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Key characteristics at a glance
Element EU ETS (Maritime)
Mechanism Cap-and-trade carbon market
Cost driver Market price of EU Allowances (EUAs)
Ship threshold Cargo & passenger ships ≥ 5,000 GT (since 2024); offshore ships ≥ 5,000 GT (from reporting period 2027)
Geographic scope EU/EEA ports
Gases covered CO₂ (2024), CH₄ & N₂O (from 2026) on tank-to-wake (TTW) basis
Phase-in 40% (2024), 70% (2025), 100% (from 2026)
Compliance party Shipping company (ISM entity)


The EU Emissions Trading System (EU ETS) is the European Union’s carbon pricing mechanism, and from 2024 it includes maritime transport. It places a cost on greenhouse gas emissions from ships by requiring companies to monitor emissions (under EU MRV) and surrender tradable emission allowances.

For shipping, EU ETS represents a shift from pure reporting to direct financial exposure to carbon emissions, making emissions performance a commercial factor in voyage planning, chartering, and fuel strategy.

Overview

Under EU ETS, shipping companies must purchase and surrender EU Allowances (EUAs) corresponding to a share of their verified greenhouse gas emissions. These allowances are traded on the carbon market, meaning the cost of compliance fluctuates with EUA prices.

The system follows a “cap-and-trade” model at EU level (with an overall emissions cap for covered sectors), but for individual voyages or ships there is a financial liability, with no fixed limit tied to emissions.


Scope

Geographical coverage:
All EU Member States plus EEA countries (Norway, Iceland, Liechtenstein).

Ship size threshold:
Applies to ships of 5,000 gross tonnage (GT) and above.

Voyage coverage:
EU ETS covers emissions from:

· 100% of emissions on voyages between two EU/EEA ports

· 100% of emissions while at berth in an EU/EEA port

· 50% of emissions on voyages between an EU/EEA port and a non-EU/EEA port

This makes EU ETS relevant not only for intra-European trade, but also for deep-sea voyages with an EU connection.
What counts as a “port of call” ?

A port of call is where a ship stops to load/unload cargo, embark/disembark passengers, or (for offshore ships) relieve crew. Several stop types do not count (e.g., refuelling-only, taking supplies, repair/dry-dock, distress/assistance, shelter from weather, certain ship-to-ship transfers, and specific container transhipment port situations).


Greenhouse gases covered:

· CO₂ – covered from 2024

· CH₄ (methane) – covered from 2026

· N₂O (nitrous oxide) – covered from 2026

This broadens the impact beyond fuel consumption alone, especially for LNG-fueled vessels where methane slip becomes commercially relevant.


Exemptions:

The following vessel types are excluded:

· Warships and naval auxiliaries

· Fishing vessels

· Government ships used for non-commercial purposes

Most commercial cargo and passenger vessels above the size threshold are therefore in scope.



Phase-in schedule

Shipping is gradually phased into full financial exposure:

· 2024: Companies must surrender allowances for 40% of verified emissions

· 2025: 70% of verified emissions

· From 2026 onwards: 100% of verified emissions

The phase-in reduces short-term shock but clearly signals full carbon pricing in the near term.

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