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Home › Environmental Compliance › EU ETS and FuelEU Maritime
Regulatory update

EU ETS and FuelEU Maritime

EU ETS, MRV and FuelEU have distinct scopes: in 2027 ETS adds offshore ships ≥5,000 GT; 400–4,999 remains proposal/review, while FuelEU concerns ships above 5,000 GT.

EU ETSFuelEU MaritimeEuropean Uniondecarbonization

Operational Explanation

EU ETS requires surrender of allowances for covered emissions; FuelEU limits lifecycle GHG intensity of energy used. MRV provides monitoring and verification with its own scope. From 2026 ETS also includes CH₄ and N₂O. Distinguish emissions year from compliance year: 100% of covered 2026 emissions is surrendered in 2027; surrender in 2026 covers 70% of covered 2025 emissions.

Regulatory Reference

Commission — maritime ETS FAQ; Directive 2003/87/EC; Regulation 2015/757; Regulation (EU) 2023/1805, FuelEU.

Scope of Application

ETS: relevant ships ≥5,000 GT and offshore ≥5,000 from 2027. MRV from 2025 includes specified 400–4,999. FuelEU: above 5,000 GT.

Procedure / How to Complete It

  1. Apply three separate scope tests.
  2. ETS geography: 100% intra-EU/in port, 50% extra-EU legs.
  3. Allowance phase-in: 40% 2024, 70% 2025, 100% from 2026 for covered emissions.
  4. FuelEU baseline 91.16 gCO2e/MJ and -2% 2025–2029.
  5. Treat smaller-ship extension only as proposal until enacted.

Practical Example

The 100% in 2026 ends phase-in but does not make every extra-EU voyage 100% geographically covered.

What Typically Goes Wrong

Writing all MRV ships enter ETS in 2027, one ≥5,000 scope, or 100% of every global emission.

Common Mistakes Mistake Library

MistakeConsequenceHow to Avoid It
Writing all MRV ships enter ETS in 2027, one ≥5,000 scope, or 100% of every global emission.Non-compliant decision or treatmentFollow the approved arrangement and applicable sources

What the PSCO Checks

Check availability of MRV and FuelEU documents of compliance where required and their consistency with the ship and relevant period. The FuelEU document is distinct from the MRV document; ETS allowance obligations are handled by the company and responsible authorities under that regime.

Operational Tips

Preparation checklist

FAQ

Do 400–4,999 automatically enter ETS in 2027?
No.
Does FuelEU include exactly 5,000 GT?
No; Article 2 says above 5,000.
Does 100% in 2026 change geography?
No.

Related Topics

Environmental Vetting and GHG RatingIMO Net-Zero Framework

Last substantive revision of this page: 15 September 2026 · page fingerprint c70e7c20d297