Rotterdam’s sharp drop in conventional bunker sales is being presented as a real-world warning of the regulatory fragmentation that IMO member states are hoping to avoid, according to PortXchange, a Rotterdam-based port emissions data company.
In an emailed press release reported by Ship & Bunker, PortXchange argues that the European Union’s country-by-country implementation of the Renewable Energy Directive III (RED III) is effectively a live test of what happens when decarbonisation rules for marine fuel suppliers differ between neighbouring jurisdictions. The company made its case ten weeks ahead of the IMO’s resumed vote on its Net-Zero Framework, and as Spain becomes the second EU member state to place a binding greenhouse gas intensity obligation directly on fuel suppliers rather than on the vessels themselves.
Rotterdam’s Falling Volumes
According to Ship & Bunker, the Dutch transposition of RED III took effect on January 1, 2026, requiring suppliers to cut the GHG intensity of bunker fuel sold in the Netherlands. In the first quarter that followed, Rotterdam’s conventional bunker sales fell to 1.58 million mt — down 28.1% year-on-year and 27.2% from the prior quarter, marking the lowest quarterly figure since at least 2010. Including biofuel blends, the total was 1.69 million mt, still down 26.8% on the year.
Second-quarter sales, including biofuels, came in at 1.75 million mt, down 26.7% year-on-year, though up 4% from the first quarter. By contrast, Ship & Bunker reports that neighbouring Antwerp-Bruges sold approximately 2 million mt over the same period, an increase of 5.5%.
Where the Volume Went
PortXchange contends that because Belgium delayed its own equivalent regulation and Germany excluded international shipping from its transposition, the volume lost by Rotterdam simply relocated to ports without similar obligations, rather than resulting in genuine emissions reductions. Ship & Bunker notes this outcome mirrors a prediction made earlier this year by bunker supplier Peninsula.
PortXchange estimates Rotterdam’s compliance-driven price premium over its nearest competitor reached $20-25/mt by September. Ship & Bunker’s own data show Rotterdam VLSFO averaging $13.50/mt above Antwerp so far this month, peaking at $26.50/mt on September 11, after trading at parity in the final quarter of 2025.
“Netherlands played it straight. Belgium delayed. Germany opted out. And the volume did exactly what volume does when the rules aren’t the same next door: it moved,” said PortXchange managing director and co-founder Sjoerd de Jager, as quoted by Ship & Bunker. “Spain’s next. The real question is who else is willing to go first without checking whether anyone’s coming with them.”
Spain’s Different Approach
Spain’s Royal Decree 611/2026, published July 23 and reported by Ship & Bunker, sets a GHG intensity reduction curve for fuel suppliers rising from 6.5% in 2027 to 33% in 2040, alongside a renewable fuel sub-target climbing from 2% to 20% over the same period. Notably, the Spanish rule applies only to fuel supplied for domestic cabotage, not to international shipping bunkering at Spanish ports — meaning hubs such as Algeciras and Barcelona face different exposure than Rotterdam.
IMO Vote Looms
With the IMO’s Net-Zero Framework vote due December 4, PortXchange argues the Rotterdam experience should inform member states weighing whether a single global measure is achievable. Ship & Bunker notes that adoption was already delayed by a year following an October 2025 extraordinary session, where members voted 57-49 to adjourn. The process now moves through an intersessional working group on November 23-27, MEPC 85 from November 30, and the resumed extraordinary session on December 4.
“Two governments have now shown what happens when the transition isn’t coordinated: the tonnes move, the emissions don’t,” de Jager said, according to Ship & Bunker. “The industry doesn’t need another debate about who regulates first. It needs ports, suppliers and regulators acting together before December, not after. That’s not a policy preference. It’s a survival strategy.”
Does This Matter to You?
The Rotterdam data illustrates how uneven regulatory timelines between neighbouring bunkering hubs can shift trade flows and pricing, as demonstrated by the premium gap now recorded between Rotterdam and Antwerp. Bunker buyers and vessel operators calling at European ports may see cost differences depending on which jurisdiction they bunker in, while suppliers face varying compliance obligations depending on the port and cargo type, as seen in Spain’s cabotage-only rule versus the Netherlands’ broader scope.
The outcome of the IMO’s December vote on the Net-Zero Framework could determine whether such national-level divergence continues or is replaced by a more uniform global approach, which would affect how compliance costs and fuel choices are distributed across bunkering markets going forward.
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
