Case Study IX: Biofuel vs Pooling – A Real-World Voyage Scenario
- Maximilian Schroer
- Jun 22
- 3 min read

As shipping companies navigate the complex cost landscape shaped by FuelEU Maritime, understanding the trade-offs between compliance options becomes essential. This week, we revisit the biofuel vs pooling discussion of previous newsletters with a focused case study: a containership on a transatlantic voyage.
Voyage Details:
Route: New York to Hamburg
Speed: 24 knots
Duration: ~6 days
Fuel Consumption (50%): 200 tonnes MDO + 450 tonnes VLSFO
Regulatory Scope: 50% exposure to FuelEU Maritime
The Cost of Inaction
Without any compliance strategy in place, this single voyage results in overall OPEX costs including EU ETS and FuelEU penalty of €471,600. Paying the FuelEU penalty will further increase the cost exposure in subsequent years due to an increase in penalty of 10%. This number highlights the importance of evaluating proactive measures such as biofuel or pooling.
GHG Intensity: 91.43 gCO₂e/MJ
Compliance Deficit: –56 t CO₂e
FuelEU Penalty: €35,911
EU ETS Costs: €107,231*
Fuel Costs: €328,452*
Total OPEX: ~€471,600
Biofuel – Possible, But Challenging
Swapping MDO for 26t of Bio100* brings the ship’s GHG intensity down to 89.34 gCO₂e/MJ, just enough to reach a zero compliance balance. The results:
GHG Intensity: 89.34 gCO₂e/MJ
Compliance Balance: 0 t CO₂e
FuelEU Penalty: €0
EU ETS Costs: €103,410*
Fuel Costs: €361,375*
Total OPEX: ~€465,085
Note, that the market reality introduces another constraint: stem size. Industry practice and supply chain economics typically require minimum stem volumes of at least 150 tonnes or more for biofuel deliveries. Even more critically, pricing and availability vary significantly across ports. While a supplier in Rotterdam may offer competitive pricing and fuel quality, this might not be true for New York or other global bunkering hubs.
Please also acknowledge that while ESSF's Fuel Certification Guidance illudes to it, there has been no official statement by the European Commission that HBE-incentivized fuels can be used under FuelEU increasing the risk factor when using cheaper biofuels in Rotterdam.
Pooling – Straight forward with BetterSea
An alternative strategy is to buy 56 tonnes of CO₂e surplus via solutions such as BetterSea’s FuelEU Pooling Marketplace:
GHG Intensity: 91.43 gCO₂e/MJ
Compliance Deficit: –56 t CO₂e
FuelEU Pooling Costs: €14,303*
FuelEU Penalty: €0
EU ETS Costs: €107,231
Fuel Costs: €328,452*
Total OPEX: ~€449,990
In this case, pooling the voyage emissions deficit costs only €14,303, reducing the overall OPEX substantially. Pooling is a fast and efficient compliance solution that avoids the complexities of biofuel bunkering and is well-suited for vessels without established green fuel procurement channels. In this example, pooling remains not only a straight forward but also the cheapest compliance option.
Note that pooling comes with its own legal and financial complexities that require a well-planned, standardized, and trusted execution process such as the workflow established and widely used on BetterSea's FuelEU Pooling Marketplace.
Biofuel vs Pooling Key – Takeaway
While biofuel continues to be an important pathway in decarbonization, it isn’t always the best tool for every compliance situation—especially in short-term, low-volume scenarios. Pooling and surplus trading emerge as essential strategic levers that ship operators should master.
BetterSea’s FuelEU Maritime Compliance Platform with integrated pooling marketplace provides you with a fast, streamlined, end-to-end process covering all potential compliance options, including external pooling and surplus trading. It allows you to comprehensively strategize your FuelEU and EU ETS compliance on a ship-specific level amidst volatile markets. Book a demo below and get access afterwards!
Stay tuned for more insights on navigating maritime decarbonisation compliance in our upcoming newsletters. If you have any questions or need further guidance, feel free to reach out!
Best regards,
The BetterSea Team
Contact Us: info@bettersea.tech
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*Assumptions: Fuel prices from S&P Platts, Surplus value 255€/tCO2e, EUA value 75€/tCO2, Bio100 LCV 0.03720 MJ/g, Bio100 GHG Intensity 32.9 gCO2e/MJ



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