FuelEU Maritime Regulation from 1 January 2025
The European Union's FuelEU Maritime Regulation (EU) 2023/1805 establishes a regulatory framework for reducing the greenhouse gas intensity of energy used on board ships calling at European Union ports.
The regulation forms part of the European Union's wider decarbonisation framework and applies from 1 January 2025, following the preparation and monitoring requirements introduced during 2024.
FuelEU Maritime is designed to encourage the use of renewable and low-carbon fuels and clean energy technologies while providing flexibility to shipping companies in determining how individual ships and fleets achieve the required compliance targets.
Unlike the EU ETS, which creates a carbon-market obligation based on applicable greenhouse gas emissions, FuelEU Maritime focuses on the greenhouse gas intensity of the energy used on board and introduces additional requirements for zero-emission operation at berth for specified ships.
Scope of FuelEU Maritime
FuelEU Maritime generally applies to ships above 5,000 gross tonnage calling at European Union ports, regardless of the flag they fly, subject to the detailed scope and exemptions established by Regulation (EU) 2023/1805.
The regulation establishes requirements covering the energy used on board during voyages and port stays falling within its scope. The detailed calculation and monitoring framework considers the applicable well-to-tank and tank-to-wake greenhouse gas emissions associated with the energy used by the ship.
Ships Above 5,000 GT
The principal FuelEU Maritime requirements apply to ships above 5,000 gross tonnage calling at EU ports, subject to the regulation's detailed scope and exemptions.
EU Port Calls
Applicable voyages and port stays associated with EU ports are subject to the monitoring and calculation requirements established by the regulation.
Energy Used On Board
FuelEU evaluates the greenhouse gas intensity of energy used on board, taking into account the applicable energy sources and emission factors.
Zero-Emission at Berth
Additional requirements apply to certain passenger and container ships concerning zero-emission operation while at berth at specified EU ports and from the applicable implementation dates.
Monitoring Plan
Each applicable ship requires a ship-specific monitoring plan addressing the information and data required under FuelEU Maritime.
Annual Reporting
Companies must compile and submit the required annual FuelEU information to the selected verifier within the applicable regulatory timetable.
Verification
FuelEU monitoring and reporting information is subject to verification by an appropriately accredited verifier under the regulatory framework.
Compliance Balance
The verified data is used to determine the ship's compliance balance and whether additional compliance measures are required.
1. FuelEU Maritime GHG Intensity Reduction Targets
FuelEU Maritime establishes progressively stricter limits on the average greenhouse gas intensity of the energy used on board applicable ships.
The reference point is the average greenhouse gas intensity of the energy used on board in 2020. The required reduction increases in stages through 2050.
2025
2% reduction compared with the 2020 reference level.
2030
6% reduction compared with the 2020 reference level.
2035
14.5% reduction compared with the 2020 reference level.
2040
31% reduction compared with the 2020 reference level.
2045
62% reduction compared with the 2020 reference level.
2050
80% reduction compared with the 2020 reference level.
These targets mean that FuelEU Maritime is not a one-time compliance requirement. Ships and companies need to evaluate their energy use, fuel selection, operational profile, technical performance, and compliance strategy over successive reporting periods.
2. FuelEU Monitoring Plan
The FuelEU monitoring plan provides the ship-specific framework for collecting the information required to calculate the greenhouse gas intensity of energy used on board.
The monitoring plan must address the applicable monitoring methodology and the data required by FuelEU Maritime. It should reflect the actual configuration and operational characteristics of the vessel.
Key Monitoring Areas
- Identification of the ship and applicable company
- Applicable ports of departure and arrival
- Dates and times of arrival and departure
- Duration of the ship's stay at berth
- Fuel consumption at sea and at berth
- Type and quantity of energy used
- Applicable emission factors
- Electricity received through onshore power supply
- Substitute sources of energy, where applicable
- Ice-class information and relevant voyage conditions
The monitoring plan should be maintained as a controlled technical document and updated where changes to the ship, equipment, operational profile, energy sources, or applicable regulatory requirements affect the monitoring methodology.
