FuelEU Maritime explained: targets, scope and penalties

FuelEU Maritime is the European Union’s fuel standard for ships. From 1 January 2025 it caps the yearly average greenhouse gas intensity of the energy a vessel uses, measured in grams of CO2 equivalent per megajoule (gCO2e/MJ) on a well to wake basis, which counts the emissions of producing the fuel as well as burning it. It is not a carbon price: the EU Emissions Trading System for shipping makes a company buy allowances for the emissions it reports, while FuelEU limits the energy itself and penalises the ships that miss the limit. Both apply to the same vessels.

The reference number the rule is built on

Compliance is measured against a fixed baseline of 91.16 gCO2e/MJ, calculated by the Commission from 2020 fuel consumption reported under the EU’s monitoring, reporting and verification system. The Commission states that this value will not be revised, so each target is a fixed percentage below a fixed number.

Year	Reduction against the 2020 reference
2025	2%
2030	6%
2035	14.5%
2040	31%
2045	62%
2050	80%

The 2025 step is tighter than it looks. In an illustrative example, the Commission concludes that a vessel burning heavy fuel oil, light fuel oil or marine diesel would not meet the resulting limit of 89.34 gCO2e/MJ, while a dual fuel medium speed LNG engine would be marginally compliant. The metric covers carbon dioxide, methane and nitrous oxide over the full lifecycle, so methane slip counts, and the later steps sit below what any oil fuel can deliver.

Who is covered, and which energy counts

The regulation applies to ships above 5,000 gross tonnage calling at ports under the jurisdiction of a Member State, regardless of flag. Fishing vessels and non-commercial government ships are outside it. Gross tonnage is an internal volume measure, not a cargo measure, and how container ships are sized sets out how it relates to TEU.

Scope follows the voyage. All energy used between two ports under EU jurisdiction counts, as does half the energy on a voyage to or from an EU outermost region, and half on a voyage between an EU port and a third country port.

Two boundaries decide the awkward cases. The Commission lists neighbouring container transhipment ports, and a stop at a listed port is not treated as a port of call, so a relay outside the EU cannot reset the voyage; the mechanics are in what transshipment means. And because the regulation is not yet in the European Economic Area Agreement, Norwegian and Icelandic ports are treated as third-country ports, so a voyage between an EU port and Norway follows the international rules.

The compliance year

A company submits a monitoring plan for each ship, records voyages, time at berth, fuel burn and emissions from 1 January 2025, and delivers a ship-specific report to a verifier by 31 January of the following year. The data lands in the FuelEU database, a compliance deficit is assessed as of 1 June, and any penalty must be paid by 30 June.

Banking, borrowing and pooling

Three mechanisms sit between the ship and the penalty. A ship with a positive balance can bank the surplus into later periods, and banked units do not expire. It can borrow the equivalent surplus from the next period, repaying with a 10% surcharge. Or two or more ships can pool balances, so that over-performance on one hull covers another’s deficit, provided the pool is positive overall. Pools are registered, validated by every participating company and recorded by the verifier by 30 April, and a ship can sit in only one pool per period.

Pooling is where the commercial interest sits. The regulation sets no price and creates no tradable unit: compliance units cannot be exchanged between ships at all, and pooling is the only route by which one ship’s surplus can cover another’s. Any payment is a private agreement, so a pool is a negotiated transaction, not a market with a clearing price.

The berth obligation

A separate requirement covers the berth. Container and passenger ships above 5,000 GT must use onshore power supply (OPS) or an equivalent zero-emission technology there from 1 January 2030 in ports covered by Article 9 of the EU’s alternative fuels infrastructure regulation, and from 1 January 2035 in all EU ports that develop OPS capacity.

The penalty is disclosed: EUR 1.5 per kWh, multiplied by the ship’s total electrical power demand at berth in kW, multiplied by the non-compliant hours rounded up. That figure includes cargo handling and hotel load, so a large container ship on a long call accumulates exposure quickly. Stays of under two hours are exempt, as that is the minimum time needed to connect.

What non-compliance costs

For an intensity deficit, the Commission points to the formula in Annex IV: energy consumption in megajoules, multiplied by a fixed amount of money per megajoule, multiplied by the percentage by which intensity should have been reduced. The amount rises after two or more consecutive deficit periods. Failure to pay escalates: under Article 25 the Commission lists expulsion from ports, flag detention and restricted port access in several Member States. Revenue is collected by the administering state, which must report on its use.

What it means for a shipper

There is no allowance price to read off a screen and no single per container figure to pass through. The cost appears in the fuel a carrier can economically burn on a European loop, in penalty or pooling expense on ships that fall short, and in the contract terms that allocate it. Unlike the EU ETS, where the Directive gives the shipping company a right of reimbursement, FuelEU leaves liability to private agreements. A shipper should ask which entity is the company for the ship, and how the carrier intends to comply.

Common misreadings

• That a compliant ship is a compliant voyage. The test is an annual average, not a per sailing check.
• That LNG settles the question. Methane slip counts, and later targets sit below what gas alone delivers.
• That a surplus can be sold. It can be banked or pooled. It cannot be traded as a unit.

What to watch

• The renewable fuels sub-target. A sub-target for renewable fuels of non-biological origin applies from 2034, and the Commission can waive it where production capacity is insufficient, availability is uneven or prices are too high. It also publishes the fleet’s annual share of those fuels.
• EEA incorporation. Until Norway and Iceland are inside the regulation, their ports sit outside the intra-EU definition, which changes the treatment of North Sea and Norwegian coastal calls.
• Pooling behaviour. Pools are recorded by 30 April each year, which will show which carriers are short and which hold surplus on European services.

Sources: European Commission, FuelEU Maritime (regulation (EU) 2023/1805, targets, berth rules, EEA notice of 18 December 2025) and the questions and answers on regulation (EU) 2023/1805 (reference value, scope, banking, pooling, penalties), retrieved 27 October 2026.