Surplus Units Under the IMO Net-Zero Framework

A surplus unit (SU) is the transferable credit, measured in tonnes of CO2 equivalent, that a ship receives under the draft IMO Net-Zero Framework when its attained annual GHG fuel intensity (GFI) is below the direct compliance target annual GFI . The rules sit in draft regulations 2.3.16, 36 and 38 of a new Chapter 5 to MARPOL Annex VI , published as MEPC/ES.2/2. One unit equals one tonne CO2eq of positive compliance balance. It can be used once: transferred to another ship to balance that ship’s Tier 2 deficit, banked, or cancelled voluntarily, and it lapses two calendar years after the year it is issued.

The draft is not law. MEPC 83 approved it on 11 April 2025, the extraordinary session MEPC/ES.2 adjourned in October 2025 without adopting it, and the resumed session is scheduled for 4 December 2026.

Two features separate surplus units from the EU instruments most owners already run. No surplus unit can touch a Tier 1 deficit, and the text contains no pool.

Surplus unit definition in draft regulation 2.3.16

Draft regulation 2.3.16 defines the unit: “Surplus unit (SU), expressed in tonnes of CO2eq, means a transferable unit a ship in direct compliance is eligible to receive in accordance with regulation 36”. The unit is denominated in tonnes CO2eq on a well-to-wake basis, it is transferable, and only a ship in direct compliance can receive it.

The companion definition in regulation 2.3.11 describes the remedial unit as non-transferable. That contrast is the design of the draft: a unit earned by performance can move between ships, while a unit bought to cover a deficit stays with the ship that bought it.

The old label “reward unit” has no basis in the draft. The word reward in Chapter 5 belongs to a separate scheme, the ZNZ reward paid from the IMO Net-Zero Fund under regulations 2.3.12 and 39. MEPC/ES.2/2 also never uses “vintage”, “multiplier” or “offset” for surplus units.

Surplus unit issuance: direct compliance and the positive balance

Chapter 5 applies to ships of 5,000 gross tonnage and above (draft regulation 30.1), and such a ship receives surplus units only in a year it is in direct compliance. Draft regulation 36.2 places a ship in direct compliance when its GFI compliance balance is equal to or greater than zero, that is, when its attained annual GFI is at or below the direct compliance target for the year.

Quantity under regulation 36.11

Regulation 36.11 reads: “The amount of surplus units a ship in direct compliance is eligible to receive shall be equal to its positive compliance balance, expressed in tonnes of CO2eq, taking into account guidelines developed by the Organization.” Footnote 89 records that the guidelines are still to be developed.

The compliance balance under regulation 36.1 is the direct compliance target minus the attained GFI, multiplied by the ship’s total energy used (Energy_total in megajoules), then divided by 10^6 to convert grams to tonnes.

The text sets no cap, no floor and no multiplier. A tonne of positive balance produced by an LNG dual-fuel ship, a methanol conversion or wind-assisted propulsion is one surplus unit either way. How each energy source enters attained GFI is set by draft regulation 33 and the attained GFI methodology , not by regulation 36.

A ship exactly at the target

A ship whose attained GFI equals the direct compliance target has a balance of zero. It is in direct compliance and owes no remedial units , but it receives no surplus units, because a zero balance is not a positive balance.

Reference value for 2030

The target is 93.3 gCO2eq/MJ reduced by the direct compliance factor in Table 4 of draft regulation 35: 77.439 gCO2eq/MJ in 2028, 73.707 in 2030 and 53.181 in 2035 (values derived from the Table 4 factors 17.0, 21.0 and 43.0 percent). The year-by-year series is in the GFI reduction trajectory . A ship using 4.02 x 10^8 MJ in 2030 (the energy content of 10,000 tonnes of VLSFO at 40.2 MJ/kg) with an attained GFI of 60.0 gCO2eq/MJ would receive (73.707 - 60.0) x 4.02 x 10^8 / 10^6 = 5,510.2 surplus units (site arithmetic).

