FuelEU Explainer: Breaking Down Responsibility
Introducing the first article in a series on FuelEU Maritime Regulation from the Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping.
Introducing the first article in a series on FuelEU Maritime Regulation from the Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping.
The second article in a series on FuelEU Maritime Regulation from the Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping.
The third article in a series on FuelEU Maritime Regulation from the Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping.
The fourth article in a series on FuelEU Maritime Regulation from the Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping.
The fifth article in a series on FuelEU Maritime Regulation from the Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping.
The sixth article in a series on FuelEU Maritime Regulation from the Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping.
This newsletter concludes the series by the Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping on how companies can embrace the opportunity created by FuelEU Maritime to decarbonize.
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FuelEU Maritime Fact Sheet
FuelEU Maritime (FuelEU) is a regulation under the European Union’s (EU) 'Fit for 55' package, aiming to ensure that the maritime sector contributes to the EU goal of reducing greenhouse gas (GHG) emissions by 55% by 2030 and achieving climate neutrality by 2050. This regulation mandates a progressive reduction in the yearly GHG intensity of the energy used by ships, starting with a 2% reduction in 2025 and scaling up to an 80% reduction by 2050 (Figure 1). These targets are designed to accelerate the transition towards renewable and low-carbon fuels in maritime transport.
Scope and Responsibility
FuelEU applies to commercial vessels (passenger and cargo) over 5,000 gross tonnes traveling to European Economic Area (EEA) ports consisting of EU member states, Iceland, and Norway. It will apply to 100% of the intra EEA traffic (including consumption at berth), and 50% of traffic from an EEA port to a third country. It complements the existing EU Emissions Trading System (ETS) which has been extended to maritime transport in 2024. While the ETS focuses on reducing total emissions and therefore drives energy saving, FuelEU addresses the type and GHG intensity of fuels.
The responsibility for compliance under FuelEU and ETS lies with the ‘shipping company’. However, an implementing regulation of ETS clarified that the responsibility can stay with the shipowner rather than the Document of Compliance (DoC) holder. This change had no effect on FuelEU; therefore, the responsibility for FuelEU compliance is with the DoC holder.
Options for Compliance
While FuelEU obligates reduction of yearly GHG intensity, it takes a technology-neutral approach. To meet FuelEU targets, vessels have a suite of compliance pathways to choose from, each contributing to the reduction GHG intensity:
Flexibility measures are designed to assist those that either underachieve or overachieve on the emission reduction targets.
Allows companies to use a portion of anticipated surpluses from future years to comply with current year targets. A 10% borrowing penalty is applied to the compliance balance and added to the following period.
Enables companies with surplus reductions to save them for future compliance needs (with no expiration).
Vessels that overachieve on the intensity targets can generate value by monetizing excess compliance, known as ‘surplus’, with other vessels. If companies are able to find buyers for the surplus, pooling can become another source of revenue that potentially closes the cost gap between green and fossil fuels.
Regulatory Roadmap
Companies will need to submit a monitoring plan in August of 2024 and then will be responsible for working with an accredited EU verifier to submit an emissions balance in compliance with FuelEU intensity requirements (Figure 2).
FuelEU is the world’s first regional GHG intensity regulation of maritime fuels. It provides a comprehensive structure for reducing maritime GHG emissions through new sources of energy. By understanding mechanisms like pooling, the maritime industry can leverage the policy to enable investments in alternative fuel. Furthermore, as the IMO develops mid-term measures, preparing for FuelEU can give companies an advantage in an evolving policy landscape.
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