The EU Emissions Trading System (EU ETS) has covered maritime transport emissions since 1 January 2024. It is a cap-and-trade obligation: a shipping company responsible for a covered vessel must surrender EU allowances for the emissions that fall within the system’s geographic, vessel and gas scope. One allowance represents one tonne of carbon-dioxide equivalent.
The difficult part is determining what is actually covered. ETS vessel coverage is narrower than the EU Maritime Monitoring, Reporting and Verification (MRV) reporting system, and route percentages vary by the jurisdiction of each port. The rules also phase in over three emissions years, so the amount due is not immediately 100%.
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How the maritime ETS works
The EU ETS sets an overall emissions cap and represents that cap with allowances. Companies operating covered ships measure their emissions, obtain the required allowances and surrender them through the Union Registry. After the phase-in period, a company with 10,000 tonnes of emissions within the maritime ETS scope would surrender 10,000 allowances. During the phase-in, it surrenders only the percentage prescribed for that emissions year.
The maritime extension builds on the EU MRV Regulation. MRV is the monitoring and reporting framework; the ETS is the additional legal duty to surrender allowances. They overlap, but they are not interchangeable. A ship can have to report under MRV before its emissions or vessel category creates an ETS surrender obligation.
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Who is legally responsible?
The “shipping company” responsible for ETS compliance is the entity responsible for the ship’s operation under the applicable EU rules. It maintains the monitoring plan, submits reports, arranges verification and surrenders allowances. If responsibility for a ship changes during a reporting year, the previous company remains responsible for allowances corresponding to emissions produced while the ship was under its responsibility.
Which ships are covered?
ETS coverage depends on vessel type, gross tonnage (GT) and the year concerned. The current rules do not put every commercial vessel into the allowance obligation.
| Vessel category | MRV reporting position | EU ETS position |
|---|---|---|
| Cargo and passenger ships of at least 5,000 GT | Within the established MRV system | Covered from 2024 |
| Offshore ships of at least 5,000 GT | Added to MRV reporting from 2025 | Covered from 2027 |
| Offshore ships from 400 GT to below 5,000 GT | Added to MRV reporting from 2025 | Not currently covered by the ETS; possible future inclusion is part of the review process |
| General cargo ships from 400 GT to below 5,000 GT | Added to MRV reporting from 2025 | Not currently covered by the ETS; possible future inclusion is part of the review process |
The distinction matters operationally. From 2025, smaller offshore and general cargo ships in the 400-to-below-5,000-GT band can have MRV reporting duties even though the ETS does not yet require allowance surrender for them. The possible inclusion of those smaller ships in the ETS from 2028 is a review issue, not a rule already in force.
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Gas coverage also has two timelines:
- MRV from 2024: monitoring and reporting include carbon dioxide (CO₂), methane (CH₄) and nitrous oxide (N₂O).
- ETS from 2024: CO₂ is included in the allowance obligation.
- ETS from 2026: CH₄ and N₂O are added to the allowance obligation.
Consequently, a company may have to measure and report methane or nitrous oxide before those gases become part of the ETS surrender calculation. “Reported under MRV” does not automatically mean “allowances are due under the ETS” for the same year.
Do voyages outside the EU count?
Maritime ETS coverage is route-based and flag-neutral. The decisive questions are where a voyage starts and ends, and whether the ports fall under the relevant European jurisdiction. The European Commission’s legal framing includes ports under an EU Member State’s jurisdiction and treats Norway and Iceland as covered through the EEA Agreement.
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| Voyage or activity | Share of emissions in the ETS scope | How to apply it |
|---|---|---|
| Voyage between two covered European ports | 100% | All emissions for the voyage are counted. |
| Emissions while a covered ship is in a covered European port | 100% | In-port emissions are included, subject to the vessel and gas rules for the year. |
| Voyage between a covered European port and a port outside that jurisdiction | 50% | Half of the voyage emissions fall within the ETS scope. |
| Voyage entirely between ports outside the covered European jurisdictions | Not covered by the maritime ETS route rules | It is not an EU ETS voyage merely because the ship later calls at Europe; assess each voyage leg and port jurisdiction. |
The 50% rule applies to the voyage linking a covered port with a port outside the covered jurisdiction. It does not mean that every tonne emitted by a ship that has any European call is automatically covered. Companies need voyage-level records that identify the endpoints and the emissions assigned to each leg.
In-port emissions are a separate calculation
Emissions produced while a covered ship is in a covered port are treated as 100% within scope. Port stays therefore cannot be omitted simply because the ship is not moving. Fuel used for auxiliary engines, boilers or other onboard operations during the stay must be captured in the monitoring system when it falls within the applicable vessel and gas scope.
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How the surrender phase-in works
The obligation is introduced in three steps. The emissions year and the surrender year should always be kept together when planning cash flow and compliance.
| Emissions year | Percentage of in-scope emissions requiring surrender | Surrender deadline |
|---|---|---|
| 2024 | 40% | 30 September 2025 |
| 2025 | 70% | 30 September 2026 |
| 2026 and later | 100% | 30 September of the following year |
For example, if a company has 10,000 tonnes of emissions within the 2024 maritime ETS scope, the phase-in requirement is 4,000 allowances due by 30 September 2025. If the same amount is attributable to 2025, the requirement is 7,000 allowances due by 30 September 2026. For 2026 emissions, the full 10,000 allowances would be due by 30 September 2027, assuming the emissions are all within scope.
