Since the 1st of January 2025, shipowners have faced new, strict restrictions on greenhouse gas (GHG) intensity levels when calling in EU ports. Unlike previous regulations, FuelEU Maritime is enforced by hefty penalties for non-compliance, driving action in ways previous initiatives, like the Carbon Intensity Indicator (CII), struggled to achieve.

These penalties are designed to make an impact, and they are. At €2,400 per tonne of VLSFO energy equivalent, fines are steep enough to turn compliance into a business-critical decision. Analysis from OceanScore estimates that passenger vessels could face penalties averaging €520,000 per year, while the global tanker fleet may collectively incur costs of €2 billion by 2030, according to Broker BRS Group. Meaning that the seemingly small initial GHG reduction of 2% has real influence.

With it still being early days for FuelEU Maritime compliance, shipowners and operators are still evaluating the best strategies on the table but it’s best not to wait too long. To provide some color, NAPA has conducted simulations comparing the costs of both a 182kDWT bulker operating on a cross Atlantic route and for a roro equipped with Flettner rotors operating inside the EU.

It must be acknowledged that trying to forecast costs until 2050 using static values in a very dynamic environment (e.g. EUA pricing, bunker pricing, bunkering strategy, FuelEU compliance strategies) can be difficult. Still, this data suggests that while FuelEU maritime is not yet a significant contributor for the total fuel and emission related operational expenses, this will quickly change for both vessels as FuelEU Maritime requirements tighten.

The graph on the left shows that the non-compliant bulker will have to start paying FuelEU Maritime penalties from this year itself. The graph on the right depicting the roro with Flettner rotors, however, highlights that investments in wind assisted propulsion systems will help offset FuelEU Maritime costs, helping vessels stay compliant till 2030 due to the emission savings achieved.

Further simulations based on NAPA’s performance model reveal the scale of the potential costs involved – although exact prices will be set by the market. For example:

• A typical capesize bulk carrier operating between Brazil and Rotterdam consumes approximately 16,700 tons of fuel annually, considering both VLSFO 380 CST and LSMGO. This would put its GHG intensity to 91.4gCO2/MJ and take its compliance balance to 703.70 tonCO2 eq in deficit. This represents nearly €450,750 in penalties for 2025, adding 5.1% to bunkering costs. Alternatively, based on MMMCZCS’ estimates that external pooling will cost around €420 per ton, the cost increase would instead be 0.9%.
• An LNG-powered feeder-size container vessel operating between Rotterdam and the Baltic Sea would consume approximately 2250 tons of LNG. Given the well-to-wake emission factors set by FuelEU, the vessel would generate 30 tons of compliance surplus. It would be just about compliant and wouldn’t have much surplus to trade through pooling.

All of this sets the scene nicely for new business opportunities as FuelEU Maritime doesn’t just penalize; it creates rewards and opportunities. Vessels that meet or exceed compliance thresholds can not only increase asset value and improve access to finance but can also offer surplus compliance credits for pooling to other vessels. Pooling, borrowing, and trading compliance surpluses could lead to the creation of new markets, rewarding companies who are proactively investing in green technologies. For compliant vessels, this isn’t just about avoiding fines – it’s about gaining a competitive edge in the market.

How can ship owners decide on the best path for them?

Everyone will approach FuelEU differently, but whichever path is chosen, early knowledge and proactive action will pay dividends. Data will be essential from the start to enable shipowners to simulate scenarios and assess the cost-effectiveness of different compliance strategies. Tools like the NAPA FuelEU Maritime module have been designed to provide precise calculations on a voyage-specific and fleet-wide basis, helping shipowners weigh up these options with confidence.

Real-time monitoring of fuel consumption and emissions allows shipowners to track their compliance. For vessels nearing their limits, data provides timely insights, enabling decisions like adjusting routes, increasing drop-in biofuel usage, or reallocating compliant ships. Without such monitoring, shipowners risk incurring preventable penalties or missing opportunities for operational efficiency.

For vessels that are over compliant, data becomes a means to unlock financial opportunities. NAPA’s FuelEU Maritime module calculates surplus availability and offers projections on pooling profitability, ensuring shipowners can maximize returns on their green investments.

Looking ahead

FuelEU isn’t happening in a vacuum. It builds on the spirit of regulations like the EU ETS and the IMO’s CII and affirms the industry’s general direction of travel towards decarbonization. We must also consider the IMO Net Zero Framework, which is expected to be ratified in October 2025. Time will tell whether this framework will make EU-level GHG regulations for shipping obsolete, however the trend of more stringent environmental regulations remains. Shipowners who embrace this shift will not only avoid penalties but also position themselves as leaders in a more sustainable industry. By leveraging data, adopting green fuels, and exploring compliance strategies like pooling, the maritime sector can turn regulation into a catalyst for innovation and growth.
Source: By Ossi Mettälä, Product Manager, NAPA Shipping Solutions