3. FuelEU Energy and Emissions Data
FuelEU Maritime requires accurate monitoring of the energy used on board. The quality of the underlying data is therefore fundamental to the final calculation of the ship's annual greenhouse gas intensity and compliance balance.
Data should be traceable from the original operational records through the calculation process and into the annual FuelEU report.
Fuel Consumption
Fuel quantities and applicable fuel types should be accurately recorded and supported by appropriate bunker and operational documentation.
Energy Consumption
Energy used by the vessel during applicable voyages and port stays forms an important part of the FuelEU calculation.
Emission Factors
Applicable well-to-tank and tank-to-wake emission factors must be correctly applied according to the FuelEU methodology.
Supporting Records
Bunker delivery documentation, fuel records, operational records, electricity data, and other supporting information should be retained and traceable.
4. Well-to-Tank & Tank-to-Wake Emissions
FuelEU Maritime uses a well-to-wake approach to determine the greenhouse gas intensity of energy used on board.
This approach considers emissions associated with the production and supply of energy as well as emissions resulting from its use on board the ship.
Well-to-Tank
Well-to-tank emissions relate to the production, processing, and distribution of the energy or fuel before it reaches the ship.
Tank-to-Wake
Tank-to-wake emissions relate to emissions produced by the ship when the energy or fuel is used on board.
The combined methodology is important because a fuel or energy source cannot be assessed only on the basis of emissions released during onboard use. FuelEU Maritime evaluates the relevant greenhouse gas intensity across the applicable well-to-wake framework.
5. Alternative Fuels & Low-Carbon Energy
FuelEU Maritime is designed to be technology-neutral and provides shipping companies with flexibility in selecting fuels and technologies capable of reducing the greenhouse gas intensity of energy used on board.
Depending on the vessel, operational profile, fuel availability, infrastructure, and applicable technical arrangements, compliance strategies may include renewable fuels, low-carbon fuels, shore power, substitute energy sources, wind-assisted propulsion, or other technologies and operational measures.
Renewable Fuels
Renewable fuels may provide a pathway for reducing the greenhouse gas intensity of energy used on board, subject to the applicable FuelEU sustainability and certification requirements.
Low-Carbon Fuels
Lower-carbon energy sources may contribute to compliance depending on their applicable FuelEU emission factors and the ship's overall energy profile.
Shore Power
Onshore power supply can reduce the need for onboard combustion during applicable port stays and becomes increasingly important for vessels subject to the zero-emission-at-berth requirements.
Energy Technologies
Alternative energy technologies may contribute to reducing the ship's overall greenhouse gas intensity where they meet the applicable regulatory requirements.
6. Zero-Emission at Berth Requirements
FuelEU Maritime introduces additional requirements for certain passenger ships and container ships above 5,000 GT while at berth.
The objective is to reduce emissions generated while ships are moored at the quayside by requiring the use of onshore power supply or another applicable zero-emission technology under the conditions established by the regulation.
From 1 January 2030
The zero-emission-at-berth requirement applies to specified passenger and container ships in EU ports covered by the Alternative Fuels Infrastructure Regulation framework.
From 1 January 2035
The requirement extends to all EU ports equipped with onshore power supply facilities, subject to the detailed provisions of FuelEU Maritime.
Onshore Power Supply
Ships may use onshore power supply to meet the applicable zero-emission-at-berth requirement where the relevant infrastructure and regulatory conditions are available.
Alternative Zero-Emission Technology
The regulation also provides for the use of applicable zero-emission technologies in accordance with the requirements and conditions established by FuelEU Maritime.
7. Annual FuelEU Reporting & Verification
FuelEU Maritime requires companies to compile annual information based on the monitored data collected during the reporting period.
The first FuelEU reporting period was 1 January to 31 December 2025. The first FuelEU report was submitted to the selected verifier by 31 January 2026.
The verifier uses the applicable monitored information to determine the ship's annual greenhouse gas intensity and compliance balance in accordance with the regulation.
