Navigating the complexities of maritime emissions regulations can be challenging as they continue to evolve. Here, we provide a five-year timeline and a sort summary of key points for you to remember.
Navigating the complexities of maritime emissions regulations can be challenging as they continue to evolve. Here, we provide a five-year timeline and a sort summary of key points for you to remember.
Maritime emissions regulations timeline
EU Emissions Trading System
The EU Emissions Trading System (ETS) is a cap-and-trade system designed to reduce greenhouse gas (GHG) emissions.
Since 2024, the ETS has included CO2 emissions from cargo and passenger ships above 5 000 GT entering EU ports, regardless of the ship’s flag.
Maritime emissions are gradually phased into the EU ETS, with 40% of emissions covered in 2024, increasing to 70% in 2025, and 100% by 2026.
From January 2025, general cargo vessels 400 GT - 4 999 GT and offshore vessels above 400 GT are covered by the EU Monitoring, Reporting and Verification Regulation (MRV) in preparation for the inclusion into the EU ETS.
From January 2027 offshore ships above 5 000 GT will be included in the EU ETS.
From January 2027 vessels below 5 000 will potentially be included in the EU ETS (to be decided 2026).
From January 2026 the EU ETS will also include CH4 (methane) and N2O (nitrous oxide) emissions.
If by 2028, there is no global market-based measure in operation applying a carbon price on international maritime emissions, the EU will consider including 100% of the emissions from extra-EU voyages in the EU ETS.
Penalties
Penalty for non-compliance is 100 Euros per tonne of CO2. Additionally, the required allowances need to be surrendered.
Continuous non-compliance may result in severe consequences such as trade bans or denial of port entry within EU Member States.
FuelEU Maritime Regulation
The FuelEU Maritime Regulation is complementary to the EU ETS and it targets the fuel itself, adding significant cost on conventional fuels and potential benefit for alternative fuels.
Introduced in January 2025, the FuelEU Maritime regulation sets annual well-to-wake GHG intensity limits on energy used onboard ships above 5 000 GT trading within the EU or European Economic Area (EEA). The baseline for the reduction is the average well-to-wake GHG intensity of the fleet in 2020: 91.16 gCO2e/MJ. The limits ensure a gradual decrease in GHG intensity.
From 2025 the GHG intensity of energy used onboard ships must be reduced by 2%, setting the limit at 89.34 gCO2e/MJ.
From 2030 the GHG intensity of energy used onboard ships must be reduced by 6%, setting the limit at 85.69 gCO2e/MJ.
From 2035 the GHG intensity of energy used onboard ships must be reduced by 14.5%, setting the limit at 77.94 gCO2e/MJ.
From 2040 the GHG intensity of energy used onboard ships must be reduced by 31%, setting the limit at 62.9 gCO2e/MJ.
From 2045 the GHG intensity of energy used onboard ships must be reduced by 65%, setting the limit at 34.64 gCO2e/MJ.
From 2050 the GHG intensity of energy used onboard ships must be reduced by 80%, setting the limit at 18.23 gCO2e/MJ.
Penalties
The penalty for annual deficit is set at EUR 2,400 per tonne of VLSFO-equivalent; 10% additional penalty for consecutive non-compliance across two reporting periods.
Continuous non-compliance may result in severe consequences such as trade bans or denial of port entry within EU Member States.
IMO's MARPOL
MARPOL is the main international convention covering prevention of pollution of the marine environment. Annex VI Prevention of Air Pollution from Ships covers mandatory technical and operational energy efficiency measures aimed at reducing greenhouse gas emissions from ships.
The Carbon Intensity Indicator (CII) came into effect in 2023. It measures a ships’ energy efficiency. Based on their performance, ships receive an environmental rating and the rating thresholds become increasingly stringent towards 2030. CII metrics are under review, with updated metrics expected by 2026.
An economical element, a global GHG pricing mechanism, is expected to be adopted in 2025 and enter into force in 2027.
A technical element, namely a goal based marine fuel standard regulating the phased reduction of the marine fuel´s GHG intensity is also expected to be adopted in 2025.
Penalties for non-compliance will be proposed in 2025.
Regional emissions trading systems
Regional emissions trading systems, similar to the EU ETS, are currently being developed.
The UK ETS is set to take effect from 2026. It will initially apply to ships above 5 000 GT. Current proposals cover CH4 and N2O emissions.
Potential inclusion of ships below 5 000 GT in 2028.
Other countries i.e., China and Turkey, have announced that they will develop similar emissions trading systems.
LFO
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Light Fuel Oil (ISO 8217 Grades RMA, RMB and RMD. Including VLSFO with visc < 80)
HFO
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Heavy Fuel Oil (ISO 8217 Grades RME, RMG, and RMK. Including VLSFO with viscosity > 80)
Navigating the complexities of maritime emissions regulations can be challenging as they continue to evolve. Here, we provide a five-year timeline and a sort summary of key points for you to remember.
Maritime emissions regulations timeline
EU Emissions Trading System
The EU Emissions Trading System (ETS) is a cap-and-trade system designed to reduce greenhouse gas (GHG) emissions.
Since 2024, the ETS has included CO2 emissions from cargo and passenger ships above 5 000 GT entering EU ports, regardless of the ship’s flag.
Maritime emissions are gradually phased into the EU ETS, with 40% of emissions covered in 2024, increasing to 70% in 2025, and 100% by 2026.
From January 2025, general cargo vessels 400 GT - 4 999 GT and offshore vessels above 400 GT are covered by the EU Monitoring, Reporting and Verification Regulation (MRV) in preparation for the inclusion into the EU ETS.
From January 2027 offshore ships above 5 000 GT will be included in the EU ETS.
From January 2027 vessels below 5 000 will potentially be included in the EU ETS (to be decided 2026).
From January 2026 the EU ETS will also include CH4 (methane) and N2O (nitrous oxide) emissions.
If by 2028, there is no global market-based measure in operation applying a carbon price on international maritime emissions, the EU will consider including 100% of the emissions from extra-EU voyages in the EU ETS.
Penalties
Penalty for non-compliance is 100 Euros per tonne of CO2. Additionally, the required allowances need to be surrendered.
Continuous non-compliance may result in severe consequences such as trade bans or denial of port entry within EU Member States.
FuelEU Maritime Regulation
The FuelEU Maritime Regulation is complementary to the EU ETS and it targets the fuel itself, adding significant cost on conventional fuels and potential benefit for alternative fuels.
Introduced in January 2025, the FuelEU Maritime regulation sets annual well-to-wake GHG intensity limits on energy used onboard ships above 5 000 GT trading within the EU or European Economic Area (EEA). The baseline for the reduction is the average well-to-wake GHG intensity of the fleet in 2020: 91.16 gCO2e/MJ. The limits ensure a gradual decrease in GHG intensity.
From 2025 the GHG intensity of energy used onboard ships must be reduced by 2%, setting the limit at 89.34 gCO2e/MJ.
From 2030 the GHG intensity of energy used onboard ships must be reduced by 6%, setting the limit at 85.69 gCO2e/MJ.
From 2035 the GHG intensity of energy used onboard ships must be reduced by 14.5%, setting the limit at 77.94 gCO2e/MJ.
From 2040 the GHG intensity of energy used onboard ships must be reduced by 31%, setting the limit at 62.9 gCO2e/MJ.
From 2045 the GHG intensity of energy used onboard ships must be reduced by 65%, setting the limit at 34.64 gCO2e/MJ.
From 2050 the GHG intensity of energy used onboard ships must be reduced by 80%, setting the limit at 18.23 gCO2e/MJ.
Penalties
The penalty for annual deficit is set at EUR 2,400 per tonne of VLSFO-equivalent; 10% additional penalty for consecutive non-compliance across two reporting periods.
Continuous non-compliance may result in severe consequences such as trade bans or denial of port entry within EU Member States.
IMO's MARPOL
MARPOL is the main international convention covering prevention of pollution of the marine environment. Annex VI Prevention of Air Pollution from Ships covers mandatory technical and operational energy efficiency measures aimed at reducing greenhouse gas emissions from ships.
The Carbon Intensity Indicator (CII) came into effect in 2023. It measures a ships’ energy efficiency. Based on their performance, ships receive an environmental rating and the rating thresholds become increasingly stringent towards 2030. CII metrics are under review, with updated metrics expected by 2026.
An economical element, a global GHG pricing mechanism, is expected to be adopted in 2025 and enter into force in 2027.
A technical element, namely a goal based marine fuel standard regulating the phased reduction of the marine fuel´s GHG intensity is also expected to be adopted in 2025.
Penalties for non-compliance will be proposed in 2025.
Regional emissions trading systems
Regional emissions trading systems, similar to the EU ETS, are currently being developed.
The UK ETS is set to take effect from 2026. It will initially apply to ships above 5 000 GT. Current proposals cover CH4 and N2O emissions.
Potential inclusion of ships below 5 000 GT in 2028.
Other countries i.e., China and Turkey, have announced that they will develop similar emissions trading systems.
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