The European Commission's commitment to prevent shipping companies from being charged twice for the same emissions has been welcomed, but the practical reality remains a compliance maze, according to a report by Philippos Ioulianou from EmissionLink. Without detailed guidance on how duplicate carbon costs will be avoided, shipowners and managers are being left to navigate an increasingly complex regulatory landscape.
Regulatory Overlap Creates Compliance Challenges
Three major carbon pricing schemes — EU ETS, FuelEU Maritime and the IMO's emerging framework — are converging on the shipping industry, each with different scopes, timelines, calculation methods and commercial logic, according to EmissionLink. The European Commission recognised the risk of double charging, but Ioulianou noted that "avoiding duplicate charging is not straightforward, it’s an administrative, commercial and technical challenge ship owners and managers must now adopt."
For a vessel trading into Europe, the exposure may include all three schemes. The obligations will not always sit with the same party, data will not always be calculated the same way, and costs will not always be recoverable under existing charter party terms. The risk for shipowners includes:
- Paying twice for the same tonne of emissions
- Reporting twice or building parallel compliance processes
- Calculating twice with different methodologies
- Confusion over how EU and IMO obligations are reconciled
Ioulianou posed critical questions: "How will EU and IMO obligations be reconciled and how will equivalent payments be recognised? How will systems interact without punishing the same tonne of emissions more than once and what evidence will shipowners need to prove it?"
Data and Expertise Requirements
Accurate, auditable emissions data is essential, but data alone is not enough. Owners also need expertise to interpret data across different schemes and make correct commercial decisions. EmissionLink reported that it has already supported accurate FuelEU emissions data delivery for more than 600 vessels. According to the company, "every vessel has a different operating profile, every voyage has a regulatory consequence and every compliance decision can affect cost exposure, penalties, pooling options, charterparty recovery and future planning."
Revenue Use and Industry Calls
At a ShipEnergy forum during Posidonia, Ioulianou argued that carbon pricing will retain credibility only if revenues are clearly used to support maritime decarbonisation. He stated that EU member states need to set out a clear pathway for the use of EU ETS and FuelEU-related revenues. These funds should be directed back into the sector and not become a government revenue stream.
What This Means for Importers and Exporters
The current situation means that importers, exporters and trade policy professionals must understand their exposure across EU ETS, FuelEU Maritime and the future IMO framework. The challenge is no longer simply submitting the right figure into the right system — it is understanding how current and future emissions schemes interact, how they affect the business, and how to avoid double penalties, duplicated processes and avoidable costs.
| Scheme | Status | Key Characteristic (from source) |
|---|---|---|
| EU ETS | Now in force | Different scope, timeline, calculation method, commercial logic |
| FuelEU Maritime | Now in force | Different scope, timeline, calculation method, commercial logic |
| IMO NZF framework | Moving forward slowly | Different scope, timeline, calculation method, commercial logic |
As the article notes, a clear and agreed approach may become a reality, but it will not make today’s obligations disappear. Owners, managers and operators need to understand their exposure now.
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