Pooling emerged as the clear preference among shipowners navigating the first year of FuelEU Maritime reporting, with 92% of vessels using the mechanism, according to an analysis by P&I club Skuld.
The report, authored by Skuld’s decarbonisation and transition risk lead Matias Bøe Olsen, draws on European Commission data and a review conducted by the Maersk Mc-Kinney Møller Center for Zero Carbon Shipping, along with an interview with the Center’s climate policy manager Joe Bettles, as reported by Ship & Bunker.
Pooling Outpaces Alternatives
According to Ship & Bunker, only 2% of vessels opted for the borrowing mechanism, which pushes a compliance deficit into the following year in exchange for a 10% surcharge. The remaining vessels either paid the penalty outright or achieved compliance directly through LNG or other low-GHG energy sources.
The analysis notes that the price for trading compliance surplus averaged around EUR 208 per tonne of CO2-equivalent and held steady throughout the year. This price sat well below the EUR 640/tCO2eq penalty applied to VLSFO, a gap that made pooling a far more attractive route than absorbing penalties, Bettles told Ship & Bunker.
Fuel Mix Behind the Numbers
According to the Center’s estimates cited by Ship & Bunker, the fleet will need 3.22 million tonnes of CO2-equivalent reductions relative to an all-VLSFO baseline to hit the 2% reduction target set for the 2025-2029 period. LNG is estimated to have delivered roughly a third of the reductions achieved so far, with biofuel blends — primarily biodiesel and bio-LNG — making up the balance.
Bettles explained to Ship & Bunker that even though LNG cannot be dropped directly into conventional engines, the pooling structure under FuelEU allows LNG-fuelled vessels to share their over-compliance with ships unable to use LNG physically. He added that, depending on engine type, LNG-fuelled vessels can maintain compliance with the 14.5% reduction target through 2039, with further flexibility available through banked surplus or liquefied biomethane use.
Implications Beyond Europe
Bettles told Ship & Bunker that the first-year findings carry relevance beyond the EU, particularly as IMO member states prepare to resume negotiations on the Net-Zero Framework. He said FuelEU shows that a global fleet can comply with a GHG intensity regulation using existing fuels while still incentivizing cleaner energy uptake.
The Skuld analysis draws three broader lessons from the first reporting year, as reported by Ship & Bunker: that a fuel standard for shipping can function in practice, that future regulations should support a wider mix of energy sources given limited uptake of wind-assisted propulsion, e-fuels, and onshore power, and that policy stability with clear reduction pathways strengthens the investment case for cleaner alternatives.
Does This Matter to You?
These first-year compliance patterns offer an early signal of how flexibility mechanisms under FuelEU Maritime are being used in practice, which may be relevant for those tracking compliance costs, fuel procurement strategy, or emissions trading dynamics tied to vessel operations calling at European ports. The relative price stability of compliance surplus versus the penalty rate, as detailed by Ship & Bunker, could factor into cost planning for parties exposed to FuelEU obligations. The direct implications for broader bunkering and trading decisions beyond the EU framework are not detailed in the source material.
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
