New voyage-level data has revealed how the routing of container ships between Asia and Europe can dramatically alter their exposure to the EU Emissions Trading System (EU ETS), according to a case study by supply chain emissions data firm VesselBot, as reported by Ship & Bunker.
According to Ship & Bunker, VesselBot’s analysis found that seven voyages travelling from Singapore to Felixstowe and then on to Zeebrugge had only 0.5% of their total emissions falling within the scope of the EU ETS. This is because the UK sits outside the EU scheme, meaning the long Singapore-to-Felixstowe leg is entirely excluded, while only half of the shorter Felixstowe-to-Zeebrugge crossing counts toward allowance obligations.
The Numbers Behind the Study
VesselBot’s broader dataset, cited by Ship & Bunker, covers more than 20,000 containership voyages linked to EU and EEA ports in the second quarter of 2026. These voyages generated an estimated 11.8 million tonnes of CO2 equivalent, of which 7.15 million tonnes, or 60 percent, required allowances. At an assumed allowance price of 80 euros per tonne, VesselBot estimates the total quarterly ETS bill for container lines at roughly 572.4 million euros.
Looking specifically at direct Singapore-to-Europe services, VesselBot examined 58 voyages operated by one major container line running to Rotterdam, Valencia, and Piraeus. The study calculated an ETS cost of 26.3 to 30.5 euros per TEU on these routes, compared to the carrier’s published Energy Transition Surcharge of 70 euros per TEU to Rotterdam and 56 euros per TEU to Valencia and Piraeus. VesselBot notes that this gap should not be interpreted as evidence of overcharging, since the surcharge also factors in FuelEU Maritime compliance costs and other commercial considerations beyond the scope of the ETS analysis.
A Familiar Schedule Effect
For the seven voyages routed via Felixstowe before Zeebrugge, VesselBot calculated an ETS exposure of just 4,400 to 6,000 euros per voyage, which is less than the 7,000 euros that a single 100-TEU shipment would generate under the published 70 euros per TEU Zeebrugge surcharge. Ship & Bunker’s own calculations from the study data show that direct Singapore-to-Rotterdam voyages carried an average ETS exposure of about 474,000 euros each, compared to roughly 5,000 euros for voyages that first called at Felixstowe.
Ship & Bunker notes this pattern echoes a 2024 Sea-Intelligence estimate it previously reported, which found Brexit had reduced ETS-reportable distance on some North Atlantic services by as much as 73 percent, since only the final port of call counts under EU rules and UK ports fall outside the scheme.
VesselBot was careful to caveat its findings, stating that the Felixstowe routing pattern is consistent with, though not proof of, deliberate scheduling to reduce ETS exposure, adding that the data should be read as suggestive rather than conclusive. The firm also pointed out that each vessel carried fewer containers out of Felixstowe than it brought in, consistent with genuine cargo-handling calls rather than token stops designed purely to reset voyage scope under EU rules.
Regulatory Backdrop
According to Ship & Bunker, the UK’s own emissions trading scheme began covering shipping on July 1 but currently applies only to domestic voyages and port emissions, with international voyage coverage proposed from 2028. Separately, the European Commission proposed tighter rules in July concerning vessel calls at nearby non-EU ports, which could affect future routing strategies of this kind.
Does This Matter to You?
This data may be relevant to those monitoring container freight surcharges, carbon compliance costs, and route planning across Asia-Europe trades. The findings suggest that published Energy Transition Surcharges do not necessarily reflect the actual EU ETS cost of a specific voyage, and that routing decisions, particularly calls at UK ports, can significantly change a shipment’s carbon allowance exposure. Cargo owners, charterers, and bunker buyers tracking compliance costs on these lanes may find the gap between surcharges and underlying ETS liability, as well as the regulatory scrutiny on non-EU port calls, useful context for understanding how carriers price and route services under the EU ETS framework.
Gulf Bunkering does not provide operational or security guidance. This article is for informational purposes only. Operators should consult flag state authorities, P&I clubs, and relevant advisories for decisions relating to transit planning.
Sources: Ship & Bunker
