EU ETS Maritime Scope and Phase-In, 2024 to 2030

The maritime scope of the EU Emissions Trading System is the set of rules in Articles 3ga to 3gg of Directive 2003/87/EC, inserted by Directive (EU) 2023/959, that decides which ships, voyages and gases owe EU allowances from 1 January 2024, and how fast the obligation rises to 100%. Ships of 5,000 GT and above carrying cargo or passengers commercially surrender allowances for 100% of emissions between two EU ports and at berth, and 50% on voyages to or from a non-EU port. The surrender share was 40% of 2024 emissions and 70% of 2025, and is 100% from 2026, the year methane and nitrous oxide join CO2. Offshore ships of 5,000 GT and above enter in 2027, and four surrender derogations run to 31 December 2030.

This article covers the scope and phase-in mechanics. The wider regime, allowance economics and market context are in EU ETS for shipping .

Legal basis: Directive (EU) 2023/959 and the MRV amendments

Maritime transport entered the EU ETS through two acts adopted in Strasbourg on 10 May 2023 and published in the Official Journal (OJ L 130) on 16 May 2023. Both entered into force on 5 June 2023. Directive (EU) 2023/959 amends the ETS Directive, 2003/87/EC; Member States had to transpose it by 31 December 2023 and apply it from 1 January 2024. Regulation (EU) 2023/957 amends the EU MRV Regulation , Regulation (EU) 2015/757, so that the monitoring data it produces can carry a surrender obligation.

The ETS is a regional overlay on the international baseline. At IMO level, MARPOL Annex VI Reg.27 requires ships of 5,000 GT and above to report fuel consumption to the IMO Data Collection System , and Reg.28 rates their carbon intensity under the CII scheme. Neither puts a price on a tonne of CO2. The global pricing measure, the IMO Net-Zero Framework , was approved at MEPC 83 in April 2025 and has not been adopted: the extraordinary session convened to adopt it adjourned in October 2025 and is scheduled to resume on 4 December 2026.

The maritime chapter of the amended Directive consists of seven articles and a set of amended general provisions:

Directive (EU) 2023/959 was incorporated into the EEA Agreement by EEA Joint Committee Decision No 335/2023 of 8 December 2023, which entered into force on 30 December 2023 with an EEA compliance date of 1 January 2024.

The detailed rules sit in Commission acts adopted in late 2023. Delegated Regulation (EU) 2023/2776 sets the monitoring rules for greenhouse gases, including methane slip. Delegated Regulation (EU) 2023/2849 governs the company-level aggregated emissions data, and Delegated Regulation (EU) 2023/2917 governs verification, verifier accreditation and approval of monitoring plans by administering authorities. Implementing Regulation (EU) 2023/2599 deals with the administration of shipping companies. The Commission put maritime transport at “around 14% of total EU transport emissions, or around 4% of total EU CO2 emissions” in the explanatory memorandum to proposal COM(2026) 616.

EU ETS ships in scope: 5,000 GT and commercial carriage

A ship is in the maritime ETS when it is of 5,000 GT and above and is performing voyages “for transporting for commercial purposes cargo or passengers”, the wording of MRV Article 2(1) as replaced by Regulation (EU) 2023/957. Annex I to Directive 2003/87/EC adopts the MRV activity as the ETS activity, so the two scopes start from the same ship population. Gross tonnage is measured under the 1969 Tonnage Convention , per MRV Article 3(e).

The threshold wording changed in 2023. The original Regulation (EU) 2015/757 covered ships “above 5 000 gross tonnage”; since Regulation (EU) 2023/957 it reads “5 000 gross tonnage and above”, matching MARPOL Annex VI Regs 27 and 28. A ship of exactly 5,000 GT is in.

MRV Article 2(2) excludes “warships, naval auxiliaries, fish-catching or fish-processing ships, wooden ships of a primitive build, ships not propelled by mechanical means, or government ships used for non-commercial purposes”. The list is closed: search and rescue craft, research ships and yachts are not named, so each turns on whether it carries cargo or passengers for commercial purposes.

Flag is irrelevant to scope. A container ship under any flag state calling at Rotterdam is in; an EU-flagged bulk carrier trading only between Brazil and China is not, because it never makes an EU port call. The ship types in scope from 2024 include oil tankers , LNG carriers , passenger ships , ro-ro and ro-pax ships , bulk carriers, container ships and general cargo ships , all at 5,000 GT and above.

