namely: 

  • Shipping Companies that fail to surrender their allowances when due, will, in addition to their surrender obligation for the missing emission allowances, incur an excess emissions penalty of EUR 100 per tonne of GHG equivalent emitted that has not been surrendered. 
  • Failure to comply with the surrender requirements for two or more consecutive reporting periods may result in the issuance of an expulsion order by the competent authority of the Member State of the port of entry with such effect that (1) all Member States, except the flag state, shall refuse entry to all ships operating under that shipping company’s control and, (2) where a ship is flagged in a Member State and it enters one of its ports, the flag state may detain the ship. An expulsion order will remain until the Shipping Company fulfils its emission allowance surrender obligations. 
  • The names of Shipping Companies not complying with EU ETS regulations may also be published. The company-wide applicability of the EU ETS could result in significant consequences for sister ships.

When should partial verification be done?

Partial verification is mandated when a vessel undergoes a change in operational control between shipping companies. In accordance with Article 11(2) of the EU MRV Regulation, the outgoing company must submit a verified partial emissions report to the administering authority within three months of the transfer. 

How are EU Allowances purchased and how much do they cost?

EUAs are traded on platforms such as the European Energy Exchange (EEX). While only the shipping company can hold a Maritime Operator Holding Account (MOHA), charterers are legally obligated to reimburse EUA costs under time charter arrangements, as per Article 3gc of the revised EU ETS Directive.
The BIMCO ETS Clause 2024 is widely adopted to govern EUA cost-sharing and transfer mechanisms in charter party agreements.

How to report in case of SHIFTING OF BERTH?

When a vessel shifts berth within the same port, it is not considered a separate voyage under EU ETS. 

  • Such movements are excluded from voyage reporting because they do not involve a change in port of call. 
  • However, emissions during shifting may still be monitored and included in the total emissions at berth, which are 100% covered under EU ETS. 

What documentation must a bunkering company provide for biofuel to be recognized as sustainable under the EU framework?

To ensure biofuel is classified as sustainable within the EU regulatory framework, the bunkering company must supply: 

  • A Proof of Sustainability (PoS) certificate issued under an EU-recognized voluntary certification scheme (e.g., ISCC, RSB), confirming compliance with the Renewable Energy Directive (RED II). 
  • Mass balance documentation demonstrating traceability of the biofuel batch throughout the supply chain.
  • GHG emissions savings calculations showing compliance with minimum thresholds set by RED II. 
  • Evidence of certification scheme compliance covering environmental and social sustainability criteria. 

These documents collectively verify that the biofuel meets EU ETS and RED II sustainability and traceability requirements. 

Consequences of change in SHIPPING COMPANY?

When a shipping company changes, the new company must update the Monitoring Plan (MP) and notify the verifier for approval. If the change occurs during the reporting period: 

  • Emissions Reporting: The company responsible at year-end reports   emissions for the full year. 
  • Partial Emissions Report: The previous company submits a verified report for its period of responsibility 
    (Jan – change date) within three months. 

What is the reporting protocol if a voyage spans across two EU ETS reporting periods?

  • Emissions from departure until 31 December 2024 are reported under the 2024 reporting period. 
  • Emissions from1 January 2025 until arrival are reported under the 2025 reporting period. 

What happens if a vessel Stops for drydock/repairs?

  • Dry-docking or repair stops are excluded from the definition of a “port of call” under the MRV Regulation. 
  • This means that emissions during the dry dock period are not counted toward the vessel’s EU ETS obligations. 
  • The voyage is considered to pause during dry dock, and emissions reporting resumes once the vessel departs for its next operational voyage. 

Questions?

Our experts are at your service

Contact