Shipowners and charterers can turn biofuel investments into profit by managing overlapping carbon compliance mechanisms across CII, the EU ETS, FuelEU Maritime, and voluntary carbon markets, according to a whitepaper published this week by Berlin-based carbon management platform ZERO44.
The €492-Per-Tonne Opportunity
ZERO44’s worked example demonstrates that a vessel swapping marine gas oil (MGO) for B100 biodiesel on an intra-EU voyage can generate net revenue of up to €492 ($562) per tonne of fossil fuel replaced, the whitepaper reports. Against a fuel premium of €335 per tonne, FuelEU and EU ETS savings of €283 nearly cover the outlay. Selling the resulting FuelEU surplus via the pooling mechanism at €190 per tonne of CO2 brings in a further €544, leaving €492 of net revenue.
| Item | Amount per tonne |
|---|---|
| Fuel premium (MGO to B100) | €335 |
| FuelEU + EU ETS savings | €283 |
| Pooling surplus sale (FuelEU) | €544 |
| Net revenue | €492 |
Choosing carbon insetting instead — selling verified reductions to cargo owners chasing scope 3 targets at an assumed €120 per tonne — yields a smaller but still positive net revenue of €360 per tonne, according to the whitepaper.
The Additionality Trap
However, the whitepaper stresses that additionality is critical. Only fuel that is not counted toward regulatory targets qualifies for the voluntary carbon market. A reduction already used for compliance "should never be sold a second time", the whitepaper states. FuelEU surplus that is banked or pooled is off-limits to insetters, while the FuelEU calendar means owners can wait between four and 16 months to learn whether bunkered fuel counts toward compliance. ZERO44 says this gap can be closed by earmarking volumes for either regulatory or voluntary use upfront.
Pooling vs Insetting
The paper points to last year’s oversupply of FuelEU surplus, much of which went unsold, as evidence that operators need more than one route to recovering their biofuel spend. Unlike pooling, insetting lets operators assign reductions to specific customers, differentiating their service in the process. The voluntary market price of €120 per tonne is assumed in the whitepaper, but actual market rates may vary.
Charter Party Implications
Making the math work in charter parties is another matter. The party responsible to regulators — the owner or ISM company — is often not the one choosing the fuel, the whitepaper observes. ZERO44 suggests binding owner-charterer declarations that specific volumes will not be used for FuelEU compliance, handing charterers full control of the surplus.
"For voyages to, from, and within the EU, going beyond compliance is already a revenue-generating strategy today, not a future ambition," the whitepaper concludes.
For logistics managers, freight forwarders, and ocean carriers, the ZERO44 analysis indicates that biofuel premiums need not be a pure cost increase. Operators who coordinate compliance across CII, EU ETS, and FuelEU Maritime can recover — and even profit from — the fuel switch. The key is structuring charter party agreements to allocate the carbon surplus. The whitepaper also highlights that early movers can differentiate their service by offering scope 3 reductions to cargo owners, potentially improving their competitive position on EU routes.
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