Two MRV-only bands were added from 1 January 2025 and carry no surrender obligation today:

• Article 2(1a): general cargo ships and offshore ships below 5,000 GT but not below 400 GT.
• Article 2(1b): offshore ships of 5,000 GT and above. These enter the ETS on 1 January 2027.

The Commission’s carbon market report COM(2025) 735 of 3 December 2025 counted 3,313 shipping companies and 13,627 ships in MRV scope for 2024.

EU ETS territorial scope: 100% intra-EU and at berth, 50% to or from a third country

Article 3ga(1) allocates a voyage’s emissions to the ETS by where its two ports of call sit. The Directive refers to ports of call “under the jurisdiction of a Member State”, so it is the port’s legal location that matters, not the ship’s position when the fuel was burnt.

The 50% share on a third-country leg is a flat factor. It does not depend on distance sailed inside EU waters, so a Tarifa to Tangier ferry crossing and a Rotterdam to Singapore passage both count at half. In 2024 the rule removed 48.6 Mt of the 138.3 Mt CO2 reported under MRV scope, according to COM(2025) 735.

At-berth emissions count at 100% whatever the voyage share. Auxiliary engine and boiler fuel burnt alongside Hamburg is fully in, even when the ship arrived from New York at 50%. Shore power therefore reduces the ETS bill in proportion to the fuel it displaces at berth.

Article 3gg(2) links the 50% share to IMO progress: if the IMO has not adopted a global market-based measure at least comparable to the ETS by 2028, the Commission must report on extending coverage beyond 50% of emissions on voyages to and from third countries. That report has not yet fallen due.

Neighbouring container transhipment ports

Article 3ga(2) stops a container line from resetting the 50% share with a call just outside the Union. Without it, a Shanghai to Rotterdam service could call at a North African hub, turning one long 50% voyage into a long 0% voyage and a short 50% voyage. The Commission lists neighbouring container transhipment ports meeting four criteria:

1. the share of transhipment of containers exceeds 65% of total container traffic, measured in TEU, over the most recent 12-month period;
2. the port is outside the Union;
3. it is less than 300 nautical miles from a port under the jurisdiction of a Member State;
4. the third country does not effectively apply measures equivalent to the Directive.

A container ship’s stop at a listed port is excluded from “port of call” by Article 3(z). The listed port is not treated as an EU port; the stop simply does not break the voyage. A Shanghai to Tanger Med to Rotterdam rotation is therefore one Shanghai to Rotterdam voyage at 50%. A container feeder loading at Tanger Med is not making a port call there either; its voyage runs from its previous port of call, so a Valencia to Tanger Med to Rotterdam feeder rotation is one Valencia to Rotterdam voyage at 100%.

Commission Implementing Regulation (EU) 2023/2297 of 26 October 2023 lists two ports, applying from 1 January 2024: East Port Said in Egypt, at the northern entrance of the Suez Canal near Port Said , and Tanger Med in Morocco. The exclusion applies only to container ships. A tanker or bulk carrier calling at either port makes an ordinary third-country port call. Article 3ga(2) requires the list to be updated by 31 December every two years. FuelEU Maritime carries its own twin list, set by Implementing Regulation (EU) 2025/1127 of 6 June 2025, which names the same two ports.

EU ETS port of call and voyage definitions

A voyage under Article 3(x) takes the MRV definition: “any movement of a ship that originates from or terminates in a port of call”, in MRV Article 3(c) as replaced by Regulation (EU) 2023/957. A port of call under Article 3(z) is “the port where a ship stops to load or unload cargo or to embark or disembark passengers, or the port where an offshore ship stops to relieve the crew”.

Article 3(z) then excludes stops made for these purposes alone:

• refuelling;
• obtaining supplies;
• relieving the crew of a ship other than an offshore ship;
• going into dry-dock or making repairs to the ship, its equipment or both;
• stopping in port because the ship needs assistance or is in distress;
• “ship-to-ship transfers carried out outside ports”;
• seeking shelter from adverse weather or performing search and rescue activities;
• stops of container ships in a listed neighbouring container transhipment port.

The practical effect is that commercial calls, not physical stops, cut a voyage into segments. A tanker that loads at Primorsk, bunkers off Skagen and discharges in Houston performs one Primorsk to Houston voyage outside scope, because neither port of call is in a Member State, even though it burnt fuel at anchor in Danish waters. A tanker that loads at Rotterdam, takes bunkers at Gibraltar and discharges at Houston performs one Rotterdam to Houston voyage at 50%, because the Gibraltar stop is refuelling only.

