From the 2025 compliance year, FuelEU Maritime — Regulation (EU) 2023/1805 — requires the greenhouse gas (GHG) intensity of energy used on board ships to decline each year, with a penalty for missing the limit and a Document of Compliance for ships that meet it. Writing in Splash247, Captain Alex Byelyavtsev identifies six structural problems with the regulation, which was designed to push ships toward renewable and low-carbon energy and support the EU’s Fit for 55 climate package.
Compliance can be collective
The first problem concerns the compliance mechanism itself. Under Article 21 of the regulation, ships may pool compliance balances so the pool meets the GHG intensity limit on average, Byelyavtsev noted. That pooling flexibility is written into the rule, meaning a ship can appear compliant through the pool rather than through its own fuel. A FuelEU Document of Compliance confirms that a ship complied with the regulation for a reporting period — and that compliance can include pooling. It does not prove that the ship cut its voyage emissions or changed fuel at scale. Compliance is an accounting result; emission reduction is a physical result, and early FuelEU practice has mixed the two.
The fuel is not ready at fleet scale
The second problem is the fuel itself. Clean marine energy is not available at fleet scale, according to the Splash247 analysis. Drop-in biofuels are limited and contested; methanol and ammonia help only ships engineered to burn them, while most of the world fleet continues to use conventional bunkers. Yet the legal year can still end with a green balance. The European Commission’s own impact assessment pathways projected that renewable and low-carbon fuels should provide 6% to 9% of the international maritime fuel mix by 2030, and 86% to 88% by 2050 — model paths, not today’s supply.
Who is obliged
The third problem is the allocation of the compliance duty. The regulation places the duty on the company responsible for the ship — the fuel user — rather than placing the same hard duty on producers to make that fuel at scale, according to Byelyavtsev. It concentrates responsibility on the final user. A study by the International Chamber of Shipping (ICS) and the European Community Shipowners’ Associations (ECSA) warned that putting the main fuel-standard duty on ships rather than fuel suppliers creates enforcement and supply problems, because the law can demand a cleaner fuel that does not yet exist in the volumes required.
The trajectory, the money, the ship
The fourth problem is the target itself. Article 4 sets the reduction at 2% from 2025, 6% from 2030, then far harder toward 80% by 2050. The dates are clear, but for many ships the physical path is not. The target is someday-achievable if the fuels appear, the ships are replaced and the money holds; someday possible is not the same as achievable now.
The fifth problem is money. Real transition requires capital for new ships and scarce fuels. UNCTAD’s Review of Maritime Transport 2025 put the global containership fleet at about 30.3 million teu as of April 2025, up about 10% year-on-year after heavy ordering and elevated deliveries. Those ships add slots; more slots mean more competition, and that squeezes the surplus available for the next round of transition.
The sixth problem is where responsibility sits. FuelEU attaches the duty to the ship because the ship burns the energy. Research on port congestion shows ships often sail fast then wait at anchor for a berth, with average potential emissions savings of about 10% for containerships if waiting time becomes slower sailing. An IMO-backed Just in Time study found average fuel savings of about 14% per containership voyage when speed is matched to berth availability. FuelEU still parks the legal duty on the vessel, Byelyavtsev observed.
Regulatory context
Shipping accounts for only about 3% to 4% of EU CO₂ emissions on Commission figures, and the sector already faces the EU Emissions Trading System (ETS) for shipping alongside FuelEU. The political noise is large for that share, and the early paperwork success is large too, but the real fuel change is still small.
What’s wrong with FuelEU is not that shipping was asked to cut emissions; it is the order of the rule. The EU set a mandatory transition for fuel users without matching it with a hard production duty at the same scale.
| Compliance year | Required GHG intensity reduction |
|---|---|
| 2025 | 2% |
| 2030 | 6% |
| 2050 | 80% |
Sources:
