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Today, pooling is widely recognised as a reliable compliance mechanism under FuelEU Maritime. In most commercial discussions, the underlying assumption is that once a pool is agreed, it will be executed. This assumption deserves closer investigation. In practice, pooling is not a single step but a multi-stage process with dependencies and hard deadlines. The successful execution of a pool requires that each of these steps is completed correctly and in sequence by all pool par

Borrowing under FuelEU Maritime is often described in market discussions as a convenient fallback option. The narrative is simple: if a pool does not work out or surplus cannot be sourced at an acceptable price, the vessel can simply borrow compliance from the following year. This narrative is misleading. Borrowing is not designed as a universal safety net, and in many practical situations it cannot even cover the deficit of a single conventional vessel. In addition, the regu

FuelEU Maritime allows pooling as one of its flexibility mechanisms. Under Article 21 of the Regulation, companies may group vessels in a pool to reallocate compliance balances, provided the pool satisfies the regulatory conditions on surplus/deficit allocation and total positive balance (see previous newsletter ). In April of the year following the reporting period (for the first time April 2026), pools and their allocations must be recorded in the Official FuelEU Database a

As regulatory obligations under FuelEU Maritime begin to settle into market practice, maritime lawyers and shipowners face new challenges: crafting robust S&P contracts for ships that safeguard from unexpected regulatory and commercial liability. While our previous newsletter addressed the general compliance responsibilities of buyers and sellers ( “Selling and Buying Ships Under FuelEU Maritime” ), this edition moves beyond theory and provides actionable legal guidance for d

Each week, more stakeholders enter the FuelEU Maritime pooling market, and with it comes growing uncertainty about what can and should be traded. One recurring misconception is the idea of trading only “already generated surplus.” While it seems like a cautious approach to not buy something that doesn't exist yet, it overlooks the annual nature of FuelEU Maritime compliance. FuelEU Calculations & Annual Energy Consumption FuelEU Maritime does not measure compliance at any sin

As the first FuelEU Maritime compliance cycle progresses, the surplus market has expanded rapidly. What began as a maritime compliance instrument has evolved into a traded commodity, and in doing so, it has attracted far more participants than the regulation or its creators appear to have anticipated. FuelEU pooling rights and who holds them The regulation assigns the compliance responsibility and as such the right to pool to the ISM company. However, contractual arrangements

FuelEU Maritime compliance brings new commercial challenges. While the regulation defines penalties and created a surplus trading market,...

BetterSea & its Co-Founder Maximilian Schroer Featured in Industry Insight on EU Emissions Regulations, EU ETS and FuelEU Maritime. The...

BetterSea Calculator Cited for Delivering Cost-Efficient FuelEU Strategy As enforcement of the FuelEU Maritime regulation nears, Lloyd’s...