Instead of acting solely as a cost driver, the FuelEU Maritime regulation could create a net financial gain, potentially around €250 million, according to a recent analysis by maritime data and compliance firm OceanScore.
The regulation, which entered into force on January 1, 2025, promotes the use of renewable, low-carbon fuels and clean energy technologies for vessels, essential to support the sector’s decarbonization.
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“FuelEU isn’t just another penalty,” Albrecht Grell , Managing Director at OceanScore, emphasized.
“It’s structured in a way that can push money back into parts of the industry — but only if you understand where and how that happens.”
The analysis by the Hamburg-based maritime technology firm focuses on the balance of greenhouse gas (GHG) intensity compliance under FuelEU. The initial compliance deficit across vessels exceeding the regulation’s threshold is estimated at around 2.1 million metric tons (MT) of CO₂e, while more efficient vessels — mainly LNG and LPG carriers — generate a surplus of about 1.3 million MT of CO₂e.
That leaves a net compliance gap of roughly 0.8 million MT, which is likely to be closed using biofuels . These fuels, such as used cooking oil methyl ester (UCOME), have a lower calorific value and higher price point, but offer the advantage of emissions reduction credits and corresponding savings under the EU ETS.
At today’s prices, factoring in the ETS phase-in rate of 70% and current exchange rates, covering this compliance gap via biofuels is expected to cost the industry around €200 million , or €230 per MT of CO₂e. While that’s not insignificant, it’s a relatively modest figure for an industry of this scale.
What happens on the revenue side?
The other half of the story is about how emissions-related costs are passed on, especially in container, ferry, and cruise segments, which together make up nearly 50% of total emissions.
In many cases, emissions surcharges are now included in contracts of affreightment (COAs), and some are linked to FuelEU’s penalty levels.
“It’s not a universal practice, but we’ve seen a significant number of surcharges that shadow the penalty rates,” Grell said.
“And when you run the numbers, even conservatively, the revenue side starts to look pretty interesting.”
OceanScore’s model assumes that just half of operators apply surcharges at two-thirds of the penalty rate, which equates to about €640 per MT of CO₂e. Under these conditions, total additional revenue could reach €450 million.
Subtracting compliance costs leaves a potential net gain of €250 million — although how sustainable that is remains uncertain.
“Windfalls like this don’t last forever. But in the short term, there’s clearly value on the table. The trick is knowing how to capture it — and who actually does,” Grell added.
Who benefits from this value shift depends on where you sit in the value chain, as per OceanScore. Owners, charterers, and ship managers all have different exposure to compliance costs and different leverage in passing them along. Charterers may aim to pass on more costs than they reimburse, owners will negotiate how these costs are handled, and managers – especially third-party ones – often sit at the center of compliance obligations.
“Ship managers are in a uniquely exposed position. They carry the responsibility for compliance but typically operate on tight margins. The additional cost, for tools, processes, and reporting systems could quickly reach €3,000–4,000 per vessel annually,” Grell continued.
“Managers shouldn’t be shy about asking for their share of this upside. They’re doing the heavy lifting, and it’s in everyone’s interest that they’re properly resourced to do it well.”
Preparing for a new compliance market
FuelEU doesn’t just introduce a new rule, it’s setting the stage for a compliance credit market. As operators buy and sell surpluses and deficits, pricing, liquidity, and strategy will become real levers for competitiveness.
OceanScore is working with shipping companies to help them navigate this evolving space, offering data-driven compliance tools, emissions strategy support, and access to pooling mechanisms.
“Whether you’re a charterer, an owner, or a manager, this is a moment to get ahead of the curve,” Grell said.
“The costs are manageable, and the opportunity is real — but only if you’re prepared.”
about 1 year ago
Instead of acting solely as a cost driver, the FuelEU Maritime regulation could create a net financial gain, potentially around €250 million, according to a recent analysis by maritime data and compliance firm OceanScore.
