FuelEU Compliance Process: From Data Submission to DoC Issuance

The end of a FuelEU Maritime reporting year doesn't mean the work is done. On the contrary, it marks the beginning of an interesting post-reporting process that is as critical as the operations throughout the year. It requires this process to be laid out in great detail, clarify the timeline, procedural options, and the sequence companies have to follow between January and June of the following year. Understanding these steps is essential to ensuring compliance and avoiding costly penalties or missed opportunities. This newsletter dissects and illustrates what practically happens at the close of a compliance year.

The Reporting Period May End, But Not The Compliance Year

While 31st December marks the end of the reporting period, the next six months are a mix of validation, reporting, and strategic decision-making. Here’s how it unfolds:

1. By 31st January: Submit the Annual FuelEU Report

   The first obligation of the new year is the submission of the FuelEU report for each vessel. This includes data on energy used, fuel types consumed, and calculated GHG intensity, measured on a well-to-wake basis.

   
   

2. By 31st March: Verified Compliance Balance Recorded

   Once submitted, the report is assessed by a verifier who calculates the vessel’s compliance balance, whether it has a surplus, a deficit, or is in balance. Only then does the process of flexibility mechanisms officially begin.

   
   

3. By 30th April: Declare Pooling, or Borrowing

   Companies can now decide whether to:

   • Borrow from the next period (with strict limits as per our previous newsletter),

   • Pool surpluses and deficits across vessels (see our previous newsletter regarding FuelEU pooling).

   These actions must be reported and verified. Crucially, they must be declared and documented in the database by 30th April.

   
   

4. By 1st June: Penalty Notification

   If a vessel remains in deficit even after applying flexibility mechanisms, the company will be notified by the administering state of the financial penalty. This notification includes the amount due based on the FuelEU Maritime penalty structure.

   
   

5. Between 30th April and 30th June: Declare Banking

   Report and decide any banking of compliance surpluses. This also illudes to the fact that banking is applied after reporting of pooling and as such transfer of compliance balances (refer to our previous newsletter regarding FuelEU banking)

   
   

6. By 30th June: Penalty Payment and Issuance of DoC

   To close the loop, companies must settle any penalty payments by 30th June. Only then is the FuelEU Document of Compliance (DoC) issued.

   
   

The above outlines what has been presented in our previous newsletter on the FuelEU timeline and adds new information and detail regarding the cadence of pooling, borrowing, and banking.

Pathway to FuelEU compliance: Process and Timeline

The below illustration depicts the FuelEU compliance pathway for different scenarios and options:

Conclusion

The newsletter lays out a clear but demanding timeline for closing the compliance loop under FuelEU Maritime. From data submission to banking and pooling, each step allows for strategic optimization, but only if done correctly and on time.

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!

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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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