In April 2023, the European Parliament and Council voted to implement changes to the EU ETS, including the sectoral expansion to the maritime industry as of 2024. Many companies in the maritime industry, such as ship owners and operators, will, therefore, be exposed to the EU ETS and its prices. In particular, shipping companies – often the ship owners - will have to manage their compliance obligations and costs. This can be done by purchasing allowances on the EU ETS primary market, operated by EEX, as well as on the spot and derivatives secondary market. On this page, you will find information on the EU ETS specific to the maritime industry, including information on the regulatory background, purchasing options and market access.
The leading marketplace for freight and carbon
With a global network of market participants from financial, energy, and commodity markets as well as extensive experience in both emissions and in maritime markets, EEX is a reliable partner in the development of sustainable shipping. EEX is a leading marketplace for shipping derivatives (FFAs), with around 40% of global volumes in dry freight derivatives, and the central primary auction platform (EU ETS Auctions) on behalf of the EU Commission and the participating EU member and EEA EFTA states. EEX also offers secondary carbon markets for spot and derivatives.
For the fulfilment of their compliance obligation, shipping companies can buy and sell allowances on the EEX primary (spot auction) and secondary market (spot continuous and derivatives). As the price for allowances is market-based and not fixed, operators may want to hedge their exposure to price movements through futures and options over a longer period. Futures are listed at EEX up to nine years ahead. Since 2021, EEX has been publishing a Zero Carbon Freight Index (ZCFI) to provide companies with visibility as regards the carbon price for dry freight.
The markets can be accessed through direct membership options, as well as indirect access providers.
Direct membership requires registration as a trading participant to trade on a specific market or product. You can find out more about direct membership here.
Indirect access is provided through EEX members, such as banks or other intermediaries. Depending on the individual access provider, different services are offered to non-members:
- own trading frontend
- screen of the Access Provider, or
- on behalf service by the Access Provider.
Find out more about indirect access to trading on EEX here.
Intermediaries for the EU ETS*
ACT Financial Solutions B.V.
For further information, please see below the detailed intermediary list. To the website of ACT Financial Solutions B.V.
ABN Amro Bank
For further information, please see below the detailed intermediary list. To the website of ABN Amro Bank.
*The list is constantly updated, non-exhaustive and comprises companies that have expressed their interest in being listed.
EU ETS regulatory and legal FAQs for the maritime sector
Do shipping companies need to buy allowances (EUA) for surrender against reported emissions?
From 2024 onwards, shipping companies are liable under the EU ETS and must surrender allowances in line with their verified and reported emissions.
Who does 'shipping company' as a compliance entity refer to?
The responsible entity will be the ‘shipping company’. This is defined as the shipowner or any other organisation or person, such as the manager or the bareboat charterer, that has assumed the responsibility for the operation of the ship from the shipowner and that, on assuming such responsibility, has agreed to take over all the duties and responsibilities imposed by the International Management Code for the Safe Operation of Ships and for Pollution Prevention, set out in Annex I to Regulation (EC) No. 336/2006 of the European Parliament and of the Council.*
However, since this entity is not always directly in charge of the operation and, thus, emission outputs of a ship, a specific clause was added to the Directive. Specifically, the shipping company will be entitled, under national law, to claim reimbursement for the costs arising from the surrender of allowances from the entity that is directly responsible for the decisions affecting the emissions of the ship. This will, however, serve to affect the compliance obligations of the shipping company and its liability for that towards the administering authority.
* As currently defined in the preliminary published EU ETS Directive: https://data.consilium.europa.eu/doc/document/PE-9-2023-INIT/en/pdf , pending formal publication in the EU’s Official Journal.
Will all types of ships and emissions be included in the ETS?
Generally, CO2 emissions from ships above 5,000 gross tonnage that carry cargo or passengers for commercial purposes will be within the scope of the EU ETS. This will be expanded to CH4 and N20 as of 2026. Large offshore ships will also be included as of 2027.
Certain exemptions exist to address specific national circumstances, such as for small islands or public service contracts.
Will there be an allocation of free allowances?
There will be no free allocation of allowances to shipping companies. From the start, all allowances will be auctioned. However, to ensure a smooth inclusion of the sector in the EU ETS, the surrendering of allowances by shipping companies will be gradually increased with respect to verified emissions reported for the years 2024 and 2025. This means, shipping companies will be liable to surrender allowances for 40% of verified emissions for 2024. In 2025, this increases to 70%. As of 2026 and each year thereafter, shipping companies will have to surrender allowances reflecting 100% of their verified emissions.
Will emissions from all voyages starting or concluding in the EU be covered?
Emissions which are in scope for the ETS are all emissions resulting from intra-EU voyages, all emissions occurring while the vessel is within an EU port, 50% of emissions resulting from voyages to the EU from a 3rd country port and 50% of emissions resulting from outgoing voyages from an EU port to its next 3rd country port.
Will there be ‘shipping’ allowances as it is the case for aviation?