The percentages apply to the covered emissions for that reporting year, not to a company’s entire fuel bill or all emissions from every vessel in its fleet.
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The annual compliance process
Compliance is a recurring data, verification and registry process rather than a single annual payment.
- Maintain an approved monitoring plan. The plan sets out how fuel use, activity data, emissions factors, voyages and port stays will be monitored for each covered ship.
- Monitor ship-level emissions. Record the data needed to separate covered and non-covered voyages, 100% and 50% route allocations, in-port emissions and the gases applicable in that year.
- Prepare ship reports and an aggregated company report. Each ship has a report, and the company also submits an aggregated view covering the ships for which it is responsible.
- Arrange accredited verification. An accredited verifier checks the monitoring approach and emissions reports. Reports are normally verified by 31 March of the following year, or by 28 February if the administering authority requests that earlier date.
- Submit through THETIS-MRV. THETIS-MRV is the reporting platform operated by the European Maritime Safety Agency (EMSA).
- Obtain and surrender allowances in the Union Registry. Surrender the applicable percentage by 30 September of the following year. Keep evidence linking the surrendered amount to the verified emissions report.
The process should be designed around the ship’s actual operating data. A monitoring plan that cannot distinguish a European-to-European voyage from a European-to-non-European voyage will not reliably produce the correct 100% or 50% calculation.
What shipping companies need to track
A practical control file for each covered ship should make the following information easy to retrieve:
- Ship identity, GT, vessel category and the company responsible during each period.
- Voyage departure and arrival ports, including the jurisdictional status of each port.
- Fuel or energy consumption and the method used to calculate CO₂, CH₄ and N₂O.
- Time and emissions generated while in covered ports.
- The reporting year, because gas coverage and surrender percentages change over time.
- Changes in management, ownership or operational responsibility during the year.
- The verified report, verifier details and the allowance transaction record in the Union Registry.
Keeping the responsibility-change date is particularly important. A ship sold or transferred during the year can leave the former company with a surrender duty for the emissions generated before the transfer.
Can carbon offsets replace EU allowances?
No. Carbon credits, voluntary offsets and other certificates cannot be used to satisfy the maritime EU ETS surrender obligation. A company must surrender EU allowances for the covered emissions calculated under the system. An offset purchase may be a separate climate or corporate-finance decision, but it does not discharge the legal ETS duty.
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Implementation context and scale
The European Commission’s first report on implementation, adopted in March 2025, states that almost 12,000 vessels over 5,000 GT reported verified emissions through THETIS-MRV for 2023, representing 127 million tonnes of CO₂. Those figures describe 2023 MRV reporting and should not be read as a current annual ETS total or as the amount covered by the 2024 phase-in.
The Commission’s maritime ETS FAQ, whose content update is stated as 2 April 2025, describes the extension as applying to maritime transport emissions since 1 January 2024. The policy page and implementation report provide the same core structure: MRV data collection, route-based scope, phased surrender and verification.
Common mistakes and how to avoid them
Treating MRV and ETS as the same scope
Use two separate checks: first, does the vessel and activity have an MRV reporting duty; second, does it fall within the ETS vessel, route and gas rules for the relevant year?
Applying 100% to every European call
A European port call does not make every voyage 100% covered. A covered-port-to-covered-port voyage is 100%; a covered-port-to-outside voyage is 50%; in-port emissions in the covered port are 100%.
Using the wrong gas start date
MRV monitoring of CH₄ and N₂O began in 2024, while ETS surrender for those gases begins in 2026. Build the reporting system early, but calculate the allowance obligation using the gas rules for the emissions year.
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Confusing the emissions year with the deadline year
2024 emissions are partly surrendered by 30 September 2025; 2025 emissions are partly surrendered by 30 September 2026. A calendar reminder labelled only “ETS deadline” is not enough—identify the emissions year and percentage.
Assuming offsets settle the account
Only EU allowances satisfy the surrender requirement. Keep any offset program separate from the ETS compliance ledger.
What to verify before making an operational decision
Rules, guidance and ship-specific arrangements can change. Before signing a charter, allocating compliance costs or deciding whether a vessel is covered, confirm the current consolidated legal text and Commission guidance for:
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- the vessel’s category and GT threshold;
- the company legally responsible during each reporting period;
- the jurisdiction of every voyage endpoint and port stay;
- the gas rules in the relevant emissions year;
- the administering authority and any earlier verification date it requires; and
- the allowance account and surrender mechanics in the Union Registry.
That final check is essential for contracts that divide fuel, reporting or allowance costs between owners, managers, charterers and operators. The ETS framework supplies the calculation rules, but the commercial contract must still state who gathers the data, who pays for allowances and who acts when responsibility changes.
The Bottom Line
The maritime EU ETS is a phased allowance-surrender system layered onto MRV reporting. Cargo and passenger ships of at least 5,000 GT are covered from 2024, offshore ships of at least 5,000 GT from 2027, voyages between covered European ports are counted at 100%, voyages to or from an outside port at 50%, and in-port emissions at 100%. Companies must use EU allowances—not carbon offsets—and surrender the verified amount through the Union Registry by 30 September of the following year.
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