With the introduction of FuelEU Maritime following the famous EU ETS, shipping companies must make strategic decisions about meeting their compliance obligations at the lowest cost. Two of the most prominent pathways are:
Using biofuels to reduce a vessel’s greenhouse gas (GHG) intensity.
Purchasing surplus and pooling to offset compliance deficits at a lower cost.
But when is one option better than the other? Using real biofuel market data, we provide a FuelEU surplus value threshold for a sample case that may help shipping companies decide whether to buy biofuel or surplus.
Key Calculation: When Does The FuelEU Surplus Value Become More Expensive Than The Biofuel Premium?
Reminder: The Baseline
A sample containership consumes 10,000 tonnes of HFO within the FuelEU scope. Given its fossil fuel usage, the ship incurs a compliance deficit of 975 t CO2e in 2025 and 1,510,601.40 € in EU ETS compliance costs (considering an EUA price of 69.30 € as per EEX data from February 28th). The shipping company can decide to buy surplus and pool externally or bunker biofuel. For our analysis, we have used the below fuel price assumptions based on S&P Global data from February 28th:
542.50 €/t VLSFOe (0.5%S VLSFO in Rotterdam)
755.86 €/t VLSFOe (Bio30 Fame in Rotterdam)
The above results in a biofuel premium of 213.36 €/t VLSFOe. This value has been used as the underlying assumption for the case study.
The Results: Surplus is More Expensive at Prices Higher Than 255€
Based on the above-described sample case, the following data has been calculated to enable the comparison between pooling costs and biofuel costs.
EU ETS costs (with biofuel usage): 1,443,380 €
Fuel cost premium: 316,484 €
The below graph depicts the interplay between the assumed biofuel premium and the surplus value. The intersection with the x-axis resembles the turning point at which surplus becomes more expensive than biofuel considering this sample case.
Our sample case shows that purchasing surplus and pooling remains the most cost-effective option until the surplus price exceeds about 255 €/tCO₂e.
If the surplus price is at or below about 255 €/tCO₂e, then purchasing surplus is the cheapest way to comply.
If the surplus price exceeds 255 €/tCO₂e, then bunkering biofuel becomes a better option in terms of cost.
Note that this is based on our sample case and its underlying assumptions. For a more detailed study using your own data, check out BetterSea's free, online FuelEU Maritime Calculator.
Beyond Cost: When Pooling or Biofuel Might Not Be an Option
While our sample case provides a financial break-even point, real-world decision-making is often more complex. Several operational and strategic factors can influence whether a company chooses pooling or biofuel bunkering.
Biofuel Availability and Pricing Vary by Region
The biofuel premium in our analysis is based on Rotterdam pricing, but:
Biofuels at certain locations may have much higher premiums. Check prices for different locations, for example, here.
Smaller ports or remote bunkering locations may not have access to sustainable biofuels like Bio30 blends, forcing operators to rely on conventional fuels.
For ships with fixed operational routes, biofuel availability can be a make-or-break factor in deciding whether it's a viable compliance strategy.
Internal Company Strategy & Fleet Constraints
While biofuels are a promising compliance solution, some companies may intentionally exclude them from their strategy for several reasons, for example, due to recent technical problems with CSNL biofuels, or long-term fuel stability.
Conclusion: Balancing Cost, Availability, and Strategy
The surplus price and biofuel premium are surely one of the key factors when making compliance decisions under FuelEU and EU ETS. However, companies must evaluate several additional factors including but not limited to:
Biofuel availability at bunker locations
Technical considerations
Accesibility of external pooling options
BetterSea’s FuelEU Maritime Compliance Platform with integrated 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!
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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*The analysis assumes an emission reduction for biofuel of 65% compared to 94 g/MJ (as per RED II) and an LCV of 37200
(Disclaimer: This case study is based on assumptions if not otherwise stated)
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