EU ETS for shipping: what shipping companies must surrender, and who pays

Shipping companies whose ships of 5,000 gross tonnage (the measure of a ship's overall size) 14 and above carry cargo or passengers to, from or between ports in EU countries must surrender EU emission allowances for those ships' emissions, counted in full or by half depending on the route 231011. For 2026 emissions, the share they surrender reaches 100% for the first time, and methane and nitrous oxide count alongside carbon dioxide 36. The shipping company carries the obligation, but when a charterer or another business buys the fuel or decides the cargo carried or the ship's route and speed, the law entitles the shipping company to pass the cost on 7.

This explainer covers the shipping rules of the EU Emissions Trading System (EU ETS). Our EU ETS hub explains the system as a whole.

Which ships and voyages does the EU ETS cover?

The EU ETS covers the maritime transport activities of the maritime monitoring rules, the MRV Regulation (Regulation (EU) 2015/757), with some exceptions 3. MRV stands for monitoring, reporting and verification. The Directive behind the EU ETS is the ETS Directive (Directive 2003/87/EC) 3.

Covered by the EU ETS:

• Ships of 5,000 gross tonnage and above, for their emissions on voyages carrying cargo or passengers for commercial purposes to or from a port of call in an EU country, and within those ports 23
• Carbon dioxide (CO₂), and methane and nitrous oxide from 1 January 2026 3

Gross tonnage is calculated under the tonnage measurement rules of the International Convention on Tonnage Measurement of Ships, adopted by the International Maritime Organization (IMO) 15.

Report under the MRV Regulation, but not in the EU ETS:

• General cargo ships and offshore ships between 400 and 5,000 gross tonnage, covered by the MRV Regulation since 1 January 2025 23
• Offshore ships of 5,000 gross tonnage and above, which the EU ETS leaves out until 31 December 2026 23

Not covered at all:

• Warships, naval auxiliaries, fish-catching and fish-processing ships, wooden ships of a primitive build, ships without mechanical propulsion, and government ships used for non-commercial purposes 2

The Commission's guidance reads the offshore exclusion the same way: offshore ships of 5,000 gross tonnage and above come into the EU ETS from 2027 16. That is guidance, not law.

A port of call is where a ship stops to load or unload cargo or to let passengers on or off 1. Stops only to refuel, take on supplies, change crew (except on offshore ships), go into dry dock or shelter from bad weather don't count 1. The scope sets no condition on the flag a ship flies, and the Commission calls the system "flag-neutral and route-based" 216. Ports in Norway and Iceland count too, because the rules apply there through the European Economic Area (EEA) Agreement, the Commission's guidance says 16.

Who counts as the shipping company?

The shipping company is the shipowner, or the organisation, such as the manager or the bareboat charterer, that has taken over the operation of the ship and agreed to take on the shipowner's duties under the International Management Code for the Safe Operation of Ships and for Pollution Prevention 1. The same entity is the "company" under the MRV Regulation, so one business answers for both 15.

A manager or bareboat charterer carries the EU ETS obligations only if the shipowner has mandated it to 17. It has to give its administering authority a document, signed by the shipowner and by itself, naming each ship the mandate covers 17. Without that document, the shipowner is responsible 17. A shipowner that keeps the obligations gives the authority a list of its ships instead 18.

A time charterer (a business that hires a ship for a specific period of time while the owner still manages it, as the Commission describes it) 19 or a cargo owner that hasn't taken over the ship's operation and the shipowner's duties under that code is not the shipping company under this definition, even if it buys the fuel 1. What it may have to pay is covered below, under who ends up paying.

How much of a ship's emissions counts?

The EU ETS counts a ship's emissions by route 11:

• 50% of the emissions on voyages from a port of call in an EU country to a port of call outside the EU, and the other way round 11
• 100% of the emissions on voyages between ports of call in EU countries 11
• 100% of the emissions within ports of call in EU countries 11

Stops of container ships at two ports outside the EU, East Port Said in Egypt and Tanger Med in Morocco, don't count as port calls 120. The Commission lists a port when it is less than 300 nautical miles from a port in an EU country and transhipment makes up more than 65% of its container traffic 11. In our reading, a container ship's stop at one of these ports doesn't end its voyage, so the voyage still runs from or to the last port of call outside the list 12. The Directive asks the Commission to update the list every two years 11. The list in our sources is Implementing Regulation (EU) 2023/2297 21. We found no later change to it in the EU's records when we prepared this page.

How many allowances must a shipping company surrender, and by when?