Crediting of surplus units by the IMO GFI Registry

The IMO GFI Registry , not the Fund, issues surplus units. Draft regulation 38.1 has the IMO Secretary-General establish and administer the Registry, and regulation 38.4 lists what it does with surplus units in each ship account:

1. “.1 credit the amount of surplus units a ship in direct compliance is eligible to receive”;
2. “.2 record banked surplus units between reporting periods”;
3. “.3 record all transferred surplus units from one ship account to another ship account”;
4. cancel surplus units used by a ship to balance its Tier 2 deficit, voluntarily cancelled at the ship’s request, or expired (38.4.4.1 to 38.4.4.3).

Every ship account would have to be opened by 1 October 2027, and an annual administration fee paid by 30 June 2028 and by 30 June of each year after, under regulation 38.2. Regulation 38.9 requires the Secretary-General to report to the Committee each year on “transaction patterns in the issuance, transferring, usage and cancellation of surplus units”.

Annual timetable

The cycle runs one calendar year behind the fuel it measures. Attained GFI is calculated over the reporting period of 1 January to 31 December (regulation 33.1), and the first reporting period is 2028.

The Statement of Compliance under regulation 6.9 is the ship’s evidence, and port state control may check it under regulation 10.5. Its form, Appendix XIII, carries the surplus unit record in three paragraphs. Paragraph 5 shows units banked from previous reporting periods. Paragraph 6, for a ship in direct compliance, records the units transferred to other ships, banked for future periods and cancelled voluntarily, with the final amount banked in 6.3. Paragraph 7, for a ship in deficit, records the banked units it used and the units obtained by transfer from other ships, with the final banked amount in 7.3. Secretariat note 5.12.2 records that “recorded” was replaced by “banked” in paragraph 6.3, with a mirroring provision in paragraph 7.

Chapter 5 adds no survey step to the IAPP Certificate .

Registry build status

ISWG-GHG 21, meeting from 20 to 24 April 2026, invited the Secretariat to report the possible costs of the Registry, which it described as a centralized data platform, and to continue developing its functional requirements. Interoperability with reporting to the IMO Data Collection System , cyber security and data governance were among the points listed. No Registry rules or technical specification had been adopted by September 2026.

Three permitted uses of a surplus unit under regulation 36.12

A surplus unit credited to the ship account can be used once, for one purpose. Regulation 36.12 reads: “A surplus unit, subject to paragraphs 6 and 15 of this regulation, credited to the ship account in the IMO GFI Registry may be used once for one of the following purposes”:

• “.1 transfer to another ship to balance that ship’s Tier 2 compliance deficit”;
• “.2 banked for use in the subsequent reporting periods”; or
• “.3 voluntarily cancelled as a mitigation contribution”.

Regulation 36.13 adds: “A surplus unit shall only be transferred or cancelled once, but each one of a ship’s surplus units may be used for any of the purposes provided for in paragraph 12”. A ship holding 5,510 units can therefore split them, transferring some, banking some and cancelling the rest.

Transfer to another ship’s Tier 2 deficit

Transfer is the only route by which one ship’s performance can help another. The receiving ship must have a Tier 2 compliance deficit, which arises only when its attained GFI is above the base target annual GFI (regulation 36.4.2). Regulation 36.6 lists surplus units transferred from other ships as the first of three ways to balance that deficit, beside banked surplus units and Tier 2 remedial units.

The draft attaches no ownership, company, flag or trade condition to the transfer. A unit can go from a ship of one company under one flag to a ship of another company under another. The Secretariat’s note to MEPC/ES.2/2 (paragraph 5.7.1) records that regulation 36 was reworded so that “how the surplus units are used by the ship have to be recorded in the ship account statement”.

