Thu 14 Dec 2023 11:14 | Nathan Dobson

How the EU ETS impacts non-EU nations and shippers

Examaning the ETS and key issues for non-EU players ahead of implementation.

Flag of the European Union in front of the EU Parliament in Brussels, Belgium.

The impact of the implementation of the Emissions Trading System (ETS) is set to be felt by shippers and states outside of the EU. Image: Christian Lue/Unsplash

With the European Union ruling that its Emissions Trading System (ETS) will include shipping from January 1, 2024, the impact that this will have on non-EU nations and shippers is being keenly anticipated. The system will be based on the route of the ship, meaning that voyages between ports within the EU will have 100% of their emissions included in the ETS, whilst ships starting or ending their journey outside of the EU, 50%.

This has led some critics to suggest that there would be an increase in the use of ports that are close to Europe but not inside. For example, Egypt’s East Port Said and Morocco’s Tanger Med. However, ships using transshipment ports less than 300 nm from an EU port will also need to include 50% of emissions to that port as well as the shorter leg from just outside of the EU.

At the end of each year, shipping companies will submit details of their voyages and emissions to the administering authority (member state) with which they are registered. Registration depends on which member state the company has visited the most over the last four years. Or, for newer companies, their first port call. An independent verifier will then review the reports and issue a Document of Compliance for each ship.

For each tonne of carbon dioxide emitted by their ships, companies will need to have purchased allowances that they will submit to the administering authority by September of the next calendar year being reported. This will be phased-in: allowances will reflect 40% of emissions in 2024, 70% in 2025 and 100% from 2026 onwards.

The purchasing of allowances must now be factored into pricing between stakeholders in the value chain and most companies have already announced estimates of the extra charges. These range from Maersk’s 228 euro charge for forty-foot reefer containers between Europe and West Africa and Hapag-Lloyd’s 7 euro charge for a twenty-foot dry container between East Asia and South Europe.[1][2] Shippers already signed up to Hapag-Lloyd’s Ship Green programme or Maersk’s Eco Delivery will receive credit to offset the costs.

Maersk EU ETS surcharge estimates Q1 2024

EU Emissions Trading System (EU ETS) surcharge estimates, in EUR per forty-foot container (FEU)

Trade RouteDry fee per FEU (EUR)Reefer fee per FEU (EUR)
West Coast South America to Europe74111
Europe to West Coast South America83125
North Europe to Far East4669
Far East to North Europe70105
South Europe to Far East1117
Far East to South Europe 2030
North Europe to Middle East & Indian Subcontinent3248
Middle East & Indian Subcontinent to North Europe2538
Mediterranean to Middle East & Indian Subcontinent5583
Middle East & Indian Subcontinent to Mediterranean3654
Mediterranean to North Europe4162
North Europe to Mediterranean4162
Intra Mediterranean4568
Intra North Europe2233
North America to Mediterranean6699
Mediterranean to North America91137
Oceania - Europe, Middle east & Africa2132
Europe, Middle east & Africa to Oceania3756
South Africa to Europe6699
Europe to South Africa4771
Canada to North Europe4974
North Europe to Canada81122
USA to North Europe5887
North Europe to USA81122
West Africa to Europe87131
Europe to West Africa152228
Europe to East Coast South America4974
East Coast South America to Europe4060
East Africa to Europe3654
Europe  to East Africa5684
Europe to Indian Ocean Islands3147
Indian Ocean Islands to Europe1624

Maersk estimates of Q1 2024 emissions surcharge (in EUR) per FEU. Table: Bunker Index | Data: Maersk[3]

Hapag-Lloyd EU ETS surcharge estimates for 2024

EU Emissions Trading System (EU ETS) surcharge estimates, in EUR per twenty-foot container (TEU)

Trade RouteDry fee per TEU (EUR)Reefer fee per TEU (EUR)
East Asia – North Europe1231
East Asia – South Europe716
North Europe – North Am East Coast incl. MX East Coast916
North Europe – South America West Coast1221
Europe – West Africa1729
North Europe – Middle East1222

Hapag-Lloyd estimates of 2024 emissions surcharge (in EUR) per TEU. Table: Bunker Index | Data: Hapag-Lloyd[4]

CMA-CGM EU ETS surcharge estimates

EU Emissions Trading System (EU ETS) surcharge estimates, in EUR per twenty-foot container (TEU)

Trade routeDry fee per TEU (EUR)Reefer fee per TEU (EUR)
Asia to North Europe2540
Asia to Mediterranean2030
Europe to North America4365
Europe to South America West Coast4360
North Europe to Mediterranean2535
Intra Mediterranean2540
Intra North Europe3748

CMA-CGM estimates of emissions surcharge (in EUR) per TEU. Table: Bunker Index | Data: CMA-CGM[5]

Whilst most companies have calculated the surcharges on top of the contracted rates, companies that operate in and out of China have had to take notice of Shanghai Shipping Exchange regulations that mean charges have to be added to the base freight rate (instead of as an additional surcharge).[6] An exception also applies for Maersk into and out of Djibouti and Ethiopia, where charges will be on a prepaid basis.[7]

The big question is whether these fees will be enough to divert traffic away from Europe. Large volumes of ships stop at Europe on their way to other destinations. Ministers from seven European nations are understood to have already expressed their concern that the measures will in fact increase global emissions, with shippers bypassing Europe and taking longer routes.[8]

The scheme classifies a port of call as one where a ship loads or unloads cargo, embarks or disembarks passengers, or where an offshore ship stops to relieve the crew.[9] Ports in North Africa, Turkey and the Middle East are likely to change their approach to try and attract ships that would have usually gone to locations such as Greece or Italy. A study from the Port of Barcelona expects that African ports will benefit through economic expansions and greater ties with European ports.[10] Another way to avoid the system would be to use ship-to-ship transfers.