There will are no specific ‘shipping’ allowances available and the addition of the sector is reflected in the overall EUA cap. It is correct that aviation allowances (EUAA), which have been dedicated to aircraft operators, still exist. However, since Phase 4 (2021) of the EU ETS, EUA and EUAA have been fully fungible, and they can be used by all types of operators.
How long are purchased EUAs valid for? Is it possible to buy EUAs now for 2023 and beyond? Are there any benefits to doing this?
Allowances in the EU ETS have no expiration date. They can be purchased now, kept for a certain period, and surrendered in later years. It is also common to hedge the respective demand and price for later years with the respective contracts on the futures market. At EEX, you can trade future expiries up to 9 years ahead.
When will operators have to surrender allowances for a specific calendar year?
Operators have to surrender allowances for a specific calendar year by 30 April of the following year. As of 2024, the allowances have to be surrendered by 30th of September of the following year.
What is the difference between EUAs and voluntary carbon offsets? Are the two interchangeable?
European Emission Allowances (EUAs) are purchased and traded in the compliance market and their use for surrendering by the covered companies is mandatory. The two are not interchangeable and voluntary carbon offsets cannot be used to fulfil a company’s obligations in the compliance market.
How high can EUA prices rise? Is there an upper price limit?
The EU ETS is a volume-based system with free price formation and without a price limit or floor.
However, within the system, there is the possibility of an increase in the supply of allowances in the event of extreme price fluctuations under Article 29a of the EU ETS Directive.
Where do operators have to surrender allowances?
Operators have to surrender allowances for compliance from their operator holding account which is set up by their respective national authority. Shipping companies are expected to receive a dedicated type of operator holding account which will be detailed in the Registry Regulation. Each shipping company shall open one shipping operator holding account with their administering authority.
Purchasing and trading ETS emission allowances
Which options do I have to buy certificates?
Allowances can be bought on the EEX primary (spot auction) and secondary market (spot continuous and derivatives).
Shall ship owners hedge demand in Allowances in advances? How will this be done?
As the price for allowances is market-based and not fixed, operators may want to hedge their exposure to carbon price movements. Allowances can be bought and traded on a spot basis (auction and continuous trading) or on the futures market up to nine years ahead.
What are the contract sizes on the primary and secondary market?
The primary market is set to a tradeable minimum of 500t and the secondary market to 1000t.
Where can I find price information for EUA (spot and front years)?
Are there price differences for the certificates between the primary and secondary markets?
Generally, there are no structural price differences between the primary and secondary markets. Price differences may occur, for instance, due to the different “time stamps” of trades or size.
Why are there are differences in fees between the primary and secondary markets?
Primary auction fees result from the auctioning regulation and tender procedures. The fees for the secondary market are based on commercial decisions.
EU ETS market access for shipping
What access options are there for buying allowances on EEX?
The different membership options are outlined on the EEX website.
More information is available in the document Participation in Emissions Auctions*
*Please note that the auctions regulation is currently being revised and updated.
As of what volume does direct EEX membership make sense?
In principle, EEX is a wholesale market. Whether direct membership or indirect market access is preferable depends on the individual situation and various other factors. Please contact firstname.lastname@example.org for details.
As my company is already set up to trade FFA contracts on EEX, can I add EUA contracts to my account?
Members can add further contracts if desired. Indirect participants should contact their access providers for more information.
Does the membership for the German national ETS (nEHS) also cover EU ETS for shipping clients?
My company would like to offset emissions beyond EU ETS obligations through voluntary carbon credits. Can I buy these on EEX?
A variety of Voluntary Carbon Contracts is offered at our EEX Group Exchange Nodal.
The maritime market in the EU ETS
Is it possible that inclusion into the ETS might create a ‘two-tier’ market for shipping, with newer, cleaner vessels trading within Europe and older ones locked out in other trades?
This is what the EU calls fleet optimisation. The EU does not consider this a large risk, as it is does not really constitute evasion. There are also expectations that this type of ‘carbon arbitrage’ would be short lived given the progressive global standards for ship designs, and the potential for emissions schemes in other jurisdictions.
If ship owners pay the cost of allowances, how will this affect charterers / cargo owners?
For example, if a ship owner offers a voyage rate for a particular cargo, they may quote a ‘carbon-included’ price, similar to how bunker fuel is priced into the $/ton voyage charter rate. If a vessel is hired on a time-charter basis, the charterer is principally responsible for all operational costs of the vessel. Since the emissions report is finalised after the voyage is concluded, there may need to be provisions for either deposits or other payment agreements to be settled in favour of the ship owner, after the vessel has discharged its cargo. Alternatively, a charterer could arrange for their own emission allowances to be transferred to the ship owner after the voyage has concluded.
In general, it is expected that the costs of carbon allowances will be passed through to the delivered commodity price. However, the EU’s analysis shows low price impacts on industrial commodities overall, and only a minor negative change in demand due to carbon costs.