Why another regulation?
EEDI governs design, CII governs operational carbon intensity, EU ETS puts a price on CO₂ at the exhaust. FuelEU Maritime closes the remaining gap: the carbon footprint of the fuel itself, upstream as well as downstream.
A tonne of LNG burned in an engine emits less CO₂ than a tonne of HFO at the exhaust. But the methane slip from the engine, plus leakage in the LNG supply chain, can erode or even erase that benefit on a well-to-wake basis. FuelEU forces that accounting.
What it measures
FuelEU’s core metric is the annual average well-to-wake GHG intensity of the energy a ship uses:
GHG Intensity = Σⱼ (Eⱼ × WtWⱼ) / Σⱼ Eⱼ [ gCO₂e / MJ ]
Eⱼ- energy (MJ) from fuel j consumed in the reporting year.WtWⱼ- Well-to-wake GHG intensity of fuel j including CO₂, CH₄, and N₂O expressed as CO₂-equivalent (GWP100). Defaults are in Annex II of the Regulation; certified supplier values may be used instead.
The target
The target tightens over time. Baseline is the 2020 fleet average of 91.16 gCO₂e/MJ. Each year the allowable intensity drops:
| Period | Reduction vs 2020 baseline | Target (gCO₂e/MJ) |
|---|---|---|
| 2025–2029 | −2 % | 89.34 |
| 2030–2034 | −6 % | 85.69 |
| 2035–2039 | −14.5 % | 77.94 |
| 2040–2044 | −31 % | 62.90 |
| 2045–2049 | −62 % | 34.64 |
| from 2050 | −80 % | 18.23 |
A ship’s Compliance Balance = (Target − Attained) × Σ Eⱼ. A positive balance is a surplus that can be banked, borrowed, or pooled; a negative balance is a deficit that must be settled.
Scope
- Ships of ≥ 5,000 GT carrying cargo or passengers to, from, or between EU ports.
- 100 % of energy used on intra-EU voyages and at berth in EU ports.
- 50 % of energy used on voyages between an EU and a non-EU port.
- Same geographic logic as EU ETS for shipping.
The RFNBO 2× multiplier
To seed demand for truly green fuels, 2025–2033 energy from RFNBOs (Renewable Fuels of Non-Biological Origin - e.g. green hydrogen, e-methanol, e-ammonia from renewable electricity and compliant under RED II) counts twice in the numerator of the attained intensity. Effectively, each MJ of RFNBO offsets two MJ’s worth of fossil intensity, making RFNBO uptake dramatically more valuable than their tonnage alone suggests.
OPS (onshore power supply) requirement
From 2030, container and passenger ships at TEN-T-core EU ports must use onshore power supply (cold ironing) while berthed for two hours or more, unless they run zero-emission at berth (batteries, fuel cells). Non-compliance is added to the FuelEU compliance balance as additional deficit.
Penalty
If a ship finishes the year with a negative compliance balance, it pays:
Penalty = (|Compliance Balance| / (41,000 × Target)) × €2,400
where 41,000 MJ/t is the reference LCV of VLSFO. The formula converts the deficit into “tonnes of VLSFO equivalent” and fines at €2,400 per tonne. For a 10,000-tonne-fuel ship running on pure VLSFO in 2025, missing target by just 1 % results in a penalty on the order of €50,000.
Pooling
Ships under common management (or via negotiated commercial arrangements) can aggregate their compliance balances. A high-performing LNG or methanol newbuild can pool with an underperforming sister ship on HFO. The EU implementing acts define the mechanics; the commercial practice is that pooling credits are increasingly bought and sold like allowances.
Ship-operator implications
- Book well-to-wake, not just tank-to-wake. Fuel choice has to account for upstream leakage (LNG methane) and feedstock additionality (biodiesel ILUC).
- Track per-voyage energy, because the 100 %/50 % geographic scoping means you need to split each voyage’s fuel between intra-EU and extra-EU buckets.
- Watch the 2030 OPS cliff. Container and passenger ships need an OPS upgrade plan or a batteries/fuel-cell at-berth system.
- Integrate with EU ETS and CII planning. A LNG switch that improves CII may or may not improve FuelEU, depending on engine type and slip. An ammonia switch kills tank-to-wake CO₂ but carries an N₂O penalty on WtW.
How it interacts with other regimes
| Regime | What it governs | Units |
|---|---|---|
| EEDI/EEXI | Design-phase carbon intensity | gCO₂ / t·nm |
| CII | Operational tank-to-wake carbon intensity | gCO₂ / (dwt·nm) |
| EU ETS | Tank-to-wake CO₂ price (EUA allowances) | € / tCO₂ |
| FuelEU Maritime | Well-to-wake GHG intensity of energy used | gCO₂e / MJ |
The four stack. A 2026 EU-trading ship owner needs to plan for all of them simultaneously, which is why a three-regime cost bridge (CII → EU ETS → FuelEU) is increasingly the tool fleets use for decarbonisation investment decisions. That calculator is on our Phase 7 roadmap.