The EU ETS shipping obligation began on 1 January 2024. Companies operating vessels of 5,000 gross tonnage and above calling at EU ports must monitor their emissions, report them, and surrender allowances covering a share that rises to 100% from 2026.
This page covers who it applies to, how the phase-in works, what you have to surrender and when, how it differs from FuelEU Maritime, and the part that decides whether any of it holds up: the quality of the underlying data.
Who it applies to
According to the European Commission, the system covers CO₂ emissions from all large ships of 5,000 gross tonnage and above entering EU ports, regardless of the flag they fly. Offshore ships above 5,000 gross tonnage join from 2027.
The scope of emissions counted follows the same logic as the rest of EU maritime regulation, and rests on the same reporting obligations as MARPOL Annex VI:
- 100% of emissions on voyages between two EU ports, and while at berth in an EU port
- 50% of emissions on voyages that start or end outside the EU
The gases covered are CO₂ from 2024, with methane and nitrous oxide added from 2026. For LNG-fuelled vessels that second date matters: methane slip stops being invisible.
The phase-in, and why 2026 is the year it bites
| Emissions year | Share to surrender | Surrender happens in |
|---|---|---|
| 2024 | 40% | September 2025 |
| 2025 | 70% | September 2026 |
| 2026 onward | 100% | September of the following year |
The obligation is always retrospective: you surrender in one year for the emissions of the year before, which is one more reason the underlying fuel record has to hold up a year later. That gap is a cash-flow question as much as a compliance one, because the allowance price when you buy is not the price when you emitted.
What you actually have to do
Four things, in order.
- Monitor. Fuel consumption and emissions per voyage, under an approved monitoring plan
- Report. An annual emissions report, submitted through the EU MRV framework
- Verify. The report is checked by an accredited verifier before it counts
- Surrender. Buy and surrender EU Allowances covering the required share
The shipping company is the responsible party, and as with FuelEU that is often the ISM Document of Compliance holder rather than the registered owner. Who ultimately pays is settled in the charter party, not in the regulation.
EU ETS and FuelEU Maritime are not the same obligation
They apply to the same fleet, use overlapping data and are constantly confused. The difference is what they price.
| EU ETS | FuelEU Maritime | |
|---|---|---|
| What it targets | The CO₂ you emit | The GHG intensity of the energy you use |
| Boundary | Tank to wake | Well to wake |
| What you do | Surrender allowances | Stay under an intensity cap |
| If you fail | You buy more allowances | Penalty of €2,400 per tonne VLSFO equivalent |
| Flexibility | Trade allowances on the market | Bank, borrow or pool your balance |
A vessel can be fully compliant with one and in breach of the other. Burning a fossil fuel efficiently helps your ETS bill and does nothing for your FuelEU balance.
Everything rests on the data, and the data is the weak point
Both regimes calculate from the same raw material: how much fuel you burned, of what type, on which voyage.
An emissions report is only as good as the bunker documentation behind it. Everything upstream of the verifier is paperwork produced by different parties at different moments.
That documentation is a Bunker Delivery Note for each delivery, a Proof of Sustainability where the fuel is renewable, and the monitoring records that connect both to a voyage. Assembled months later from PDFs and spreadsheets, it usually survives an audit. Usually is doing a lot of work in that sentence.
VesselChain records each delivery once, at the moment it happens, signed by the accredited verifier the regulation already requires, and held identically by every party involved. Inside a green shipping corridor that becomes structural, because several organisations have to report from the same numbers with no lead company between them.
Frequently asked questions
Which ships does the EU ETS cover?
Cargo and passenger ships of 5,000 gross tonnage and above calling at EU ports, regardless of flag, since 1 January 2024. Offshore ships above 5,000 gross tonnage are included from 2027.
How much of my emissions do I have to pay for?
40% of emissions reported for 2024, 70% of those reported for 2025, and 100% from 2026 onward.
When is the EU ETS surrender deadline for shipping?
Surrender takes place in September of the year following the reporting year. The first deadline fell in September 2025, covering emissions from 1 January to 31 December 2024.
Does the EU ETS cover methane?
CO₂ has been covered since 2024. Methane and nitrous oxide are added from 2026, which is significant for LNG-fuelled vessels.
Who pays the EU ETS cost, the owner or the charterer?
The shipping company is the responsible party under the regulation, often the ISM Document of Compliance holder. How the cost is allocated between owner and charterer is a contractual matter.