Reporting Documentation
- Approved or assessed FuelEU monitoring plan
- Fuel and energy consumption records
- Port arrival and departure records
- Berth duration information
- Onshore power supply records, where applicable
- Substitute energy information, where applicable
- Fuel characteristics and emission-factor information
- Relevant bunker documentation
- Ship operational data
- Supporting calculations and records
8. FuelEU Compliance Balance
Following verification, FuelEU Maritime determines whether the ship has achieved the applicable greenhouse gas intensity requirement. The resulting compliance balance indicates whether the ship has achieved a surplus or has a deficit for the reporting period.
A positive compliance balance may provide flexibility through the mechanisms established by FuelEU Maritime. A negative balance may require corrective compliance action and can result in a FuelEU penalty if the applicable deficit is not otherwise resolved in accordance with the regulation.
Compliance Surplus
A ship achieving a positive compliance balance may use the regulatory flexibility mechanisms available under FuelEU Maritime, including banking or pooling where the applicable conditions are satisfied.
Compliance Deficit
A negative compliance balance indicates that additional compliance action may be required under the FuelEU framework.
Banking
Positive compliance surplus may be banked for future reporting periods in accordance with the conditions of Article 20 of the regulation.
Borrowing
Under specified conditions, a company may borrow an advance compliance surplus from a subsequent reporting period, subject to the applicable regulatory surcharge and limitations.
9. FuelEU Pooling Mechanism
FuelEU Maritime provides a pooling mechanism allowing the compliance balances of two or more ships to be combined under the conditions established by the regulation.
Pooling can allow over-performing ships to compensate for under-performing ships within the regulatory framework, provided that the applicable conditions are satisfied and the overall pool remains compliant.
Important Pooling Conditions
- A ship's compliance balance cannot be included in more than one pool during the same reporting period
- Pooling must be registered in the FuelEU database
- Participating companies must comply with the applicable pool registration requirements
- The pool must be overseen by a single verifier
- The applicable compliance allocation must be recorded in the FuelEU database
- Pooling must satisfy the regulatory conditions governing compliance balances
Pooling should therefore be considered as part of a structured fleet compliance strategy rather than as a substitute for accurate monitoring and reporting.
10. FuelEU Penalties & Consequences of Non-Compliance
FuelEU Maritime establishes penalties for applicable compliance deficits and certain non-compliant port calls.
A company with a compliance deficit that remains unresolved under the applicable regulatory mechanisms may be required to pay a FuelEU penalty. Additional penalties can apply where a ship has made non-compliant port calls in circumstances covered by the regulation.
GHG Intensity Deficit
A compliance deficit may result in a financial penalty calculated using the methodology established in the FuelEU Maritime regulation.
Non-Compliant Port Call
Additional penalties may apply to ships making a non-compliant port call where the zero-emission-at-berth requirements apply.
Repeated Deficits
Consecutive reporting periods of non-compliance can result in increased penalties under the regulatory framework.
Port Consequences
Persistent failure to fulfil applicable FuelEU obligations can result in further regulatory consequences under the enforcement provisions of the regulation.
11. FuelEU Maritime & EU ETS Relationship
FuelEU Maritime and the EU Emissions Trading System for shipping are separate European regulatory instruments, although they form part of the European Union's wider maritime decarbonisation framework.
The two systems should not be treated as interchangeable. EU ETS establishes a carbon-market obligation involving EU Allowances, whereas FuelEU Maritime establishes requirements relating to the greenhouse gas intensity of energy used on board and additional zero-emission-at-berth requirements for specified ships.
EU ETS
The EU ETS introduces an emissions trading and allowance surrender obligation for maritime emissions falling within its applicable scope.
FuelEU Maritime
FuelEU Maritime regulates the greenhouse gas intensity of energy used on board and establishes additional requirements for zero-emission operation at berth for specified ships.
EU MRV
EU MRV provides the monitoring, reporting, and verification framework for applicable maritime emissions data and is closely connected to the broader EU maritime climate compliance framework.
Integrated Compliance
Shipping companies should coordinate FuelEU, EU ETS, and EU MRV data and documentation so that the vessel's regulatory information remains consistent and traceable.
12. Preparing a Vessel for FuelEU Maritime Compliance
FuelEU compliance should be prepared as an ongoing technical and operational process rather than as an annual reporting exercise.
Shipowners, ISM companies, technical managers, and vessel operators should identify potential data-quality, documentation, fuel, energy, and operational issues before the annual verification process.
