Case Study X: Optimizing FuelEU Compliance Through Smart Fuel Allocation
- Maximilian Schroer
- Jun 29
- 4 min read

With increasing FuelEU exposure and costs, vessels calling the EU must make every g of CO₂e count. Today’s case study analyzes a practical voyage scenario involving sustainable biofuels on an EEA-in/outgoing roundtrip, focusing on optimizing FuelEU compliance through fuel allocation.
Example 1: Bio30 on EEA-In/Outgoing Roundtrip – The Need for Fuel Stream Separation
Consider a vessel that arrives in an EU port (Hamburg) from New York (an incoming leg) using fossil fuel (VLSFO and MDO) and departs toward New York (an outgoing leg) using Bio30, a 30% blend of sustainable biofuel and 70% MDO.
Roundtrip: New York - Hamburg - New York
Speed: 24 knots
Duration: ~6 days
Fuel consumption (New York to Hamburg): 400 tonnes MDO + 900 tonnes VLSFO
Fuel consumption (Hamburg to New York): 1305 tonnes Bio30 (877 tonnes MDO, 431 tonnes Bio100)
Regulatory Scope: 50% exposure to FuelEU Maritime
Under FuelEU Maritime, compliance calculations require separate reporting of each fuel stream: the bio component (e.g., UCOME or HVO) and the fossil component. The energy content of each must be disaggregated, and only energy actually consumed during the outgoing voyage leg is eligible for compliance.
To do this correctly, the biofuel blend must be split into its constituent fuels based on lower calorific values (LCV). This split enables the allocation of the sustainable biofuel energy to the outgoing voyage.
Since this leg is subject to 50% FuelEU scope exposure, the compliant energy from the bio portion may offset uncompliant GHG intensity and even create a surplus.
This disaggregation and allocation must follow FuelEU guidelines and be reported in the FuelEU database. The flexible allocation logic of the FuelEU Maritime regulation allows for optimization by assigning compliant energy (bio portion) to the outgoing leg, while the fossil portion carries a penalty. However, even the fossil fuel can be optimally allocated by optimizing for VLSFO rather than MDO due its slightly better GHG intensity.
Total Energy falling under the FuelEU Scope (50%): 53M MJ
VLSFO Consumption to be considered: 900 tonnes
Bio100 Consumption to be considered: 431 tonnes
MDO Consumption to be considered: 24 tonnes

Resultantly, the FuelEU Maritime compliance costs/surplus is:
FuelEU GHG Intensity: 74.09335 g CO2e / MJ
FuelEU Compliance Balance: 815 t CO2e
FuelEU Surplus Value: 207,989.89 €
FuelEU Penalty: 0.00 €
Example 2: Using Bio70 and Optimizing FuelEU Compliance Through Fuel Allocation
Now consider a similar scenario, but with Bio70 used on the outgoing leg. In this case, 70% of the energy used during the voyage is from sustainable biofuel. This higher blend ratio significantly improves the vessel's GHG intensity.
Roundtrip: New York - Hamburg - New York
Speed: 24 knots
Duration: ~6 days
Fuel consumption (New York to Hamburg): 400 tonnes MDO + 900 tonnes VLSFO
Fuel consumption (Hamburg to New York): 1377 tonnes Bio70 (376 tonnes MDO, 1,007 tonnes Bio100)
Regulatory Scope: 50% exposure to FuelEU Maritime
Now, fuel allocation plays an even more essential role in maximizing compliance benefits under FuelEU Maritime. Instead of looking at each single voyage the overconsumption of biofuel during the outgoing leg can be reallocated to the ingoing leg to improve the ship's compliance status as depicted in the figure below.
Total Energy falling under the FuelEU Scope (50%): 53M MJ
VLSFO Consumption to be considered: 396 tonnes
Bio100 Consumption to be considered: 1,007 tonnes
MDO Consumption to be considered: 0 tonnes

Resultantly, the FuelEU Maritime compliance costs/surplus is:
FuelEU GHG Intensity: 50.54059 (62.31286) g CO2e / MJ
FuelEU Compliance Balance: 2,075 (1,445) t CO2e
FuelEU Surplus Value: 529,261.48 (368,514.27) €
FuelEU Penalty: 0.00 (0.00) €
Note, the above values in parenthesis show the compliance values if the fuel allocation would have not been optimized across the two voyages but only looked at individually. A striking increase of about 160,000 € in surplus value was achieved through the optimal fuel allocation across the two voyages.
Also interesting under this example is that the fossil component of the bio blend can essentially be neglected as the slightly higher GHG intensity of MDO does not influence the overall GHG intensity of the ship and one may want to opt for a MDO-based blend to have a more stable fuel compared to a HFO-based blend.
Conclusion
These examples underscore the compliance potential of biofuel blends, even on partially covered voyage legs. Key takeaways:
Disaggregation of blended fuels is essential for accurate reporting and optimization.
Higher blend ratios (e.g., Bio70) unlock significantly more compliance value even on in/outgoing EU voyages.
Make sure to master fuel allocation to get the best compliance results.
BetterSea's FuelEU Maritime Platform helps you in finding the best compliance pathway considering all complexities of FuelEU. Utilising alternative fuels is too tricky or the fuels are simply not available in the ports you sail to? Check out our FuelEU Pooling Marketplace for effortless and fast compliance. It 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
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*Surplus value 255€/tCO2e, Bio100 LCV 0.03720 MJ/g, Bio100 GHG Intensity 32.9 gCO2e/MJ, Numbers have been rounded
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