Yet, the charges seem largely insignificant when placed alongside the large swings in bunker prices. Between 2020 and 2022, for example, Bunker Index price data shows that Rotterdam recorded a price spread for very-low-sulphur fuel oil (VLSFO) and marine gasoil (MGO) of $864 and $1291 per tonne, respectively (see chart below). Freight rates have also been at record lows.

Fuel GradeLow ($)High ($)Spread ($)
HSFO 380110736626
VLSFO 0.5%1501014864

Chart showing price volatility in Rotterdam for HSFO 380, VLSFO 0.5% and MGO between 2020 and 2022. Chart: Bunker Index | Data: Bunker Index

Carriers may include the new surcharges but be forced to change their base rate at the same time. At stake is the question of whether carrier costs (of which ETS charges are now a part) have any significant impact on freight rates when there are so many other factors that determine supply and demand. It is difficult to see the ETS charges causing disruptions amongst these broader forces.

The International Maritime Organisation (IMO) has so far failed to implement a global policy, but plans are in place. A GHG pricing mechanism was part of its basket of candidate mid-term GHG reduction measures (in the 2023 GHG Strategy), and it is expected to be approved at MEPC 83 (Spring 2025) and enter into force 16 months after adoption (in 2027). Looking ahead, it will be interesting to see how the EU's ETS works in conjunction with the forthcoming policy.

As regards IMO's candidate measures, The Marshall Islands and the Solomon Islands have pushed for a Universal Mandatory GHG levy. The GHGL would be paid at the same time as the ship’s fuel and its revenues would be used to fund decarbonization in the shipping sector.

The proposed fund and reward system (F&R) by the International Chamber of Shipping (ICS) would charge ships a levy-based flat rate per tonne of CO2 emitted. It would be calculated on a tank-to-wake basis using the existing Fuel Oil Data Collection System (DCS), with contributions going to a fund that would be used to reward CO2 emissions prevented via the use of alternative fuels.

The International Maritime Sustainability Funding and Reward (IMSF&R) system by Argentina et al. proposes a fund and reward system based on the existing CII measure and on DCS. A ship with CO2 emissions above its upper benchmark level (based on rating boundaries set out in the CII Rating Guidelines, as well as its capacity) would pay for its extra emissions, whilst a ship with CO2 emissions below the lower benchmark level would be rewarded for emissions reduced.

The grievances Brazil and China have over the extra costs are tied up with the broader concerns of the BASIC group of large, emerging economies (Brazil, China, India and South Africa) raised at the recent COP28 about Europe’s new EU ETS as the EU is the primary importer of coffee from Brazil and one of the top importers of cattle, wood, cocoa, rubber and soybeans from the country.

Perhaps the murkiest area for non-EU shippers is how the EU ETS will affect charterers. Charterers are usually held responsible for decisions about the movement — and therefore emissions — of the ship. However, it is likely that the charterer will pass on the costs to those that need the goods moved, and how allowances will be transferred is a particularly grey area in the legislation. This could mean different member states adopt different approaches as to deciding where the responsibility lies. Whether or not charterers choose to wait and see what happens to the price of allowances or whether they are active in the new carbon markets is likely to have a lasting impact.


[1] Sign up to a subscription plan to view notes and source information.
[2] Sign up to a subscription plan to view notes and source information.
[3] Sign up to a subscription plan to view notes and source information.
[4] Sign up to a subscription plan to view notes and source information.
[5] Sign up to a subscription plan to view notes and source information.
[6] Sign up to a subscription plan to view notes and source information.
[7] Sign up to a subscription plan to view notes and source information.
[8] Sign up to a subscription plan to view notes and source information.
[9] Sign up to a subscription plan to view notes and source information.
[10] Sign up to a subscription plan to view notes and source information.

Risk chart outlining likelihood of bad bunkers Mitigating the risks of bad bunkers  

Article by Steve Bee, VPS Group Commercial Director; Dr Malcolm Cooper, VPS CEO; and Stanley George, VPS Group Science & Technical Manager.

Air Liquide and Vopak sign ammonia MoU. Air Liquide and Vopak to collaborate on ammonia project in Singapore  

MoU to develop infrastructure for ammonia import, cracking and hydrogen distribution in Asian city-state.

Wärtsilä NH3 Ammonia label. Wärtsilä launches Ammonia Fuel Supply System  

System available for liquid and gaseous fuel, gas and non-gas carriers, and newbuilds and retrofits.

Panagiotis Bastas, head of Greece office, Aurora Marine Fuels (AMF) New Greece manager at Aurora Marine Fuels  

Panagiotis Bastas named head of the company's Athens office.

Adrian Beciri, CEO of Ducat Maritime From greenwashing to 'wacky' bunker margins  

Interview with Adrian Beciri, CEO of Ducat Maritime.

Algebra illustration. ISO 8217 formula 'not suitable' for gauging FAME fuel energy content: VPS  

Accurate measurement can only be determined using calorimetry, says testing firm.

Water drop on body of water, creating a ripple effect. Will the EU ETS move prices and inspire innovation?  

Examining whether carbon pricing is likely to have an effect on emissions reduction.

Origami ship made from Euro money. Who will bear the cost of EU emission allowances?  

Analysing the purchase of allowances to offset emissions.

Worm's eye view of four stone structures during daytime. Four cornerstones for a regulatory environment for sustainable fuels  

An analysis of the World Shipping Council's paper to IMO's Marine Environment Protection Committee (MEPC).

Maerk's first large (16,000 TEU) methanol-enabled vessel. Maersk signs green methanol deal with China's Goldwind  

Agreed annual volume of 500KT for Maersk's first 12 large methanol-fuelled ships.

↑  Back to Top