Ship-to-ship transfers carried out outside ports never create a port of call, whether they happen in a Member State’s territorial sea or on the high seas. A crude cargo lightered offshore before discharge in Rotterdam is one voyage from the load port to Rotterdam for the mother ship; for the lightering vessel, the voyage runs from its last port of call to Rotterdam.

A shipyard call for dry-docking or repair is not a port of call when it is made for that purpose alone. If the ship also loads or discharges cargo at the yard berth, the cargo operation makes it a port of call. The voyage data that shipping companies record under MRV Annex I and II, as amended by Delegated Regulation (EU) 2023/2776, carries these distinctions into the monitoring plan.

EU ETS greenhouse gases for shipping: CO2 from 2024, methane and nitrous oxide from 2026

The Annex I row for maritime transport reads: “Carbon dioxide. From 1 January 2026, methane and nitrous oxide.” So 2024 and 2025 surrender obligations are calculated on CO2 alone. From the 2026 emissions year, surrender, due by 30 September 2027, is calculated on CO2 equivalent across all three gases.

CH4 and N2O are converted using 100-year global warming potentials of 28 for methane and 265 for nitrous oxide. The values sit in the Annex to Commission Delegated Regulation (EU) 2020/1044. Delegated Regulation (EU) 2023/2776, amending MRV Annex I, applies them to shipping. Directive (EU) 2023/959 does not fix the numbers itself: Article 14(1) leaves it to the monitoring acts to “specify the global warming potential of each greenhouse gas”.

Methane matters most for LNG-fuelled ships . The monitoring formula in Delegated Regulation (EU) 2023/2776 includes a slip coefficient covering fugitive and slipped methane, so unburnt fuel passing through the engine is counted, not only the CO2 from combustion. Engine-type slip values are covered in methane slip and N2O and the methane slip deep dive . At GWP 28, each tonne of slipped methane on an intra-EU voyage costs 28 allowances from 2026.

N2O is a smaller item for conventional diesel engines, but it rises where selective catalytic reduction runs outside its temperature window or where ammonia is burnt as fuel. Each tonne costs 265 allowances.

Article 9 of the amended Directive adds allowances to the cap to match each extension: 78.4 million for maritime transport in 2024, then further increases from 1 January 2026 for methane and nitrous oxide and from 1 January 2027 for offshore ships. The 2026 and 2027 increases are directed to the Innovation Fund under Article 10a(8), described in EU ETS allowance allocation for shipping and the Innovation Fund’s maritime eligibility .

EU ETS surrender phase-in: 40% for 2024, 70% for 2025, 100% from 2026

Article 3gb sets the phase-in in three steps: shipping companies surrender allowances for “(a) 40 % of verified emissions reported for 2024”, “(b) 70 % of verified emissions reported for 2025” and “(c) 100 % of verified emissions reported for 2026 and each year thereafter”. Allowances corresponding to the difference in 2024 and 2025 are cancelled rather than auctioned.

The phase-in reduces surrender, not reporting. The verified emissions report under MRV still states 100% of in-scope emissions, after the 50% and 100% shares are applied. A ship emitting 10,000 t CO2 on intra-EU voyages in 2024 reported 10,000 t and surrendered 4,000 allowances by 30 September 2025. The same emissions in 2026 require 10,000 allowances by 30 September 2027, before any methane or nitrous oxide is added.

The first surrender year closed on 30 September 2025. According to COM(2025) 735, shipping companies surrendered for more than 99% of their 2024 surrender requirements by that deadline. The 2025 emissions year, at 70%, was due on 30 September 2026. Primary auction clearing prices in 2024 ranged from EUR 49.50 on 23 February to EUR 75.35 on 3 June, averaging EUR 64.74 over the year (COM(2025) 735); the price mechanics are covered in EUA market mechanics for shipping .

Nothing in Directive 2003/87/EC allows the 100% step to be deferred. The Commission proposal COM(2026) 616 of 17 July 2026 does not amend Article 3gb.

