Looking for the best way to comply with FuelEU Maritime?
In this 60 second video, our Global Lead of New Fuels, James Shiller explains how we can help you reduce the cost of compliance.
Why take advantage of biofuels discounts now?
- HBE discounts are at a year-long high, and may soon fall.
- RED III implementation will likely tighten supply.
- Demand is expected to rise as companies rush to comply.
Buy and bank to secure the best and lowest-cost compliance.
Contact us before 1 November 2025.
Reach out to James
Our products and services:
FuelEU Maritime compliance options compared
This 3-minute video compares the four FuelEU Maritime compliance options, side by side.
Each option has a financial, reputational and operational cost.
Make a strategic decision that ensures compliance at the lowest cost to your company.
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The best way to comply with FuelEU Maritime?
From calculations through to compliance solutions, our dedicated new fuels experts will help you secure cost-efficient compliance.
Compare compliance options
Pooling
Pooling allows multiple companies or vessels to combine their compliance balances, spreading obligations and credits across the group. Pooling can lead to cost savings and provide effective emissions reductions across your fleet. However, pooling is more expensive than buying biofuels directly (Q4, 2025). Companies who pool get no improvements to their CII rating, and still need to purchase EU allowances under EU ETS. Pooling rules are complicated, and contracts are both expensive and time-intensive. Pooling providers can be unregulated, which exposes you to higher risks. If your pool fails, you will need to find another pool to avoid penalties for non-compliance.
Borrowing
If a ship exceeds its allowed emissions in a given year, it can borrow allowances from one future period. Borrowing offers temporary flexibility to cover unexpected compliance gaps. However, borrowing also increases your compliance costs by 10%. Borrowing also puts pressure on you to lock in a compliance surplus next year when compliance costs are expected to increase. If you borrow, you must still purchase EU allowances (like with pooling). And there is no positive impact on your CII rating. Public disclosure of your choice to borrow may cause reputational damage.
Biofuels
Biofuels are the simplest and cheapest way to comply with FuelEU Maritime. Buying compliant biofuels immediately reduces your vessel's greenhouse gas intensity in line with FuelEU requirements. You also avoid EU ETS obligations and improve your CII rating if you burn biofuels. Biofuels are more expensive than conventional fuels. But paying the penalty to burn conventional fuels is significantly more expensive and reputationally damaging. Over-compliance allows you to "bank" your surplus for future compliance periods. So don't miss out on biofuel discounts - contact us today. Our technical team can help you navigate any minor engine adjustments or concerns around lower energy density.
Contact our New Fuels TeamPaying the fine
Paying the penalty for non-compliance is the most expensive and high-risk option. If you exceed GHG intensity limits, you may face a penalty of €2,400 per metric ton of Very Low Sulphur Fuel Oil (VLSFO) equivalent that exceeds the limit. Non-compliance can damage both your commercial reputation and competitive advantage. Your vessels may even be prohibited from EU ports. Paying the fine is a choice we advise against - environmentally, financially and commercially.
3 great reasons to choose biofuels:
Decrease the number of EUAs you owe
Improve your CII rating
Improve your compliance balance for FuelEU Maritime
Learn about FuelEU Maritime requirements and compliance options with our expert team
Calculations for Green House Gas Intensity
This webinar recording answers the following questions:
1. What is GHG intensity?
2. What calculations do you need to make?
3. How does the FEUM mandate the use of low carbon fuels?
4. How to lower a vessel's GHG intensity?
5. How to calculate GHG intensity - step by step
6. How different compliance options affect your costs, GHGs and EU allowance requirements. (Case study)
CONTACT US
FAQ FuelEU Maritime
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Do I need to comply with both EU ETS and FuelEU Maritime?
Yes. If you fall under the scope of both FuelEU Maritime and EU ETS, you must comply with both regulations. Vessels above 5,000 GT calling at EU ports for commercial purposes are in scope. Strategic compliance planning is therefore critical to avoid unnecessary penalties. By purchasing biofuels to meet FuelEU Maritime requirements, companies can simultaneously reduce their need to purchase and surrender EU Allowances under the EU ETS. This approach effectively addresses compliance under both regulations in a single step - something that pooling, borrowing or penalty payments cannot achieve.
