In simple terms, the system works on a straightforward principle: those who pollute must pay. Instead of using a carbon market like the EU ETS, these frameworks apply a fixed carbon contribution based on the share of a vessel’s emissions attributed to the country.

For shipowners, operators and agents, the commercial message is clear: emissions are no longer only something to report. In some trades, they now directly affect the cost of calling at port.

Overview

Under both frameworks, Djibouti and Gabon attribute 50% of the total carbon footprint of a qualifying ship movement to themselves. That means a ship sailing to or from one of these countries is not charged on the full voyage footprint, but on the part of the journey’s emissions that the country counts as its own. That attributed share is then subject to a fixed carbon contribution.

This is an important difference from EU ETS. There is no tradable allowance, no carbon market exposure, and no daily EUA price to track. Instead, the system is administrative: report the movement, calculate the carbon footprint, receive an invoice, and pay the contribution.

Scope

Geographical coverage:

The frameworks apply to qualifying ship movements to or from ports in Djibouti and Gabon. In both cases, the country counts 50% of the total carbon footprint of the movement between the national port and the previous or next port of call.‍

Ship size threshold:

The scope is broader than a simple GT threshold.

Djibouti exempts:

• vessels below 3,000 DWT
• vessels below 500 GT
• container ships below 300 TEU
• vessels under the Djibouti flag

Gabon exempts:

• vessels below 2,000 DWT
• vessels below 400 GT
• container ships below 200 TEU
• vessels under the Gabon flag

‍Voyage Coverage:

Any ship that calls at the relevant country and is subject to port and customs clearance obligations must report the movement and the associated carbon footprint, unless it falls under an exemption.

Gases covered:

The rules are expressed in terms of carbon footprint / tCO₂e (CO₂, CH₄, N₂O). In other words, the cost is charged per tonne of CO₂ equivalent with emission factors derived from Smart Freight Center.‍

Exemptions:

Besides the tonnage and capacity thresholds above, both frameworks include special treatment for military vessels and certain special-purpose ships. Gabon also has a separate rule for ships with an unknown or undisclosed destination.

Start date

Djibouti

• carbon contribution applies from 1 January 2025
• from 1 July 2025, the framework also introduces an offsetting element for up to 30% of the footprint associated with Djibouti

Gabon

• the registry is operational from 15 February 2025
• the carbon contribution becomes mandatory for maritime movements from 15 June 2025
• offsetting will apply later, from a date still to be defined

Responsibility

The party responsible under the framework is the Shipping Agent, acting as the ship’s legal representative. That agent is responsible for carrying out the reporting and mitigation obligations in relation to the registry.

In practice, this does not necessarily mean the shipping agent carries the economic burden. Commercially, the cost may still be passed through between owner, operator, charterer or cargo interests depending on the contract. But from the registry’s perspective, the shipping agent is the key compliance interface.

Cost Impact

Both frameworks apply a fixed carbon price of USD 17 per tCO₂e. In Gabon, this is also expressed in local currency as CFAF 10,710 per tCO₂e.

There are also caps on the amount payable per movement:

Djibouti

• USD 7,500 per vessel movement
• From July 2025, the framework adds an offsetting element. The rules state that an offsetting effort will be undertaken for up to 30% of the carbon footprint associated with Djibouti, alongside the carbon contribution.

Gabon

• USD 15,000 (CFAF 9,450,000) equivalent per vessel movement
• for tramp vessels, the cap may apply to the combined inbound and outbound movements
• Gabon also foresees carbon offsetting, but this will apply only from a future date to be defined.

For some exceptional cases, the contribution is not based on the normal carbon-footprint calculation but on gross tonnage:

• Djibouti: military and special vessels at USD 0.50 / GT
• Gabon: military and special-purpose ships at about USD 0.50 / GT, and ships with unknown destination at about USD 0.25 / GT per movement

The practical takeaway is that this is a predictable carbon cost compared with a traded carbon market, but it is still an additional emissions-linked cost that must be managed commercially.

Compliance mechanism

1. Reporting of movements

The ship’s legal representative, i.e. the Shipping Agent, must report the movements of the ships for which it acts, together with the ship type and the relevant ship specifications. This includes:

• port of origin and port of destination
• voyage distance in nautical miles
• vessel name
• IMO / MMSI number
• the relevant technical size metric:
• maximum TEU capacity for container ships
• maximum DWT for bulk, ro-ro, gas or oil tankers
• GT for other passenger or special vessels

2. Carbon footprint calculation

The carbon footprint can be determined in two ways.

The first is based on the ship’s actual fuel consumption and fuel type. In that case, the obligor must provide supporting evidence, such as a copy of the Captain’s Logbook. The registry can verify this information.

The second is based on default emission factors for the vessel type, combined with the voyage distance. This provides a fallback methodology where actual fuel data is not used.

3. Reporting cycle

Djibouti

• monthly reporting
• no later than 30 days after the movement

Gabon

• reporting within one month after the movement

4. Invoicing and payment

Once the movement and carbon footprint have been reported and validated, the registry issues an invoice. After payment, the registry issues a Payment Certificate, which serves as evidence that the relevant carbon contribution has been settled.

For Gabon, payment must be made within 30 calendar days of receiving the invoice. A late payment penalty of 3% per day applies from the 46th day after the invoice date.

For Djibouti, the official documentation clearly confirms invoice issuance and Payment Certificate issuance, but the payment deadline is less clearly visible in the excerpts provided here.

Commercial and operational implications

For shipowners, operators, charterers and agents, the message is simple: know your emissions. These frameworks make fuel data, voyage data and vessel-capacity data commercially relevant in a more direct way. If you cannot track them properly, you will struggle not only with reporting, but also with forecasting and controlling the cost of port calls.

As many African countries are likely to follow Djibouti´s and Gabon’s lead in aligning with Paris Agreement goals, the key to navigating these regulations is simple: know your emissions. Understanding and tracking emissions will streamline the calculation of related costs and reduce administrative burdens.

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