EU ETS offshore ships and the 400 to 5,000 GT band

Offshore ships of 5,000 GT and above follow a separate timetable. The Annex I maritime row excludes the activities covered by MRV Article 2(1b) “until 31 December 2026”. These ships began MRV monitoring on 1 January 2025 and enter the ETS on 1 January 2027, surrendering 100% of their 2027 emissions by 30 September 2028. Article 3gb gives them no 40% or 70% years: the phase-in is fixed to calendar years 2024 and 2025, which have passed.

Offshore ships differ from cargo ships in their port-of-call test. Article 3(z) counts a stop “where an offshore ship stops to relieve the crew” as a port of call. For a cargo ship, a crew-change-only stop is excluded. Work at an offshore installation or wind farm is not a port call under the present text, which is why COM(2026) 616 proposes offshore-specific rules, described below.

Offshore ships and general cargo ships of 400 to 5,000 GT have reported under MRV Article 2(1a) since 1 January 2025 and are outside the ETS. Article 3gg(5) requires the Commission to report by 31 December 2026 on including ships, including offshore ships, below 5,000 GT but not below 400 GT. The proposal is already on the table: COM(2026) 616 would bring certain categories of ships in that band into Annex I, while leaving passenger and ro-pax ships below 5,000 GT to a further report due by 31 December 2031. Until the Parliament and the Council adopt that proposal, the 5,000 GT line is the ETS threshold for every ship type. The band is covered in EU MRV for ships of 400 to 5,000 GT , and the 2027 offshore entry in EU ETS for offshore ships from 2027 .

EU ETS maritime derogations to 31 December 2030: Article 12(3-b) to (3-e)

Article 12 of Directive 2003/87/EC carries four maritime derogations, all ending on 31 December 2030. Each one reduces the surrender obligation only. Emissions under a derogation are still monitored, verified and reported under the MRV Regulation.

The outermost regions derogation keeps domestic lifeline trades inside the Member State. A Canary Islands to Cadiz voyage and a Madeira to Lisbon voyage are derogated; a Canary Islands to Madeira voyage, which links outermost regions of two different Member States, is not, and counts at 100% because both ports are in the Union.

The island and public service lists are in Commission Implementing Decision (EU) 2023/2895 of 19 December 2023. Its Annex II names one transnational link, between Cyprus (Larnaca, Limassol) and Greece (Piraeus). Implementing Decision (EU) 2024/1113 added the Åland Islands ports of Berghamn, Långnäs and Mariehamn, applying from 1 January 2024, and Implementing Decision (EU) 2024/2924 added further Danish and Greek islands and ports from 1 January 2025. A route is derogated only once its island and port appear in the Decision as amended.

The ice-class relief is route-neutral. A Finnish-Swedish ice class IA ship trading in the Baltic, the sea covered by the Helsinki Convention , surrenders 95% of its in-scope emissions whether or not it met ice that year, and the same ship trading to the Mediterranean receives the same relief.

Cruise ships are expressly outside the 12(3-d) island derogation: a cruise ship calling at a small Greek island owes allowances on the ordinary 100% or 50% basis. The derogations are covered in EU ETS maritime derogations to 2030 .

EU ETS scope compared with FuelEU Maritime

FuelEU Maritime , Regulation (EU) 2023/1805, applies from 1 January 2025 to the same broad fleet and uses the same MRV data, but its scope differs from the ETS in four places:

The two regimes charge different things. The ETS prices the tonnes emitted in scope; FuelEU penalizes the gap between the energy’s GHG intensity and the intensity target . A fossil-fuelled ship meeting its FuelEU target through pooling still surrenders allowances on every in-scope tonne. The FuelEU penalty structure and the ETS obligation run side by side, a point developed in EU ETS and FuelEU Maritime: double compliance .

On renewable fuels, Article 14(1) of Directive 2003/87/EC zero-rates emissions from biomass that meets the sustainability criteria and requires the monitoring acts to account for renewable fuels of non-biological origin while avoiding double counting. A ship burning certified biofuels therefore reduces its ETS surrender; FuelEU gives RFNBOs a reward factor of 2 until 31 December 2033 (Regulation (EU) 2023/1805 Art 5(1)).

Who surrenders EU ETS allowances: the shipping company and cost pass-through

The obligation sits with the shipping company under Article 3(w): “the shipowner or any other organisation 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 ISM Code . That is the entity named on the Document of Compliance, with one qualification.