Transfer timing in the annual cycle

The timetable leaves a short window for a same-year transfer. A seller’s units for reporting year T exist only once its data are verified and reported to the Registry, due by 30 June of T+1 (regulation 37.3). The buyer must record its compliance approach within one month of its own verified data, and no later than 31 July of T+1 (regulation 37.4). On this site’s reading, a unit earned in 2028 and used against a 2028 Tier 2 deficit would move between ship accounts in about July 2029. Earlier verification of the seller’s data widens that window; earlier verification of the buyer’s data narrows it, because the buyer’s one-month period under regulation 37.4 runs from its own verified data. The draft sets no date by which the Registry must credit units under regulation 38.4.1.

Banking

A unit not transferred or cancelled is banked. Regulation 36.14 states: “An unassigned surplus unit shall be automatically banked.” A banked unit can later balance the same ship’s Tier 2 deficit, because regulation 36.6.2 lists “surplus units banked from previous reporting periods” among the Tier 2 approaches.

The text leaves one point open. Regulation 36.12 treats banking as one of three uses, while regulation 36.13 lets each unit be used for any of them and regulation 36.14 makes banking the default. The draft does not state whether a unit banked in one year can be transferred to a different ship in a later year, and Appendix XIII has no field recording such a transfer. A flag-state account of the October 2025 drafting group (Liberian International Ship and Corporate Registry, 23 October 2025) reports agreement on “banking and inter-ship transfer of surplus GFI units within defined time-based validity”, but the plenary adjourned before reviewing that work, so it is not part of the official record.

Voluntary cancellation as a mitigation contribution

A ship can ask the Registry to cancel units outright (regulation 36.12.3, recorded under 38.4.4.2). The cancelled unit is retired as a mitigation contribution : it balances no deficit and earns nothing. Voluntary cancellation moves no money into the Fund, which receives payments only for remedial units under regulations 36.5 and 36.6.3.

Surplus unit validity and expiry under regulation 36.15

A surplus unit lasts for a fixed period. Regulation 36.15 gives it “validity of two calendar years following the calendar year of its issuance from the IMO GFI Registry” and continues: “A surplus unit not used by the ship in whose account it has been credited by its expiry date shall be cancelled by the IMO GFI Registry as a mitigation contribution.”

The draft does not fix the date of issuance. Units for reporting period T are credited after verification, which is due by 30 June of T+1 (regulation 37.3). If issuance falls in T+1, validity would run to 31 December of T+3; if the reporting year counts, to 31 December of T+2. No provision settles which, so no expiry date can be computed from the text alone.

The phrase “used by the ship in whose account it has been credited” points to expiry being measured against the holding account. A unit transferred to another ship and used against that ship’s Tier 2 deficit is cancelled on use (regulation 38.4.4.1), so the question of its expiry does not arise.

What a surplus unit cannot do

A full-text reading of draft regulations 30 to 44 finds no provision for any of the following. Each appears in commentary on the framework, but not in MEPC/ES.2/2.

No use against a Tier 1 deficit

Regulation 36.5 provides that a Tier 1 deficit is balanced “through remedial units acquired by means of GHG emissions pricing contributions to the IMO Net-Zero Fund, priced at Tier 1 benchmark rates”. A ship between the two targets, or the Tier 1 slice of a ship above the base target, pays USD 100 per tonne CO2eq for 2028 to 2030 (regulation 36.8) whatever surplus units it holds or could obtain. The compliance deficit article sets out the two tiers.

No pooling or fleet averaging

The word “pool” does not occur in Chapter 5. Attained GFI is calculated per ship over each calendar year (regulation 33.1), each ship determines its own compliance balance (regulation 36.1), and the word “company” appears only in regulations 37.2 and 37.7 on a change of company. An owner with ten ships gets ten balances and moves value between them one transfer at a time, only toward Tier 2 deficits.