A shipping company surrenders one allowance for each tonne of CO₂ equivalent (CO₂e) it counts 110. A tonne of CO₂e is a tonne of CO₂, or an amount of another greenhouse gas, such as methane, with the same global-warming potential 1. The share rose in three steps 6:

• 40% of verified emissions for 2024 6
• 70% of verified emissions for 2025 6
• 100% of verified emissions for 2026 and every year after 6

The deadline is 30 September each year, for the emissions of the year before 10. For 2026 emissions, the first year at 100% and with methane and nitrous oxide, that is 30 September 2027, by our calculation from the law's yearly date 40. Shipping companies use the same general EU allowances as industry, power producers and aircraft operators, and carbon credits can't be used instead, the Commission's guidance says 16.

Example: one container ship, three years

Example, with figures we made up: a container ship emits, each year, 8,000 tonnes of CO₂e on voyages between EU and non-EU ports of call, 3,000 tonnes on voyages between EU ports and 1,000 tonnes within EU ports 40.

• Counted: 50% of 8,000 is 4,000 tonnes, plus 3,000 and 1,000 tonnes at 100%, so 8,000 of the 12,000 tonnes count 1140
• For 2024 emissions, the shipping company surrendered 3,200 allowances, 40% of 8,000, by 30 September 2025 640
• For 2025 emissions, it surrendered 5,600 allowances, 70% of 8,000, by 30 September 2026 640
• For 2026 emissions, it surrenders 8,000 allowances, 100% of 8,000, by 30 September 2027 640

To keep the sums simple, the example assumes the same emissions every year; for 2024 and 2025 they would be CO₂ only 340.

How are a ship's emissions monitored, reported and verified?

The shipping company monitors and reports its ships' emissions under the MRV Regulation and has them checked by an accredited verifier; the EU ETS relies on those verified figures 4522. The steps follow a fixed order:

1. Monitoring plan: for each ship, a plan that a verifier has found in line with the rules goes to the administering authority 23. For a ship that falls under the rules for the first time, that is due no later than three months after its first call at a port in an EU country 23.
2. Approval: the administering authority approves the plan, within four months of that first call for a ship new to the EU ETS 23. New emission sources, new fuels or new measuring equipment mean updating the plan 24.
3. Monitoring: through the year, the company monitors each ship's emissions at sea and at berth, for every voyage to or from a port in an EU country 25.
4. Reports by 31 March: for each ship, a verified emissions report for the previous year goes to the administering authority, the flag State's authorities for ships flying an EU country's flag, and the Commission 8. By the same date, the company submits its verified aggregated emissions data at company level, the total the EU ETS uses 9. The authority can ask for both earlier, but not before 28 February 89.
5. Document of compliance: by 30 June, each ship calling at a port in an EU country carries a valid document of compliance from its verifier for the previous year 26.
6. Surrender by 30 September: allowances for the previous year's verified emissions 10.

When a ship changes shipping company during a year, the previous company submits a verified report for its part of the year no later than three months after the change 8. Each company surrenders for the emissions of the period it was responsible, the Commission's guidance says 16. Our explainer on the yearly compliance cycle sets the shipping dates next to those for installations and aircraft operators.

Which authority deals with a shipping company?

Each shipping company has one administering authority in one EU country 27:

• A company registered in an EU country: that country 27
• A company registered outside the EU: the EU country with the most estimated port calls from its voyages in the preceding four monitoring years 27
• A company outside the EU with no such voyages in those years: the EU country where one of its ships started or ended its first voyage in scope 27

The Commission publishes the list of shipping companies and their authorities: Implementing Decision (EU) 2024/411, as amended by Implementing Decisions (EU) 2025/2452 and (EU) 2026/1453 2728. A company stays with the authority on the list until a new list changes it 27. A company that isn't on the list still has to comply, and asks for attribution through the THETIS-MRV system, the Commission's guidance says 16.

Which ships and routes surrender fewer allowances until 2030?

Four derogations run until 31 December 2030 10:

• Ice-class ships with ice class IA or IA Super, or an equivalent, may surrender 5% fewer allowances than their verified emissions 10
• For voyages of passenger ships other than cruise ships, and of ro-pax ships (ships that carry more than 12 passengers and have roll-on/roll-off cargo space on board) 29, between a listed island and a port in the same EU country, EU countries treat the surrender obligation as met and take no action 1030. The islands have no road or rail link with the mainland and fewer than 200,000 permanent residents 10
• The same applies to voyages of passenger and ro-pax ships under a listed public service contract between two EU countries 1030
• Voyages between a port in an outermost region of an EU country (one of the nine remote regions named in the EU Treaties, such as the Canary Islands, the Azores and Réunion) 31 and a port in the same country create no obligation to surrender 10

The island and public service exemptions apply only to the islands, ports and contracts the Commission lists in Implementing Decision (EU) 2023/2895 30. The list holds islands in Denmark, Greece, Spain, Croatia, Italy, Malta, Finland and Sweden, and one public service contract, linking Piraeus in Greece with Larnaca and Limassol in Cyprus 3233.