Implementing Regulation (EU) 2023/2599 Article 1 adds a mandate requirement. A manager or bareboat charterer holding the ISM responsibility carries the ETS obligations only if “duly mandated by the shipowner”, evidenced by a document signed by both and supplied to the administering authority. The mandate is the condition on which a third-party manager holding the ISM Document of Compliance takes over the ETS obligations from the shipowner.

Article 3gc lets the cost move without moving the obligation. Member States must ensure that, where “the ultimate responsibility for the purchase of the fuel, or the operation of the ship, or both” lies with another entity under a contract, the shipping company “is entitled to reimbursement from that entity for the costs arising from the surrender of allowances”. The operation of the ship is defined by reference to determining the cargo carried, the route and the speed. The provision is covered in EU ETS cost pass-through under Article 3gc .

Contract forms fill in the mechanics. Under a time charter party , the BIMCO ETS Allowances Clause 2022 puts the allowances on the party that buys the fuel:

• charterers “shall provide and pay for the Emission Allowances corresponding to the Vessel’s emissions under the scope of the applicable Emission Scheme”;
• owners notify the previous month’s quantity within the first seven days of each month, with calculations and supporting data;
• charterers transfer the allowances into owners’ nominated account within seven days of notification;
• for the final month, owners notify an estimate no later than 14 days before expected redelivery, trued up in allowances within seven days;
• for off-hire periods, charterers may offset the allowances or require their return;
• if charterers fail to transfer, owners may suspend performance on five days’ notice, with the ship remaining on hire.

The clause transfers allowances in kind, monthly. It has no cash alternative, no reference price and no interest provision. It is written to be added to forms such as NYPE 2015 , and it applies only where incorporated.

For voyage charters , BIMCO issued three ETS clauses in 2023: a Freight clause, a Surcharge clause and a Transfer of Allowances clause. The allowance cost on a voyage charter is separate from the fuel element of freight, the bunker adjustment factor . Liner carriers recover it through emissions surcharges : Maersk’s surcharge from 1 January 2024 was based on an average EUA price of EUR 81.54 for 16 August to 15 November 2023 and set EUR 39 per 40-foot dry container from the Far East to North Europe in its EUR tariff, alongside a USD tariff for the same trade. Long-term contracts of affreightment need the same allocation written in, because Article 3gc gives a right to reimbursement but not a price or a timetable.

EU ETS administering authority, reporting and surrender deadlines

Each shipping company is administered by one Member State under Article 3gf(1):

1. the Member State in which it is registered;
2. if not registered in a Member State, the Member State with “the greatest estimated number of port calls from voyages performed by that shipping company in the preceding four monitoring years” within the Article 3ga scope;
3. if it made no in-scope voyage in those four years, the Member State where one of its ships started or ended its first in-scope voyage.

The Commission publishes the attribution list: Implementing Decision (EU) 2024/411 of 30 January 2024, with its Annex replaced by Implementing Decision (EU) 2025/2452 of 5 December 2025 from 1 January 2026. Article 3gf(2) sets updates before 1 February 2026 and every two years after. Under Implementing Regulation (EU) 2023/2599 Article 3, the country of registration is the one recorded in THETIS-MRV , the reporting platform run by the European Maritime Safety Agency , and port-call counts come from SafeSeaNet. Attribution is covered in EU ETS administering authority attribution .

The annual cycle for a shipping company runs:

Allowances are held in an account in the Union Registry, described in Union Registry maritime accounts ; the transfer and surrender steps are in EU ETS surrender mechanics for shipping . Allowances surrendered by shipping companies are ordinary EU allowances, fungible with those used by installations.

When a ship changes company during the year, through sale , a new bareboat charter or a change of manager, MRV Article 11(2) as replaced by Regulation (EU) 2023/957 requires the previous company to submit a verified emissions report for its period as close as practicable to the change and within three months. Each company’s aggregated data states “the period during which the ship was under the company’s responsibility” (Delegated Regulation (EU) 2023/2849). Each company surrenders for its own period; the split follows actual voyages and at-berth periods, not calendar days.

EU ETS penalties and the expulsion order: Article 16

Article 16(3) sets the excess emissions penalty at “EUR 100 for each tonne of carbon dioxide equivalent emitted for which the operator … has not surrendered allowances”, and Article 16(3a) applies it to shipping companies. Paying the penalty does not release the company from surrendering the missing allowances “when surrendering allowances in relation to the following calendar year”. Article 16(4) indexes the EUR 100 “in accordance with the European index of consumer prices”.