No borrowing

Chapter 5 has no provision letting a ship use next year’s expected surplus this year. Borrowing appears in MEPC 84/7/38 (Argentina, Liberia and Panama, 20 February 2026), a proposal to replace the two-tier structure with a single GFI target, surplus units, banking and borrowing from one subsequent calendar year for up to two consecutive years. It has not been agreed.

No price, sale or market

The only prices in Chapter 5 are for remedial units (regulations 36.8 to 36.10). There is no surplus unit price, auction, exchange or payment term. The IMO’s explanatory question-and-answer page on the framework speaks of ships trading surplus units, but the regulation text uses “transfer”, and any payment for a transfer would sit in a private contract.

On this site’s reading, the Tier 2 remedial unit price sets a practical ceiling. A ship with a Tier 2 deficit can always balance it with Tier 2 remedial units at USD 380 per tonne CO2eq for 2028 to 2030 (regulation 36.9), so it has no reason to pay more than that for a transferred unit. There is no matching floor: a unit left unused expires as a mitigation contribution and returns nothing to its holder.

No carbon market link

MEPC/ES.2/2 does not mention the Paris Agreement, its Article 6, the UNFCCC or corresponding adjustments. A surplus unit exists only inside MARPOL Annex VI Chapter 5.

Supply, demand and value of surplus units

Only two groups of ships take part in any surplus unit transfer. Supply comes from ships below the direct compliance target; demand comes from ships above the base target, because only a Tier 2 deficit accepts units. A ship between the two targets neither supplies nor uses units: it pays Tier 1 remedial units on its whole shortfall. The gap between the targets is 13.0 Z points, 12.129 gCO2eq/MJ, in every year from 2028 to 2035 under Table 4 of draft regulation 35.

How far below the target a ship must go

On the MEPC.391(81) default factors, a VLSFO pathway has a well-to-wake intensity of about 95.484 gCO2eq/MJ (site arithmetic). To reach the direct compliance target, a ship burning VLSFO would need about 18.9 percent of its energy from zero-intensity sources in 2028, 22.8 percent in 2030 and 44.3 percent in 2035 (1 minus target over 95.484). Each further percentage point of zero-intensity energy lowers attained GFI by about 0.955 gCO2eq/MJ, which on 4.02 x 10^8 MJ of annual energy yields about 384 surplus units. Real fuels are not zero-intensity; the per-fuel well-to-wake values and certified labels set the actual figure.

Value to seller and buyer

For the 2028 to 2030 reporting periods, the buyer’s alternative is a Tier 2 remedial unit at USD 380 per tonne CO2eq (regulation 36.9). The seller’s alternatives are banking the unit against a Tier 2 deficit of its own within the validity window, or letting it expire. On this site’s reading, any price agreed for a unit used against a 2028 to 2030 deficit sits between zero and USD 380. The draft sets no remedial unit price after 2030 (regulation 36.10), so no ceiling can be read for later periods.

The only public data on transactions would be the Secretary-General’s annual report under regulation 38.9 on issuance, transfer, use and cancellation. The draft gives the Registry no role in recording any price.

Surplus units and remedial units compared

The two units are mirror images, and the draft treats them differently on every point that affects a trading decision.

The asymmetry has a commercial consequence. Remedial unit revenue funds the Net-Zero Fund; a surplus unit transfer moves no money to the IMO at all. Every surplus unit used against a Tier 2 deficit replaces a Tier 2 remedial unit purchase of USD 380 for 2028 to 2030, so a liquid supply of surplus units would reduce Fund inflows. The IMO levy and economic measure article covers the Fund’s revenue side and the cost recovery provision the pass-through of remedial unit costs.

Surplus units and ZNZ rewards

Rewards for zero or near-zero GHG fuels, technologies and energy sources (ZNZs) are paid from the Fund under draft regulation 39. Regulation 39.1 sets the ZNZ threshold at not greater than 19.0 gCO2eq/MJ until 31 December 2034 and not greater than 14.0 gCO2eq/MJ from 1 January 2035, and regulation 39.3 requires the Committee to define the reward and its methodology “No later than 1 March 2027 and every five years thereafter”.

