A second EU maritime-emissions mechanism has now completed its first real cycle, alongside the better-known EU ETS. FuelEU Maritime (Regulation (EU) 2023/1805) applies to all commercial ships over 5,000 gross tonnage calling at EU/EEA ports, and unlike the ETS's cap on CO₂ allowances, it sets a shrinking limit on the greenhouse-gas intensity of the fuel a ship actually burns.
What just happened
The rule has applied since 1 January 2025, with 2025 as the first target year: ships had to cut their well-to-wake GHG intensity by 2% below a 2020 baseline (91.16 gCO2e/MJ) — a target that tightens to 6% by 2030, 14.5% by 2035, and 80% by 2050. Operators had to submit their first annual reports, covering that 2025 performance, by 31 January 2026. That first full reporting-and-verification cycle for 2025 is now behind us.
Falling short costs real money
A ship that doesn't hit its GHG-intensity target owes a penalty of roughly €2,400 per tonne of very-low-sulphur-fuel-oil-equivalent energy it's over the limit. Carriers have several ways to avoid it — blending in used cooking oil or other lower-intensity fuel, "borrowing" against a future compliance period (at a 10% surcharge), or pooling compliance across a fleet where one ship's surplus offsets another's shortfall — but where the shortfall isn't covered, the cost lands on the freight bill as a new surcharge line, separate from the existing EU ETS surcharge.
Not the same thing as the EU ETS
It's easy to conflate the two, but they're independent mechanisms stacking on the same voyage: the EU ETS prices actual CO₂ emissions via tradeable allowances (now at 100% phase-in for 2026), while FuelEU Maritime prices the fuel's GHG intensity regardless of the carbon-market price. Both can appear as separate line items on the same quote.
What it means for you
If your ocean freight invoices are showing a new charge alongside the familiar BAF and EU ETS surcharge, this is very likely it. For where this fits among all the other freight surcharges — BAF, CAF, THC, demurrage and the EU ETS: How freight is priced.
Sources: European Commission — FuelEU Maritime · ShipFinex — FuelEU Maritime compliance costs and penalties.