Article 16(2) requires Member States to ensure the publication of the names of shipping companies in breach of their surrender obligations.

Article 16(11a) adds a port-access sanction specific to shipping. Where a shipping company “has failed to comply with the surrender obligations for two or more consecutive reporting periods, and where other enforcement measures have failed to ensure compliance”, the competent authority of the Member State of the port of entry may issue an expulsion order after hearing the company. Every Member State other than the flag Member State then refuses entry to the company’s ships, and a flag Member State detains the ship. The rule applies “without prejudice to international maritime rules applicable in the case of ships in distress”. The MRV Regulation carries a parallel expulsion order for two consecutive periods of MRV non-compliance (Regulation (EU) 2015/757 Art 20(3) as amended).

Enforcement runs through the administering authority and, for access, through port state control channels. Member State penalty practice for other breaches, such as late reporting, is in EU ETS enforcement: per-incident administrative cases .

EU ETS maritime review clauses and the 2026 Commission proposal

Article 3gg sets five review points:

• 3gg(1): if the IMO adopts a global market-based measure, the Commission reports within 18 months of adoption and before the measure becomes operational, on its ambition, environmental integrity and coherence with the ETS, “while avoiding any significant double burden”, with a legislative proposal where appropriate.
• 3gg(2): if the IMO has not adopted a measure at least comparable by 2028, a report on covering more than 50% of emissions on voyages to and from third countries.
• 3gg(3): biennial monitoring, from 2024, of evasion, transport cost increases, market distortions, port traffic and competitiveness.
• 3gg(4): by 30 September 2028, an assessment of extending the second subparagraph of Article 3ga(3) beyond 31 December 2030.
• 3gg(5): by 31 December 2026, a report on including ships of 400 to 5,000 GT, offshore ships included.

The IMO trigger has not fired. The Net-Zero Framework, approved at MEPC 83 in April 2025 as a set of amendments to MARPOL Annex VI, was not adopted at the extraordinary session MEPC/ES.2 in October 2025. The session is scheduled to resume on 4 December 2026, subject to confirmation by MEPC 85 (30 November to 3 December 2026). Article 3gg(1) requires IMO adoption, not approval, so no Commission report is yet due. The IMO GHG Strategy sets the targets any global measure is intended to meet.

The Commission’s proposal COM(2026) 616 of 17 July 2026, procedure 2026/0212(COD), is a legislative revision of the maritime chapter. It is a proposal: it has not been adopted by the European Parliament and the Council and changes nothing in force. Its maritime elements include:

• extension of the Article 12(3-b) to (3-e) derogations from 31 December 2030 to 31 December 2035;
• offshore worksites treated as ports of call, with offshore-specific scope rules in Article 3ga(1);
• an annual, not biennial, list of neighbouring container transhipment ports, with revised criteria;
• inclusion of certain categories of ships of 400 to 5,000 GT through Annex I, with passenger and ro-pax ships below 5,000 GT left to a report by 31 December 2031;
• a new surrender derogation for container ships of 10,000 TEU and above on voyages over 300 nautical miles, running to 31 December 2035;
• a new Article 3gaa mechanism reserving 110 million allowances to 2040;
• an amended Article 3gg addressing double payment where a global IMO measure applies.

A companion proposal, COM(2026) 620, amends the MRV Regulation and FuelEU Maritime to match. The file is tracked in the 2026 EU ETS maritime review proposal .

Calculating the EU ETS surrender obligation

The surrender obligation for a shipping company in emissions year \(y\) combines the phase-in, the voyage share, the gases in scope and any ice-class relief:

where:

• \(A(y)\) is the number of allowances to surrender for year \(y\), one allowance per tonne of CO2 equivalent;
• \(k(y)\) is the phase-in share under Article 3gb: 0.40 for 2024, 0.70 for 2025, 1.00 from 2026;
• \(r_{\text{ice}}\) is 0.95 for a ship with ice class IA or IA Super, or an equivalent ice class under HELCOM Recommendation 25/7, until 31 December 2030 (Art 12(3-e)), and 1.00 otherwise;
• \(v\) runs over the voyages and port stays of every ship for which the company is responsible, for the period it is responsible;
• \(f_v\) is the share under Article 3ga(1): 1.00 for a voyage between two Member State ports of call and for time within a Member State port of call, 0.50 for a voyage between a Member State port of call and a third-country port of call, 0 for a voyage derogated under Article 12(3-b) to (3-d), and 0 outside scope;
• \(G(y)\) is the set of gases: CO2 for 2024 and 2025; CO2, CH4 and N2O from 2026;
• \(\text{GWP}_g\) is 1 for CO2, 28 for CH4 and 265 for N2O (Delegated Regulation (EU) 2020/1044 via Delegated Regulation (EU) 2023/2776);
• \(E_{g,v}\) is the verified mass of gas \(g\) emitted on voyage or port stay \(v\), in tonnes.