The text does not condition a ZNZ reward on direct compliance, and does not remove rewarded energy from Energy_total or from the balance that produces surplus units. It is silent on how the two interact. A ship burning a ZNZ fuel would, on the text, earn surplus units on its balance and a reward on its ZNZ energy; the draft neither permits nor forbids that expressly.

Worked example: issuing, transferring and banking

The example uses the draft 2030 values and energy of 4.02 x 10^8 MJ per ship, the energy content of 10,000 tonnes of VLSFO. The arithmetic is this site’s, on MEPC/ES.2/2 Table 4 and the MEPC.391(81) default factors; the sibling article on the direct compliance target sets out the derivation.

Ship A runs largely on a low-intensity fuel and attains 60.0 gCO2eq/MJ against the 2030 direct compliance target of 73.707. It receives 5,510.2 surplus units in its Registry account.

Ship B burns only VLSFO, with a well-to-wake intensity of about 95.484 gCO2eq/MJ on MEPC.391(81) defaults, against a 2030 base target of 85.836. Under regulation 36.4.2 it carries:

• a Tier 1 deficit of 12.129 x 402 = 4,875.9 t CO2eq, the whole band between the targets;
• a Tier 2 deficit of 9.648 x 402 = 3,878.5 t CO2eq, the excess over the base target.

Ship A transfers 3,878.5 units to Ship B. Ship B’s Tier 2 deficit is balanced; had it bought Tier 2 remedial units instead, they would have cost 3,878.5 x USD 380 = USD 1,473,830. Ship B still owes 4,875.9 Tier 1 remedial units at USD 100, USD 487,590, because no surplus unit can reach a Tier 1 deficit.

Ship A’s remaining 1,631.7 units are banked automatically under regulation 36.14. If Ship A has a Tier 2 deficit of its own in a later year inside the validity window, it can use them. If it does not, the Registry cancels them as a mitigation contribution when they expire under regulation 36.15.

Ship A and Ship B need not share an owner, a manager or a flag. What Ship B pays Ship A, if anything, is outside the draft.

Surplus units and FuelEU Maritime

For ships calling at ports in the European Economic Area, FuelEU Maritime , Regulation (EU) 2023/1805, already runs a surplus mechanism that has applied since 1 January 2025. The two diverge on each of the flexibility tools.

FuelEU pools a balance; the IMO draft transfers units. A FuelEU pool can cover any part of a member ship’s deficit, while an IMO surplus unit reaches only the Tier 2 slice. FuelEU also lets a surplus remaining after pooling be banked under Article 20(1) (Article 21(6)). The FuelEU compliance balance and pooling article covers Articles 20 and 21 in full, and the FuelEU penalties article the consecutive-deficit multiplier of Article 23(2).

Articles 20 and 21 have not been amended since the original text of 22 September 2023. The Commission proposal COM(2026) 620 of 17 July 2026, part of a FuelEU and MRV simplification package , would reword Articles 20(1), 20(2), 21(1) and 21(4), keeping the 2 percent borrowing limit, the 1.1 repayment factor and the consecutive-period rule. Its new Article 21(1) omits the sentence allowing two separate pools for the GHG intensity target and the RFNBO subtarget. It is a proposal and has not been adopted.

Surplus units and EU ETS allowances

An EU allowance under the EU ETS for shipping is a different kind of instrument. It is a permit to emit one tonne of CO2 equivalent, issued by auction or allocation, and the shipping company surrenders allowances for its reported emissions by 30 September each year under Article 12(3) of Directive 2003/87/EC, as amended for shipping by Directive (EU) 2023/959.