Review Monitoring Plan
Confirm that the ship-specific FuelEU monitoring plan reflects the vessel's actual systems, fuel arrangements, operations, and applicable regulatory requirements.
Verify Fuel Records
Review bunker delivery notes, fuel consumption records, fuel quantities, fuel types, and supporting documentation.
Review Port Data
Verify arrival, departure, berth duration, port location, and applicable port-call information.
Check OPS Data
Where applicable, verify electricity received from onshore power supply and supporting records.
Review Energy Sources
Identify all energy sources used on board and confirm that the applicable emission factors and calculation methodology are correctly applied.
Assess Compliance Balance
Review the expected compliance position and identify potential measures before the annual verification process.
Review Supporting Evidence
Ensure that operational records, calculations, certificates, fuel documentation, and other supporting evidence are complete and traceable.
Plan Corrective Action
Where a potential compliance deficit is identified, evaluate appropriate technical, operational, fuel, or flexibility measures.
13. Technical Areas Affecting FuelEU Compliance
FuelEU compliance can be influenced by a vessel's technical configuration, operating profile, fuel systems, auxiliary machinery, electrical systems, energy efficiency, and port operations.
Areas Requiring Technical Attention
- Main engine fuel consumption
- Auxiliary engine operation
- Boiler and thermal energy consumption
- Fuel measurement and monitoring systems
- Fuel storage and supply arrangements
- Alternative fuel systems
- Onshore power supply compatibility
- Electrical distribution and shore connection systems
- Energy-saving technologies
- Wind-assisted propulsion where applicable
- Operational speed and voyage profile
- Port stay and berth operations
14. FuelEU Documentation & Audit Preparation
Accurate documentation is essential because the FuelEU verification process depends on the reliability, completeness, and traceability of the information submitted by the company.
A technical review before verification can help identify inconsistencies between operational records, fuel documentation, monitoring-plan procedures, calculations, and supporting evidence.
Bunker Documentation
Review bunker delivery notes, fuel quantities, fuel grades, consumption records, and associated documentation.
Engine Records
Review engine operating records, fuel consumption records, machinery logs, and other relevant technical information.
Port Records
Verify port arrival, departure, berth duration, shore power, and other applicable port-call information.
Calculation Records
Review calculation inputs, emission factors, energy data, supporting spreadsheets, and relevant compliance records.
15. FuelEU Maritime Compliance as an Ongoing Technical Responsibility
FuelEU Maritime should be incorporated into the vessel's normal technical and operational management processes. Waiting until the annual reporting deadline can make it more difficult to correct missing data, inconsistent records, or technical limitations.
Continuous monitoring allows shipowners and technical managers to identify trends in fuel consumption, energy use, port operations, greenhouse gas intensity, and compliance balance.
This approach also supports longer-term decisions concerning alternative fuels, energy efficiency, shore power, operational measures, vessel modifications, and fleet-level compliance strategies.
16. Independent Marine Surveying & Technical Consultancy
PAMS Pacific Admiralty Maritime Services provides independent marine surveying and technical consultancy support for shipowners, operators, technical managers, offshore projects, and other maritime stakeholders.
Technical consultancy may include vessel condition assessments, marine technical inspections, regulatory compliance support, environmental vessel audits, energy-related technical reviews, offshore engineering consultancy, FPSO/SPM technical support, and preparation for statutory or class examinations.
For FuelEU Maritime, PAMS can support clients with technical documentation review, vessel data-readiness assessments, operational-record review, compliance preparation, technical inspection, and audit or verification preparation.
PAMS does not represent itself as an accredited FuelEU Maritime verifier. Where formal verification is required, the applicable verification activity is performed by the appropriately accredited verifier selected in accordance with the regulatory framework.
Frequently Asked Questions
What is FuelEU Maritime?
FuelEU Maritime is the European Union's regulatory framework established by Regulation (EU) 2023/1805 to reduce the greenhouse gas intensity of energy used on board ships calling at EU ports and to promote the use of renewable and low-carbon fuels and clean energy technologies.
When did FuelEU Maritime enter into application?
