Research brief · November 2026

FuelEU Maritime: compliance on paper, transition on hold

Why the early compliance cycles did not shift fuel, and the reforms that could.

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Compliance became a paperwork exercise

90%+

of shipping companies used external pooling (Article 21) to comply

Cost to cover 1 t CO₂e of deficit

Statutory penalty

€640

Pool surplus credit (OPX, October 2026)

€96

Penalty = €2,400 per t VLSFO-eq deficit. Prices held near €200 through 2025, then fell below €100. Paper surplus now costs about 1/7 of the penalty.

Sources Mærsk Mc-Kinney Møller Center; OceanScore OPX

Existing assets captured the pool

Fossil LNG

Beats the 2020 baseline by design. Its cheap surplus was sold to oil-fuelled fleets.

Drop-in biodiesels

FAME B24/B30 blends need no engine or bunkering changes, so no CapEx.

E-fuels: under 5%

At 3–4× fossil cost, e-methanol, hydrogen and wind together made up <5% of early compliance.

Sources MMMCZCS, Lloyd's Register, Splash247

Fix 1–2: restrict pooling, ring-fence e-fuels

To prevent the regulation from becoming a permanent greenwashing mechanism, structural adjustments are being heavily negotiated.

External pooling cap

Cap the share of a vessel's deficit a third-party pool can cover (e.g. 45–50%). The rest must be cut on board.

LNG: internal use only

Fossil LNG surplus counts within the owner's own fleet, but cannot be sold on the open market.

RFNBO sub-quota

A strict, non-poolable 1–2% e-fuel share gives producers bankable demand to build plants.

Sources Reform proposals discussed around the Commission review

Fix 3: the 2030 cliff tightens supply

FuelEU targets tighten automatically. Even if reforms stall, the jump from −2% to −6% in 2030 shrinks the cheap surplus that keeps pooling prices low today.

Required cut in GHG intensity vs 2020

−2%

−6%

−14.5%

2025–29

2030

2035

2020 baseline: 91.16 gCO₂e/MJ

What changes from 2030

Less surplus: fossil LNG beats the target by a much smaller margin.
Pricier pooling: scarce surplus pushes prices toward the penalty.
E-fuels gain ground: long-term e-fuel contracts become easier to justify.

Sources Regulation (EU) 2023/1805, Art. 4

Fix 4: make the decision-maker pay

FuelEU bills the ship's ISM company, usually the owner. But under a time charter, the charterer chooses the fuel. Moving the cost to the charterer puts the price signal where fuel decisions are made.

Charterer decides
Chooses speed, route and fuel, so it drives emissions.
BIMCO FuelEU clause
The contract shifts FuelEU costs to the charterer.
Charterer pays
For pool credits or biofuel bunkers: the polluter pays.

Sources OceanScore & Gard, European Commission, MMMCZCS, LR