Overview
Recent attention in shipping carbon compliance has centred on the EU ETS reform and its impact on port connectivity, and on the EMP application arrangements in the early enforcement phase of UK ETS maritime. For FuelEU Maritime, the key milestones of the first compliance year have now passed, but companies still need to keep track of the DoC, penalties, pooling reviews and contractual arrangements. At IMO, the meeting schedule around the Net-Zero Framework in the second half of the year also deserves early attention.
1. EU ETS: port connectivity and "evasion" risks remain in focus
The impact of the EU ETS on European port connectivity and service patterns continues to draw industry attention. The second set of results from the EU ETS Observatory published by Puertos del Estado, the Spanish state ports authority, shows a decline in the connectivity of major European ports in deep-sea container services between 2023 and March 2026. According to the report, direct connectivity fell by 5 percentage points at major northern European ports and by as much as 18 percentage points at major eastern Mediterranean ports.
The report suggests that, following implementation of the EU ETS, some services and transhipment arrangements may be shifting to neighbouring ports outside the EU, raising questions of carbon leakage and port competitiveness. Puertos del Estado also notes that the ETS revision proposal published by the European Commission on 17 July already acknowledges the need to adjust the mechanism in order to avoid unintended effects on EU maritime connectivity and port competitiveness.
Compliance note: The impact of the EU ETS on shipping is no longer only a question of who buys EUAs and who bears the cost; it increasingly extends to network design, port selection, transhipment arrangements and supply chain configuration. Shipowners, liner operators and cargo interests with long-term European trades should continue to follow how the EU adjusts rules around the definition of transhipment ports, evasive port calls and carbon leakage prevention.
2. UK ETS maritime: the EMP application deadline is counting down
UK ETS maritime has applied since 1 July 2026. UK government guidance is clear that maritime operators must set up a METS account and apply to the regulator for an Emissions Monitoring Plan (EMP) within 42 days of first carrying out UK ETS maritime activity. The first maritime scheme year runs from 1 July to 31 December 2026, and the surrender deadline for both the 2026 and 2027 scheme years is 30 April 2028.
For companies that were already carrying out relevant maritime activity on 1 July, the EMP application window is counting down. Key points to confirm now include: whether the METS account has been opened; whether the responsible party is the registered owner or an ISM company that has taken on the responsibility; whether the EMP vessel list, emission sources, fuel types and monitoring methods are complete; and whether arrangements for the verifier, UKA procurement and internal data records are in place.
Compliance note: UK government guidance also states that the EMP must set out the vessels for which the company is responsible, together with the relevant activities, fuels, emission sources, emission factors and monitoring methods. Adding vessels, adding new fuels or emission sources, or changing monitoring methods may constitute a significant change to the EMP. For companies, UK ETS is not a one-off account-opening exercise but an annual compliance process that requires ongoing maintenance.
3. FuelEU Maritime: after the first year, focus shifts to review and contracts
For FuelEU Maritime, the key milestones of the first compliance year have passed. As set out by DNV, companies must record any advance compliance surplus or banking arrangement and register their pooling intention by 30 April each year; verifiers then record the composition of the pool and approve the compliance balance. By 30 June, where a vessel is not subject to a penalty, the verifier issues the FuelEU Document of Compliance (DoC); where a vessel has a compliance deficit and owes a FuelEU penalty, the DoC is issued by the administering state or authority once the company has paid the penalty.
At this stage, companies can usefully review their 2025 FuelEU compliance: whether each vessel has obtained its DoC; whether the compliance balance is negative; whether penalty payments are involved; whether pooling arrangements were executed as planned; and whether more suitable pooling resources or low-carbon fuel options should be secured early for 2026.
Compliance note: FuelEU does not stop at single-ship compliance; it also shapes the commercial arrangements between owners, managers, charterers and fuel suppliers. Companies are advised to set out FuelEU cost sharing, entitlement to pooling benefits, low-carbon fuel arrangements and data provision responsibilities in their contracts at an early stage, rather than leaving the allocation of responsibility until the annual compliance stage.
References
- Puertos del Estado, The EU ETS Observatory confirms the trend of declining connectivity in container traffic at European ports compared with neighboring countries
- Seatrade Maritime, Negative impact of EU ETS seen on port connectivity
- UK Government, UK Emissions Trading Scheme for maritime: how to comply
- DNV, FuelEU Maritime: Regulation insights & support
Disclaimer: This article is compiled from publicly available information for reference and discussion only. It does not constitute legal, financial, investment or trading advice.
About Tecway Maritime
Tecway Maritime Technology Limited was established in 2016 as the Tecway Group team dedicated to green shipping and marine consultancy services. The group's parent company, Tecway International Limited, was founded in 1993 and has served the global maritime industry for more than thirty years.
Tecway Maritime focuses on the core needs of shipping companies in their low-carbon transition, providing UK ETS (UKA), EU ETS (EUA) and FuelEU compliance consultancy, green hydrogen project support for shipping, FGSS technical services, supply and technical support for the Cylinder Liner Diameter Measurement (CLDM) system, and export solutions for Chinese-built marine equipment. Drawing on a global network across Asia, the Middle East and Europe, Tecway Maritime delivers reliable, high-quality and sustainable solutions that help shipping companies respond to regulatory change and capture new opportunities in green shipping.