Frequently Asked Questions

The FuelEU Maritime Regulation is part of EU’s Fit for 55 package targeting the uptake of low-carbon fuels in the maritime industry. It assesses the well-to-wake greenhouse gas intensity of ships above 5,000 GT calling EU ports based on a regulatory limit. In case of non-compliance, shipping companies face a penalty of 2,400 €/t VLSFOe.

In contrast to other environmental regulations such as CII and EU ETS, FuelEU Maritime not only considers greenhouse gas emissions instead of only CO2 but also the full lifecycle of the fuel. This approach is generally referred to as well-to-wake (WtW).

FuelEU Maritime allows for a number of different compliance means and mechanisms. Direct compliance can be achieved with the use of alternative fuels (e.g., biofuels or RFNBOs), wind-assisted propulsion, and onshore power supply. By 2030, the latter becomes mandatory for container and passenger ships. On top of these direct options, the regulation created different compliance mechanisms: banking, borrowing, and pooling.

Any over-compliance achieved under FuelEU can be banked infinitely and utilised in later compliance years. On the contrary, borrowing refers to covering up to 2% under-compliance with a ship’s next year compliance balance. Pooling describes the grouping of vessels to share positive compliance balance (surplus) and achieve compliance with the regulation (please read more under “What is pooling?”). Lastly, a penalty can be paid (2,400 EUR/t VLSFOe) but consecutive non-compliance will be additionally penalised.

Pooling is one of the mechanisms shipping companies can utilise under the FuelEU Maritime Regulation to achieve compliance. It allows companies to comply on a group rather than ship level. Within a group of ships, so-called pools, compliance is determined by summing the compliance balances (numerical value showing compliance under FuelEU) of each ship. This allows for over-compliant ships to offset under-compliant ships and shall foster long-term investments in low-carbon fleets. Pooling is not restricted to single companies but can also be done in a Business-to-Business (B2B) environment.

Pooling offers a straightforward compliance option for companies with under-compliance, requiring no investments or technical adjustments to the ship. It avoids technical or commercial risks associated with alternative fuels, such as engine damage or supply constraints. For companies with over-compliance, pooling allows for the commercialization of emission reductions, similar to book-and-claim schemes on the voluntary market.

The price of external pooling under FuelEU Maritime, commonly referred to as surplus value, is likely to be volatile and seasonal with an expected higher value by the end of the compliance period and before final pool reporting date (30th April of the following year). Several studies have been conducted to forecast the value. BetterSea has also done market research, during which the average price was 421 EUR/t CO2e with a spread of 250 to 550 EUR/t CO2e. While the actual price remains exposed to volatility, the value will naturally be capped at 640 EUR/t CO2e, the penalty price. Some companies may also compare the surplus value with corresponding biofuel prices to find the most cost-effective compliance option.

The deadline stipulated by the FuelEU Maritime Regulation for pool verification and reporting is the 30th of April of the following year. For the reporting period 2025, this would be 30th April 2026.

Pooling is a completely new compliance mechanism with several complexities such as contractual arrangements, liabilities of pooling partners, and data alignment. Further, the price of external pooling, commonly referred to as surplus value, is likely to be volatile and seasonal with an expected higher value by the end of the compliance period and before the final pool reporting date (30th April of the following year). Engaging in pooling early can therefore significantly decrease the cost of compliance with FuelEU Maritime and ultimately does not expose any additional risk as unutilised surplus can always be banked for use in future compliance periods.