What happens if a shipping company doesn't surrender enough allowances?

A shipping company that hasn't surrendered enough allowances by 30 September pays an excess emissions penalty of €100 for each tonne of CO₂e not covered, rising with the European index of consumer prices, and still has to surrender the missing allowances 13. EU countries publish the names of shipping companies in breach 13.

Shipping has one penalty of its own. If a company fails to surrender for two or more reporting periods in a row and other enforcement has failed, the EU country of the port of entry can issue an expulsion order, after giving the company the chance to submit its observations 13. Every EU country except the one whose flag a ship flies then refuses that company's ships entry to its ports until the company has surrendered 13. The flag State instead detains the ship when it enters or is found in one of its ports, until the company has surrendered 13. The MRV Regulation has a similar order for ships that fail to monitor and report 34. Our compliance cycle explainer works through the penalty for all businesses in the EU ETS.

Who ends up paying: the shipping company or its customer?

The law makes the shipping company pay first and lets it recover the cost from the business that takes the commercial decisions 7. Three layers matter here.

Law: when another entity has taken on, by contract, the ultimate responsibility for buying the fuel or for operating the ship, or both, the shipping company is entitled to reimbursement from it for the costs of surrendering allowances 7. Operating the ship here means deciding the cargo carried or the ship's route and speed 7. EU countries must put this entitlement into national law, and the shipping company stays responsible for surrendering, whatever it recovers 7.

Guidance, not binding: the Commission says EU countries must also give access to justice to enforce the entitlement, and that the parties "are expected to develop contractual clauses to pass on the ETS surrendering costs as appropriate" 16.

Our reading: the Directive gives a right to reimbursement but sets no formula for the amount, no format for a surcharge and no rule for customers who neither buy the fuel nor decide the cargo carried or the ship's route and speed 7. A time charterer that buys the fuel falls under Article 3gc. A business that only books cargo space on a liner service does not appear to, so an EU ETS surcharge on its freight invoice rests on the carrier's contract or tariff, not on the Directive 7. A liner service carries goods on a regular basis on set routes, to timetables and sailing dates advertised in advance, for any customer who pays; that is how the EU's rules for liner shipping consortia defined it 35. How much the business pays, and how the charge is calculated, depends on the carrier's contract.

What would the July 2026 proposals change for ships?

The Commission proposed two changes on 17 July 2026 3637. Both are proposals, not law, and the rules above apply until an adopted change applies 3839.

• COM(2026) 616 would bring certain categories of ships between 400 and 5,000 gross tonnage into the EU ETS 38
• It would extend the island, public service, outermost-region and ice-class derogations from 31 December 2030 to 31 December 2035 38
• It would tighten the transhipment rule, listing ports where transhipment exceeds 50% of container traffic instead of 65%, and treat offshore worksites as ports of call 38
• It would reserve up to 110 million allowances to cover part of the extra cost of sustainable maritime fuels, and part or all of the extra cost of zero-emission propulsion; a shipping company that receives them should take them into account when it passes costs on under Article 3gc 38
• COM(2026) 620 would add oil tankers, chemical tankers, gas carriers, LNG carriers, ro-pax ships and passenger ships between 400 and 5,000 gross tonnage to the MRV Regulation from 2029, and merge MRV reporting with that under the FuelEU Maritime Regulation (Regulation (EU) 2023/1805) 39

Our Decode on what the July 2026 review would change covers the whole review proposal 38.

What should a shipping company or its customer do now?

The steps depend on your role:

1. Check whether your ships are in scope: 5,000 gross tonnage and above, carrying cargo or passengers to or from ports in EU countries 2. Or, for offshore ships of that size, prepare for the EU ETS from 2027 316.
2. Settle who the shipping company is. If you are the shipowner, you are responsible unless you mandate your manager or bareboat charterer in a signed document 17. Or, if you are that manager or charterer and hold the mandate, you must send the document to your administering authority 17.
3. Find your administering authority on the Commission's list 28. Or, if you aren't on it, request attribution through THETIS-MRV, the Commission's guidance says 16.
4. Keep each ship's monitoring plan approved and up to date 2324.
5. Each year, submit verified ship reports and company-level data by 31 March, and surrender allowances by 30 September; for 2026 emissions that is 31 March 2027 and 30 September 2027, by our calculation 891040.
6. Check whether a route or ship qualifies for a derogation until 31 December 2030 1030.
7. Check your charter parties (the contracts that set the rate, duration and terms agreed between the shipowner and the charterer) 19: where a charterer buys the fuel or decides the cargo carried or the ship's route and speed, you are entitled to reimbursement of the surrender costs 7. Or, as a charterer or cargo owner, check what your contract says about EU ETS costs before you accept a surcharge.

This is general information, not legal advice. For decisions about your company, check with a lawyer or adviser.