It differs from a surplus unit on transfer, validity and price:

• Transfer. Article 12(1) allows allowances to be transferred between persons within the Union, and between persons within the Union and persons in third countries where the allowances are recognized under Article 25. Holdings sit in the Union Registry under Delegated Regulation (EU) 2019/1122, which provides for maritime operator holding accounts . A surplus unit moves only between ship accounts.
• Validity. Article 13 states that “Allowances issued from 1 January 2013 onwards shall be valid indefinitely.” A surplus unit lapses two calendar years after its year of issuance.
• Price. Allowances trade on exchanges and in auctions, so a market price exists (EUA market mechanics ). A surplus unit has none.

No surplus unit can be surrendered under the ETS, and no allowance can balance an IMO deficit. The EU ETS and FuelEU double compliance article covers how the two EU instruments stack; a third, IMO layer would add a separate account and a separate unit. The surrender mechanics article covers the ETS side.

Surplus units in charter parties and ship sales

The draft credits surplus units to the ship account and is silent on who holds their commercial value. Regulation 36.7 states that a ship which has fully balanced its deficit “shall be considered as being compliant with its target annual GFI” without prejudice to recovering costs relating to the operational responsibility of the ship, defined as “determining the fuel used or the cargo carried or the route or the speed”. It addresses costs, not units.

Under a time charter party the charterer usually buys the fuel and sets speed, so the performance that earns the units is often the charterer’s while the units sit in the ship account, whose holder the draft does not name. A bareboat charter party raises the same question with the charterer as operator, and Chapter 5 does not answer it either. For EU compliance BIMCO has published the FuelEU Maritime Clause for Time Charter Parties 2024 (adopted by its Documentary Committee on 25 November 2024), a FuelEU clause for SHIPMAN 2024, and FuelEU and ETS clauses for memoranda of agreement adopted on 11 December 2025. As of September 2026 it has published no clause for IMO surplus units; the BIMCO FuelEU Maritime clause article covers the EU wording.

On a sale, draft regulations 37.2 and 37.7 require a part-year report and a Statement of Compliance for the period up to a change of flag or company completed after 1 January 2028. No provision addresses banked units. On this site’s reading, units credited to a ship account (regulation 38.4.1) would remain in that account after a sale; the draft does not say so, and a memorandum of agreement would need to allocate their value expressly. Regulation 37.8, on a ship permanently withdrawn from service, is equally silent on the units left in its account.

Surplus unit guidelines and pending IMO work

Regulation 36.11 depends on guidelines “developed by the Organization” that do not yet exist (footnote 89). The work sits in the Intersessional Working Group on GHG :

• ISWG-GHG 20 (20 to 24 October 2025) discussed draft guidelines on GFI calculation, GFI compliance approaches and the IMO GFI Registry, and invited the sponsors to merge their drafts into consolidated draft guidelines with placeholders.
• ISWG-GHG 21 (20 to 24 April 2026) asked the Secretariat for Registry costs and continued work on its functional requirements. Its summary does not mention surplus units.
• ISWG-GHG 22 (1 to 4 September 2026) deferred the implementation guidelines to ISWG-GHG 23, scheduled for 23 to 27 November 2026.

The Net-Zero Framework implementation guidelines and the GFI Calculation Guidelines are tracked separately. Until they are adopted, the transfer procedure, account-holder rules and any fee per transaction are undefined.

Adoption status and proposals to change surplus units

Surplus units have no legal effect. MEPC 83 approved the draft Chapter 5 on 11 April 2025 “with a view to circulation”. The extraordinary session convened to adopt it, MEPC/ES.2 (14 to 17 October 2025), adjourned; the IMO summary states that “The extraordinary session will be reconvened in 12 months’ time”. MEPC 84 (27 April to 1 May 2026) established an intersessional working group, recorded that Member States “will be able to submit new amendments and adjustments to the draft amendments previously approved”, and scheduled the resumed session for 4 December 2026, subject to confirmation by MEPC 85 . It adopted and amended nothing in Chapter 5.

Adoption would follow the tacit acceptance procedure of MARPOL Article 16. The Registry account deadline of 1 October 2027 and the 2028 first reporting period were written for adoption in October 2025; on this site’s reading, they would have to be revisited on any later timetable.

Several 2026 amendment proposals would change surplus units directly. The first two below are as summarized in an IMO officer’s presentation to the ISCC conference of 10 June 2026:

• Circular Letter No.5215 (Tuvalu): no surplus units, with all emissions subject to remedial unit payment at a minimum of USD 300 per tonne CO2eq;
• Circular Letter No.5214 (Brazil): “less steep reduction trajectories for the base target and the direct compliance target towards 2035 (more SUs)”;
• MEPC 84/7/38 (Argentina, Liberia and Panama): a single GFI target, surplus units for ships that “outperform the applicable GFI Target”, transfer “exclusively through the IMO GFI Registry”, banking and borrowing.

None of these has been agreed. The approved text described in this article is MEPC/ES.2/2 as circulated.

Common errors about surplus units

• “Surplus units can offset any deficit.” They reach only a Tier 2 deficit (regulations 36.5, 36.6). A Tier 1 deficit takes Tier 1 remedial units only.
• “Owners can pool ships, as under FuelEU.” Chapter 5 has no pool and no fleet average; value moves one transfer at a time between ship accounts.
• “Units can be banked indefinitely” or “for five years”. Validity is two calendar years following the year of issuance (regulation 36.15).
• “The IMO sets a surplus unit price.” No price exists; the USD 100 and USD 380 figures are remedial unit prices (regulations 36.8, 36.9).
• “The Net-Zero Fund keeps the ledger.” The IMO GFI Registry does (regulations 38.1, 38.4).
• “Verification happens at IAPP renewal.” The Administration or RO verifies annually by 30 June and issues a Statement of Compliance under regulation 6.9; there is no IAPP survey step.
• “Chapter 4 ter” or “regulation 29ter”. The draft is Chapter 5, regulations 30 to 44, with surplus units in regulation 36.
• “Surplus units were adopted at MEPC 83.” They were approved there; adoption has not happened.
• “Reward units”. No such term exists in the draft; rewards are ZNZ rewards under regulation 39.

Limitations

Every surplus unit rule in this article comes from MEPC/ES.2/2, a draft approved in April 2025 and not adopted. Regulation numbers, dates and prices could change at the resumed session or through the amendments MEPC 84 invited. The guidelines to which regulation 36.11 refers do not exist, so the procedure for crediting, transferring and cancelling units, and any per-transaction fee, cannot be described.

The text itself leaves open the year from which the two-year validity runs, whether a banked unit can later be transferred to another ship, and what happens to banked units on a change of company. The worked example is this site’s arithmetic on the Table 4 factors and MEPC.391(81) default emission factors; a real ship’s attained GFI depends on certified fuel lifecycle labels , the GFI calculation guidelines and verified energy data.

The market value of a surplus unit is not set anywhere. The USD 380 ceiling is an inference from regulation 36.9 for 2028 to 2030 only, and no floor exists. EU figures are from the original texts of Regulation (EU) 2023/1805 and Directive 2003/87/EC as consolidated to 1 March 2024; COM(2026) 620 would change FuelEU Articles 20 and 21 if adopted.

Related Articles

• IMO Net-Zero Framework
• IMO Net-Zero Framework GHG fuel intensity
• Direct compliance target annual GFI
• Base target annual GFI
• GFI reduction trajectory
• Marine GFS methodology
• Remedial units
• IMO GFI Registry
• Surplus unit mitigation contribution
• IMO Net-Zero Fund disbursement
• 2023 IMO GHG Strategy
• FuelEU compliance balance and pooling
• FuelEU reward mechanism
• Well-to-wake intensity
• Per-fuel WtW blend methodology
• Green shipping corridors