To meet the compliance requirements of FuelEU Maritime, vessels differ in their fuel choices and operating conditions. For vessels with a compliance deficit, pooling provides a way to use the compliance surpluses of other vessels to offset that deficit.
So how does pooling work, and what should shipowners consider when participating?
01 What Is Pooling?
Pooling is a flexible compliance mechanism under FuelEU Maritime that allows two or more vessels to place their compliance balances in a single pool and allocate them according to the rules.
In simple terms, it means using the compliance surpluses of some vessels to offset the compliance deficits of others.
When the annual average greenhouse gas intensity of the energy used by a vessel is below the regulatory limit, a compliance surplus can arise; when it is above the limit, a compliance deficit arises. Pooling provides a framework for allocating compliance balances between these vessels.
02 How Can a Compliance Surplus Offset a Deficit?
As a simplified example, suppose two vessels have the following compliance balances in the same reporting year:
Vessel A: surplus of 100 tonnes CO₂e
Vessel B: deficit of 80 tonnes CO₂e
Combined total: surplus of 20 tonnes CO₂e
Together, the two vessels have a surplus of 20 tonnes CO₂e. If the pooling conditions are met and the relevant procedures are completed, part of Vessel A’s surplus can be allocated to Vessel B to offset its deficit.
03 Can Vessels from Different Companies Join the Same Pool?
Yes. Pooling can take place between vessels belonging to the same company, or involve vessels from different companies.
Therefore, even if a shipowner has no vessels of its own that can provide a compliance surplus, it can consider cross-company pooling arrangements to find a way to offset the deficit.
Where different companies are involved, the parties need to agree on arrangements such as balance allocation and the verifier for the pool, and complete the relevant confirmations in the FuelEU database.
04 Why Should Shipowners Understand Pooling?
The conditions for using low-carbon fuels differ from vessel to vessel. Fuel availability, bunkering locations, equipment compatibility and operating arrangements all influence shipowners’ choices.
Pooling provides an additional compliance option for vessels with a compliance deficit, while giving vessels that generate a surplus an opportunity to earn corresponding returns through commercial arrangements.
Shipowners can compare pooling arrangements with alternatives such as using low-carbon fuels themselves, taking costs and implementation conditions into account.
Pooling fees are agreed by the relevant parties through commercial agreements; the regulation does not set a uniform trading price.
05 Joining a Pool Involves More Than Signing an Agreement
Pooling must satisfy regulatory conditions and complete database recording and verification procedures. Several basic requirements include:
- The sum of the compliance balances in the pool must be positive;
- For a vessel that originally had a deficit, the deficit must not increase after allocation;
- For a vessel that originally had a surplus, it must not become a deficit after allocation;
- In the same reporting year, a vessel’s compliance balance for greenhouse gas intensity cannot be included in multiple pools at the same time.
It is important to note that joining a pool does not in itself guarantee that a vessel’s deficit has been fully offset; this depends on the final allocation. The vessel’s existing data monitoring, reporting and verification obligations must also still be fulfilled.
Under the current rules, the selected verifier must record the final pool composition and the allocation of compliance balances to each vessel in the FuelEU database before 30 April of the verification year. Shipowners should therefore allow time to confirm arrangements, coordinate the parties and complete verification.
06 Understanding Pooling Early Helps with Planning
If a vessel is expected to have a FuelEU compliance deficit, the relevant data can first be organised to establish a preliminary balance, before comparing feasible compliance options.
Sources
1. Regulation (EU) 2023/1805 on FuelEU Maritime, Articles 16 and 21 and Annex IV.
2. European Commission official FuelEU Maritime Q&A, Article 21 section.
3. Netherlands Emissions Authority (NEa): practical guidance on FuelEU Maritime for shipping companies.