EU ETS: European Union's Emissions Trading System

It should be considered! From the beginning of 2026, the EU ETS is 100% phased in for maritime. Nitrous Oxide and Methane are also now in scope. This means that an increase of approximately 44% in costs for EUAs compared to 2025 (assuming the price of allowances remains at 2025 levels).  ETS is not the only EU regulation to consider. From 2025, FuelEU Maritime requires you to lower the GHG intensity in your fuel mix. Biofuel for instance is a "plug 'n play" compliance solution.
If you would like to compare compliance costs, reach out to our New Fuels team to access our decision tool.  

In the case of a shipping company that is not registered in an EU Member State, it will be the EU Member State with the greatest estimated number of port calls from voyages performed by that shipping company in the last four monitoring years.
 
In the case of a shipping company that is not registered in an EU Member State and that did not carry out any voyage falling within the scope of the EU ETS Directive in the preceding four monitoring years, the administering authority will be the EU Member State where a ship of the shipping company has arrived or started its first voyage falling within the scope of the EU ETS Directive.
 
The concrete action also depends on whether you are the doc holder  or you require mandate from the doc holder.
 

The process for opening a trading account is online and open to non-EU citizens, subject to conditions spelt out by each EU Member State (through their National Administrator). Users must first open an account in the Union Registry to be able to trade EU allowances.
Each Member State has individual requirements. So, in short, it needs to be checked with the administrating authority in the Member State in question.
Each Member State has individual requirements. So, in short, it needs to be checked with the administrating authority in the Member State in question.

The ETS regulation is flag neutral meaning that it applies to all vessels regardless of the flag they fly. Meanwhile the geographic scope is as follows: 100% of all voyages intra EU and 50% of in and outbound voyages to third countries.

It has nothing to do with how much cargo you transport, load or discharge. If you discharge in a port in a non-EU country that fulfills the requirements (300 NM and at least 65 % of container activity) then it will not count as a port call.

As of now STS operations are exempted ie. it will not count as a port call and thereby not be covered by ETS. The EU Commission will monitor this and its case in turns that this is used as a loophole ´resulting in major evasion, then the regulation is likely to be changed.