Insights · Decarbonisation · EU ETS
For the first time, a ship's carbon has a bill attached. Since 2024 shipping has been inside the EU's carbon market, and operators must buy and surrender an allowance for every covered tonne of CO₂ — a cost that lands directly on the voyage.
The EU ETS is Europe's flagship climate instrument: a cap-and-trade market that puts a price on carbon by issuing a limited number of emission allowances, each covering one tonne of CO₂-equivalent. Polluters must hold and surrender one allowance for every tonne they emit, and the total cap shrinks over time, so the price reflects scarcity. In 2024 the system was extended to maritime transport for the first time — turning a ship's emissions, long unpriced, into a direct line on the operating budget. It works in tandem with FuelEU Maritime, but the two do different jobs: the ETS prices the carbon, FuelEU restricts the fuel.
The maritime ETS applies to ships of 5,000 gross tons and above, irrespective of flag, calling at EEA ports. The geographic coverage is the same as FuelEU:
Emissions data comes from the EU's existing Monitoring, Reporting and Verification (MRV) system, which already required large ships to report fuel use and CO₂ on EU-related voyages — so the measurement framework was in place before the obligation to pay arrived.
To soften the introduction, the obligation ramps up over three years, and the basket of gases widens at the end of it:
| Year | Share of emissions to surrender | Gases |
|---|---|---|
| 2024 | 40% | CO₂ |
| 2025 | 70% | CO₂ |
| 2026 onward | 100% | CO₂, methane (CH₄), nitrous oxide (N₂O) |
The addition of methane from 2026 matters for gas-burning ships in particular, because methane slip from LNG engines was previously outside the carbon bill. By 2026 the full emissions of a covered voyage are priced.
There is no fixed tariff. Allowances are bought on the carbon market, so the cost per tonne is whatever the EU Allowance (EUA) price happens to be — it has traded broadly in the tens of euros per tonne, and it moves daily. The bill for any one ship is therefore the product of three things: its covered CO₂ tonnage, the phase-in percentage for the year, and the prevailing allowance price. A large container ship or tanker on heavy EU rotation can run up a six- or seven-figure annual allowance cost, which is why fuel efficiency and routing now have a hard financial edge.
For the first time, a tonne of marine CO₂ has a market price attached to it — and the company operating the ship has to go out and buy the allowance to cover it. The principle of cap-and-trade applied to shipping
The duty to surrender allowances falls on the "shipping company" responsible for the vessel — by default the registered owner, but it can be the company that has contractually assumed responsibility for the ship's operation. Because that party may be the manager or commercial operator rather than the owner on the registry, identifying who actually controls the voyage is part of the question — exactly the kind of resolution covered in our explainer on beneficial ownership.
The ETS is one of several pressures bearing down on a ship's carbon at once. FuelEU Maritime caps the intensity of the fuel; the IMO's CII rating scores operational efficiency A–E; and the IMO's 2030 and 2050 targets set the long-run global direction. The combined effect is that an inefficient ship now pays more on every front.
The inputs that drive these costs — a ship's type, size and the EU ports it serves — are on its Marifest file. Across 97,000+ vessels you can read the particulars in the registry, resolve the operating company, and look up terms such as MRV and EUA in the glossary.
How Marifest helps
The ETS cost lands on a specific vessel and a specific operating company. Marifest holds both, keyed to the permanent IMO number, so the party that owes the allowances is clear.
Type and gross tonnage decide whether a ship is in ETS scope; both are recorded for every vessel.
The obligation can sit with the operator, not the owner — Marifest resolves both via GLEIF.
The ports a fleet serves determine which voyages fall into the 50% or 100% scope.
ETS, FuelEU and CII all read off the same hull, anchored to its IMO number across the registry.