The ice-class factor is applied per ship; the formula shows it outside the sum for a single-ship case.

Worked example: one container ship, 2025 and 2026

A container ship of 90,000 GT without an ice class reports these verified emissions for 2025, in the illustrative figures below:

• Voyages between two Member State ports: 8,000 t CO2
• Voyages between a Member State port and a third-country port: 24,000 t CO2
• At berth in Member State ports: 600 t CO2
• Voyages between two third-country ports: 15,000 t CO2 (outside scope)

Scope-weighted emissions:

Allowances for 2025, due by 30 September 2026:

At the 2024 average primary auction price of EUR 64.74 (COM(2025) 735), used here only as a reference, that is EUR 933,551.

For 2026, due by 30 September 2027, assume the same CO2 and scope-weighted methane and nitrous oxide of 1.0 t and 0.8 t respectively, illustrative figures for a diesel-engined ship:

The obligation rises by 6,420 allowances, 44.5%, with no change in operation. The phase-in step supplies 6,180 of them and the new gases 240. On an LNG-fuelled ship the methane term can be far larger, which is why the slip coefficient in Delegated Regulation (EU) 2023/2776 matters to LNG owners from 2026.

Common scope errors

• Reading the phase-in into the report. The verified emissions report states full scope-weighted emissions; the 40% or 70% applies only to surrender.
• Treating a bunkering, crew-change or STS stop as a port call. Article 3(z) excludes them; the voyage runs through.
• Treating Tanger Med or East Port Said as EU ports. They are excluded from “port of call” for container ships only; they are not in the Union.
• Applying the island derogation to cruise ships. Article 12(3-d) excludes cruise ships by its terms.
• Assuming the time charterer holds the obligation. The shipping company under Article 3(w) surrenders; the charterer’s liability is contractual, through Article 3gc and the charter clause.
• Splitting a mid-year change of company by calendar days. Each company answers for the voyages and port stays during its period of responsibility.

Limitations

This article states the law in force on 27 September 2026. The following points remain open or depend on documents outside the Directive:

• Lay-up. Article 3ga(1) covers emissions within a port of call, but Article 3(z) defines a port of call by cargo or passenger operations and does not list lay-up among the excluded stops. The treatment of a ship laid up at an EU berth with no commercial call is not settled by the text; see lay-up of ships .
• Transhipment port list. Article 3ga(2) requires the list in Implementing Regulation (EU) 2023/2297 to be updated by 31 December every two years. Check the current consolidated act before relying on the two ports named here.
• Offshore ship definition. Which ship types count as offshore ships for MRV Article 2(1a) and (1b) is set in the MRV implementing framework, not in the Directive, and is not reproduced here.
• Island lists by Member State. Implementing Decision (EU) 2023/2895 as amended lists individual islands and ports; confirm a route against the consolidated Decision, not against this summary.
• COM(2026) 616. Every element of the proposal can change in the ordinary legislative procedure. Nothing in it applies until adopted and published in the Official Journal.
• FuelEU outermost-region treatment. The comparison table states the Article 2(1)(c) counting rule of Regulation (EU) 2023/1805 only; any other FuelEU exemption for these voyages is outside this article.
• Prices. The EUR figures in the worked example use the 2024 average auction clearing price as a reference only; the actual cost depends on the date and market of purchase, see slow steaming for the main operational lever on emissions and UK ETS for shipping for the separate UK scheme.

Related Articles

• EU ETS for shipping
• EU ETS surrender mechanics for shipping
• EU ETS allowance allocation for shipping
• EU MRV Regulation 2015/757
• IMO DCS and EU MRV compared
• FuelEU Maritime explained
• EU ETS and FuelEU Maritime: double compliance
• EU maritime carbon pricing
• RFNBO rules in EU law
• Emissions monitoring and reporting
• IMO Net-Zero Framework
• UK ETS for shipping