With the FuelEU Maritime regulation, the newest and most ambitious environmental policy will come into force on 1 January 2025. Ships calling at ports in the European Union must start the transition to alternative fuels and energy sources, leading to significant changes in maritime operations in the years to come. Vessels that do not comply with the FuelEU Maritime regulation will face substantial penalties.

The FuelEU Maritime regulation of the European Union aims to align the shipping industry with the EU’s climate neutrality goals. To contribute to this goal, the shipping industry must progressively reduce its greenhouse gas (GHG) emissions by 80% by 2050 compared to 2020.

Learn more about FuelEU Maritime

Biofuels will have the deepest impact on FuelEU Maritime penalties. The use of the right biofuel will be crucial.

Penalties of up to 310,000 euros for an average vessel

It will not be possible to comply with FuelEU Maritime through efficiency measures and reduced fuel consumption alone. Instead, new fuels and sources of energy must be used as of 2025. Vessels that continue to exclusively use conventional fuels (LSFO, ULSFO, MGO) for their energy needs will not comply with the FuelEU Maritime regulation and a penalty payment will be enforced on the vessel.

In 2025, an average intra EU trading vessel with an annual fuel consumption of 5,000 MT of conventional fuel will be penalised 200,000 to 310,000 euros at the end of the year depending on the fuel grade if no alternative energy options are used. With every year of continued non-compliance, penalties will increase by an additional 10%. Furthermore, when the GHG intensity limits of FuelEU become more stringent in 2030, penalties will dramatically increase. In addition, failure to comply with the shore power requirements for container and passenger vessels will result in huge penalties, making non-compliant port calls financially unviable.

Direct and indirect compliance measures

There are various measures to achieve compliance with FuelEU Maritime. These can either directly concern vessel operations or achieve compliance indirectly. Direct measures are

  • The use of alternative fuels
  • The use of shore power
  • The installation of sails

When it comes to alternative fuels, solutions range from the use of recycled cooking oils to green hydrogen. Each type of fuel requires careful evaluation, depending on the fuel and the vessel. For the use of shore power or sails, the trade patterns of the vessel need to be assessed, and costs and benefits must be weighed.

When considering the adoption of alternative fuels, it's crucial to understand the total costs associated with each fuel option for comparison.

Apart from using low-carbon fuels and compliance technologies, the EU has implemented flexible options to reduce the GHG intensity penalties. These indirect measures are

  • Borrowing - in case of a compliance deficit, the company may borrow a small credit from the next reporting period
  • Banking - meaning using a compliance surplus that was generated in excess in previous years
  • Pooling multiple vessels to balance deficiencies in some with surpluses in others

Each of the indirect measures must be carefully evaluated: Borrowing compliance could prove to be an expensive mistake, potentially resulting in significantly increased penalties in the following year. The banking of compliance could lead to a penalty exposure for another of your vessels if pooling is not used efficiently. Any pooling arrangement, especially when it comes to contractual agreements, is highly complex and, while potentially offering significant cost savings, must be carefully assessed.

How can BSM support with FuelEU compliance?

Over the past year, BSM has made significant efforts to support clients in complying with FuelEU Maritime, enabling to manage the new regulation and minimise overall compliance costs effectively and dynamically.

  • First milestone achieved, FuelEU Monitoring Plans submitted: By 31 August 2024, all vessels under the scope of FuelEU Maritime had to submit Monitoring Plans to authorised verifiers (for example DNV). BSM successfully submitted all plans before that deadline, ensuring that the managed vessels can comply with all aspects of the regulations from the very beginning.
  • Monitoring, recording and reporting systems and procedures in place: BSM developed integrated IT systems and procedures ensuring the accurate monitoring, recording, correction and reporting of all relevant voyage and emission data of FuelEU effected vessels.
  • Transparency with forecasting and calculations: BSM created a FuelEU Simulator and Dashboard integrated into its PAL ship management software. These tools allow users to visualise all FuelEU Maritime-relevant data and ensure reliable forecasts and calculations. They enable to simulate anticipated GHG intensity, compliance balances and FuelEU penalties for the years 2025 to 2050, based on the data entered. BSM is working on a solution to give customers access to the new tools via LiveFleet gaining full transparency.
  • Evidence-based decision-making on modifications and costs: BSM is able to simulate the effects of modifications on managed vessels and provide actionable, ship and trade-specific insights on how customers can minimise compliance costs. Whether that is through simulating the effects of using shore power or estimating the amount of biodiesel required for a single voyage or a whole fleet. This offers full transparency across the wide range of options and a better bargaining position for example in charter agreements.
  • Insights into pooling options: BSM’s systems can monitor the compliance status of anticipated pools and further provide insights into how pools can be managed most efficiently.

“We are ready on the service side, we are ready on the system side, and we are ready on the workforce side”, Anil Jacob confirms. He is Head of Fleet Performance and responsible for BSM’s Emission Management Services. “From the outset, our approach was not just to develop measures to ensure the necessary compliance management. We wanted to go further and create real added value”. FuelEU Maritime is highly complex and multi-dimensional that pitfalls lurk everywhere. A wrong decision you make today, for example regarding the use of alternative fuels or new technologies, can cost you very dearly in the future and affect your competitiveness. “We offer our customers a full and transparent picture of each of their ships and vessel-specific solutions. This ensures the certainty of having all aspects and options fully in view and being able to make substantiated decisions.”

In addition, BSM prepares and sensitises its employees in the fleet teams and its seafarers on board the ships on FuelEU Maritime. “We have held numerous webinars for shore staff and are preparing our seafaring staff for the new FuelEU requirements as part of our Vessel Performance and Decarbonisation Courses, said Jacob. In the end, it's all about everyone pulling together, the fleet teams, the seafarers, IT developers, performance superintendents, data analysts and many more, and of course in close cooperation with owners and their charter customers. “I am convinced that we are ahead of track.”

BIMCO Shipman Clause for FuelEU Maritime

The FuelEU Maritime regulation requires a revision of contracts to address responsibilities and financial risks. This is not only the case for charter parties. A revision of ship management contracts is necessary to address the new challenges introduced by the FuelEU Maritime regulation.

BIMCO is still working on creating a FuelEU Maritime Clause for the Shipman Agreements. The outline clause in its present form acknowledges that for the purpose of FuelEU Maritime, the DOC holder serves as frontend towards the EU authorities. It will describe the contractual task basket between ship manager and vessel owner as follows: The ship manager will be in charge of handling the fuel and perform monitoring and reporting tasks according to vessel owners’ needs. The vessel owner will be in charge of ensuring compliance through the above means e.g., by sourcing compliant biofuel, pooling the vessel, banking or borrowing. Where owners decide to trade the vessel uncompliant, the penalties are on owners with sufficient security to be granted to the DOC holder.

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