FuelEU Maritime applies from 1 January 2025. Monitoring-plan provisions applied earlier as part of the preparation for the first reporting period.
Which ships are covered by FuelEU Maritime?
FuelEU Maritime generally applies to ships above 5,000 gross tonnage calling at EU ports, regardless of flag, subject to the detailed scope, exemptions, and special provisions contained in Regulation (EU) 2023/1805.
What are the FuelEU Maritime GHG intensity targets?
The required reduction in the annual average greenhouse gas intensity of energy used on board is 2% in 2025, 6% in 2030, 14.5% in 2035, 31% in 2040, 62% in 2045, and 80% in 2050, compared with the 2020 reference level.
What information must ships monitor under FuelEU Maritime?
Monitoring includes information such as fuel and energy consumption, ports of departure and arrival, arrival and departure times, berth duration, electricity received through onshore power supply, applicable emission factors, substitute energy, and other information required by the ship-specific monitoring plan.
What is the first FuelEU reporting deadline?
The first reporting period covered 1 January to 31 December 2025. The first FuelEU report was due to the selected verifier by 31 January 2026.
Does FuelEU Maritime require onshore power supply?
FuelEU Maritime introduces zero-emission-at-berth requirements for specified passenger and container ships above 5,000 GT. The requirements generally involve connection to onshore power supply or the use of another applicable zero-emission technology, subject to the regulatory conditions and implementation dates.
When do the zero-emission-at-berth requirements begin?
For specified passenger and container ships, the requirements begin from 1 January 2030 in EU ports covered by the applicable Alternative Fuels Infrastructure Regulation framework. The requirements extend to all EU ports equipped with onshore power supply facilities from 1 January 2035, subject to the detailed provisions of FuelEU Maritime.
What is a FuelEU compliance balance?
The compliance balance represents the ship's position against the applicable FuelEU greenhouse gas intensity requirement after the relevant data has been calculated and verified. A positive balance represents over-compliance, while a negative balance indicates a compliance deficit requiring action under the applicable regulatory mechanisms.
Can FuelEU compliance surplus be banked?
Yes. FuelEU Maritime allows a positive compliance surplus to be banked for a subsequent reporting period in accordance with the conditions established by Article 20 of Regulation (EU) 2023/1805.
Can ships pool their FuelEU compliance balances?
Yes. FuelEU Maritime provides a pooling mechanism under which the compliance balances of two or more ships may be pooled, subject to the regulatory conditions, registration in the FuelEU database, and verification requirements.
Is FuelEU Maritime the same as the EU ETS?
No. FuelEU Maritime and the EU ETS are separate regulatory instruments. EU ETS establishes an emissions trading and allowance surrender system, while FuelEU Maritime focuses on the greenhouse gas intensity of energy used on board and includes additional zero-emission-at-berth requirements for specified ships.
Can PAMS provide FuelEU Maritime compliance support?
Yes. PAMS Pacific Admiralty Maritime Services provides independent marine surveying and technical consultancy support including technical documentation review, vessel data-readiness assessment, operational-record review, environmental vessel audits, technical inspections, compliance preparation, and preparation for verification activities. PAMS does not represent itself as an accredited FuelEU Maritime verifier.
PAMS Pacific Admiralty Maritime Services
PAMS Pacific Admiralty Maritime Services is an independent marine technical consultancy specializing in marine surveying, marine technical consultancy, offshore engineering consultancy, FPSO engineering support, marine audits, technical inspections, and regulatory compliance.
Technical compliance services include statutory and class survey preparation, vessel condition assessments, environmental vessel audits, technical equipment inspections, regulatory compliance verification support, offshore operations, and engineering consultancy.
PAMS supports shipowners, operators, technical managers, offshore projects, and maritime stakeholders through independent technical assessments and compliance-focused consultancy.
Based in Manila, Philippines — operating as an independent technical consultancy.
Need FuelEU Maritime Compliance Support?
PAMS Pacific Admiralty Maritime Services provides independent marine surveying and technical consultancy support for shipowners, operators, technical managers, and offshore projects requiring FuelEU Maritime preparation, technical documentation review, environmental assessment, and compliance support.