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What is the FuelEU Maritime regulation?
FuelEU Maritime is an EU regulation and one of the first to mandate a change in the marine fuel supply mix to achieve compliance. Each vessel must lower its Greenhouse Gas (GHG) intensity, which is determined by the type of fuel consumed on relevant voyages. To reduce GHG intensity, a low-carbon fuel must be included in the fuel mix. While other compliance mechanisms exist, low-carbon fuels are the most direct form of compliance.
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How is FuelEU Maritime related to EU ETS?
Fuel EU Maritime Regulation and the EU ETS are complementary. The EU ETS provides a regulatory framework for emissions reduction. In parallel, FuelEU Maritime supports the transition to low-carbon and renewable fuels, aligning with the goals of the EU ETS.
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What are the GHG intensity regulations?
They are rules based on the measure of GHG intensity: the grams of CO₂ equivalent emitted over the lifecycle of the fuel, divided by the megajoules (MJ) of energy it produces. FuelEU Maritime mandates a reduction to 89.3368 gCO₂eq/MJ for the average GHG intensity per vessel. The IMO’s Net Zero Framework (NZF) is still being finalized but is expected to introduce two GHG intensity benchmarks, penalizing those who cannot meet direct compliance.
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Which GHG’s are covered?
It depends on the regulation. From 2026, most regulations will include CO₂, CH₄, and N₂O.
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How do you calculate GHG intensity when using biofuel?
You need the Proof of Sustainability (PoS) or Proof of Compliance (PoC) for the biofuel to obtain its specific GHG intensity, often referred to as the “E” number. A minor adjustment is then applied, after which you have the effective GHG intensity of the biofuel.
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What is the FuelEU Maritime penalty?
The penalty is EUR 2,400 per metric tonne of VLSFO equivalent, calculated based on the vessel’s energy use and the difference between its GHG intensity and the target GHG intensity.
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What happens if penalties are not paid?
If a ship fails to comply with FuelEU Maritime for two or more consecutive reporting years, the competent authority of the EU Member State at the port of call can issue an expulsion order. The ship will then be barred from entering any EU port until compliance obligations are met.
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What is the "port of call" under the FuelEU Maritime?
As a rule of thumb, a port call is one where cargo is loaded or discharged for commercial purposes, except at designated transshipment ports. There are additional exemptions. If you are unsure, you should reach out to your fuel supplier or the New Fuels team for assistance.
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What is Banking, Borrowing, and Pooling?
Banking, borrowing, and pooling are compliance flexibility mechanisms under FuelEU Maritime:
- Banking: Surplus compliance (exceeding the required GHG intensity target) can be carried forward to future years.
- Borrowing: A company can borrow a limited amount of compliance balance from the following year to cover a current-year deficit, reducing flexibility in the next period.
- Pooling: Pooling can occur between vessels from different companies, not limited to a single ownership structure. Overcompliance from one vessel can offset the deficit of another, enabling collective compliance at a lower overall cost.
Compliance Deadlines
1 November 2025
Achieve compliance at the lowest possible cost by buying (and banking) biofuels in Dutch ports before 1 November 2025.
The opportunity for discounted biofuels is likely to end by 1 November. This is because HBE discounts are currently at a year-long high which is unlikely to extend past 1 November. Additionally, RED III implementation will likely tighten supply, and demand is expected to rise as companies rush to comply before year-end.
1 January 2026
Evaluate your remaining compliance options like pooling, borrowing, banking and paying the penalty.
31 January 2026
Submit your report to the verifier.
31 March 2026
Verifier records your report in the FuelEU database.
30 April 2026
Declare banking, borrowing or pooling with verifier.
1 May 2026
Verifier records compliance balance in FuelEU database.
30 June 2026
Verifier issues DoC or issues penalty.
31 December 2026
End of 2026 reporting period.
Download the banking whitepaper - FuelEU Maritime
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