FuelEU Maritime is an EU regulation that caps the greenhouse gas intensity of the energy used by ships above 5,000 gross tonnage calling at EU ports. It has applied since 1 January 2026, and missing the cap costs €2,400 per tonne of VLSFO equivalent.
The legal text is Regulation (EU) 2023/1805. This page explains who it applies to, what it obliges you to prove, what non-compliance costs, and the part most guides skip: how you actually evidence the fuel data behind the numbers.
Who it applies to, and who is responsible
The regulation covers ships above 5,000 gross tonnage calling at ports in the European Union and the European Economic Area, regardless of flag.
Responsibility sits with the holder of the ISM Document of Compliance, which is not always the registered owner. In a time charter it is usually the manager or operator, while the commercial cost of the fuel sits elsewhere. That mismatch is why BIMCO published a dedicated FuelEU clause for time charter parties: the regulation names one responsible party, and the contract has to decide who pays.
What the regulation actually measures
FuelEU does not cap emissions in absolute terms and it does not ban any fuel. The IMO is negotiating a global measure that works the same way, and it is not yet adopted. It caps the greenhouse gas intensity of the energy a ship uses, measured well-to-wake: production, transport and combustion of the fuel, not just what leaves the funnel.
The scope of energy counted is:
- 100% of the energy used on voyages between two EEA ports of call
- 100% of the energy used while at berth in an EEA port
- 50% of the energy used on voyages between an EEA port and a port outside the EEA
Each vessel ends the year with a compliance balance: a surplus if it beat the target, a deficit if it did not.
The compliance calendar
| When | What |
|---|---|
| 1 Jan 2025 | Data collection begins, well-to-wake |
| 1 Jan 2026 | GHG intensity limits apply |
| 31 August | Monitoring plans submitted to the verifier |
| 30 April 2026 | Compliance balance approved in the FuelEU database |
| 30 June 2026 | FuelEU Document of Compliance issued |
Missing a date is not a paperwork problem. The Document of Compliance is what a port state control officer asks for.
What non-compliance costs
€2,400 per tonne of VLSFO energy equivalent of non-compliant energy used, which works out at roughly €58.54 per gigajoule.
Three details make the headline figure worse than it looks.
It escalates. Where a penalty is payable, it increases by 10% for each consecutive reporting period in which a penalty applies. A deficit left unaddressed compounds rather than repeating.
It can end in expulsion. A vessel operating without a valid FuelEU Document of Compliance for two or more consecutive reporting years faces an EU-wide expulsion order, barring it from every EU and EEA port until historic penalties are paid and compliance is verified.
It is per vessel. A fleet does not average out unless you actively pool.
The three ways to close a deficit
- Banking. A surplus in one year can be carried forward to the next
- Borrowing. A limited advance can be taken against next year’s expected surplus, and it is repaid with a penalty factor
- Pooling. Several vessels, which do not have to share an owner, combine their balances so surpluses cover deficits
All three depend on the same thing: verified figures that the FuelEU database will accept. You cannot pool numbers a verifier has not signed off.
The part most guides skip: proving the data
Everything above rests on one assumption, and it is rarely examined. The GHG intensity of your energy is calculated from what you say you bunkered.
The evidence chain is a Bunker Delivery Note for each delivery, a Proof of Sustainability certificate where the fuel is a biofuel or a renewable fuel of non-biological origin, and the monitoring records that tie both to a voyage. If that chain has a gap, the number in the database is an assertion, not a measurement.
This is why the regulation requires an accredited verifier to approve the monitoring plan and the compliance balance. The verifier is not checking your intentions, they are checking whether your documents support your figures.
In practice most operators assemble that chain from PDFs and spreadsheets held by different parties, and reconstruct it months later. It works, until someone asks a question the paperwork cannot answer.
VesselChain records each delivery once, at the moment it happens, signed by the accredited verifier the regulation already requires, and held identically by every partner. Inside a green shipping corridor that matters even more, because five organisations have to agree on one set of numbers with no lead company between them.
FuelEU and EU ETS are not the same thing
They overlap in scope and are often confused. EU ETS puts a price on the CO₂ a ship emits and requires surrendering allowances. FuelEU caps how carbon-intensive the energy itself may be, well-to-wake, and penalises exceeding the cap. A vessel can be fully compliant with one and in breach of the other.
Frequently asked questions
Who is responsible for FuelEU compliance, the owner or the charterer?
The holder of the ISM Document of Compliance is the responsible party under the regulation. Who bears the cost is a contractual matter, which is why BIMCO issued a FuelEU clause for time charter parties.
What is the FuelEU Maritime penalty?
€2,400 per tonne of VLSFO energy equivalent of non-compliant energy, roughly €58.54 per gigajoule. It rises by 10% for each consecutive period in which a penalty applies. Estimate your own exposure with the calculator, or see what compliance software can and cannot prove.
Which ships does FuelEU Maritime apply to?
Ships above 5,000 gross tonnage calling at EU and EEA ports, regardless of flag.
What happens if a ship has no FuelEU Document of Compliance?
After two or more consecutive reporting years without a valid Document of Compliance, an EU-wide expulsion order can be issued, barring the vessel from EU and EEA ports until historic penalties are paid and compliance is verified.
Is FuelEU Maritime the same as EU ETS?
No. EU ETS prices the CO₂ emitted and requires surrendering allowances. FuelEU caps the well-to-wake greenhouse gas intensity of the energy used and penalises exceeding that cap.
