FuelEU Maritime: pooling, banking and penalties explained

FuelEU Maritime applies to ships above 5,000 gross tonnes carrying passengers or cargo for commercial purposes. It covers all the energy used on voyages and at berth within the EU, and half of the energy used on voyages into or out of the EU. The obligation sits with the shipping company responsible for the ship.

The measure is the well-to-wake greenhouse gas intensity of that energy, in grams of CO₂e per megajoule, against a reference value of 91.16 g CO₂e/MJ. The limit tightens every five years.

Renewable fuels of non-biological origin (RFNBOs), such as e-methanol and e-ammonia, count double until the end of 2033. If their share in 2031 is below 1%, a 2% RFNBO subtarget applies from 2034.

Each ship’s compliance balance is the difference between the limit and its actual GHG intensity, multiplied by the energy it used. A positive balance is a surplus, and a negative balance is a deficit. A verifier checks the figures in the FuelEU database.

• Banking: a verified surplus can be carried forward to the ship’s next reporting period (Article 20).
• Borrowing: a ship with a deficit can borrow an advance surplus of up to 2% of its limit multiplied by its energy use. The borrowed amount is repaid in the next period with a 1.1 multiplier, and borrowing cannot be used in two consecutive periods.
• Pooling: ships can combine their balances, described below (Article 21).

Pooling lets two or more ships, from the same company or different companies, add up their compliance balances. A ship sailing on biofuel or an RFNBO with a large surplus can cover the deficits of ships still on fossil fuel. The terms between the companies, including any payment for the surplus, are a commercial matter between them.

• The pool’s total compliance balance must be positive.
• No ship may end with a larger deficit than it brought in, and no ship with a surplus may end in deficit.
• Each ship can belong to one pool per reporting period. Separate pools may be formed for the GHG intensity requirement and for the RFNBO subtarget.
• The pool is registered in the FuelEU database, and the verifier records it by 30 April of the verification period.
• A surplus left in the pool after the allocation can be banked by the ships that hold it.

A deficit that remains after banking, borrowing and pooling pays the FuelEU penalty. It is set at €2,400 per tonne of VLSFO-equivalent energy, which is about €58.5 per gigajoule of the deficit. A ship that has a deficit for consecutive periods pays 10% more for each additional period. The penalty is multiplied by 1 + (n − 1)/10, where n is the number of consecutive periods.

Separate penalties apply to the RFNBO subtarget, once it applies, and to ships that fail to use on-shore power at berth where required: €1.50 per kilowatt of established power demand multiplied by the hours at berth.