The FuelEU Maritime regulation, which came into force on January 1, 2025, is a cornerstone of the European Union’s “Fit for 55” package, aiming to reduce greenhouse gas (GHG) emissions from shipping drastically. As companies grapple with compliance, questions surrounding reporting, fuel allocation, exemptions, and certification have indeed become common.
Key Guidelines for FuelEU Maritime Implementation
- Report on calculation methodologies under Regulation (EU) 2023/1805 (FuelEU): This report provides essential guidance and best practices for understanding and implementing the calculation methodologies outlined in FuelEU Maritime. It offers critical information for calculating actual vessel performance, with a particular focus on the principles of fuel allocation. The content aligns with insights from DNV, which actively contributed to the report’s development. Beyond calculations, the guideline also covers technical requirements, including the use of renewable and low-carbon fuels, specific voyage exemptions, and compliance flexibility mechanisms such as banking, borrowing, and pooling. Further guidance from the European Commission is anticipated in the second half of 2025.
- Report on Marine Fuels Certification Procedures to support implementation of FuelEU Maritime: This second guideline is highly relevant for both FuelEU Maritime and the EU ETS, specifically addressing fuel sustainability certification. It introduces a template for Proof of Compliance (PoC), which can be used as an alternative to a Proof of Sustainability (PoS) when the supplier also uses the fuel for compliance with the Renewable Energy Directive. The report strongly recommends using this PoC template to ensure fuel eligibility under both FuelEU and EU ETS if a PoS is unavailable. Additionally, it outlines comprehensive procedures for certifying renewable and low-carbon marine fuels in accordance with both regulations, providing practical instructions for fuel suppliers and shipping companies on required documentation, sustainability certification, and traceability.
Certification of Actual Methane Slip Values
A current challenge highlighted in the report is that FuelEU and EU ETS regulations only permit the use of default methane slip values by engine type, as international standards for actual measurement are not yet available. While IMO guidelines for measuring methane slip from LNG engines were adopted at MEPC 83 in April 2025, they lack crucial details regarding:
- Procedures for on-board monitoring of emissions (e.g., performance of after-treatment systems).
- Methods to ensure the stability of values over time, especially after engine modifications.
- Standardized test cycles for consistent measurement.
In response, the European Commission is actively working on interim guidelines to enable the certification of actual methane slip values based on the IMO protocol, with these guidelines also expected in the second half of 2025.
FuelEU Report Submission in Thetis
The FuelEU database, integrated into the Thetis platform, has been updated as of June 18, 2025, to support FuelEU Maritime partial reports. This is particularly important when there is a change in company (e.g., due to a vessel sale), requiring a verified FuelEU report to be recorded in the database within one month of the change. DNV’s “FuelEU Maritime service under Fleet Status on Veracity” has been adjusted to process these partial reports, allowing companies to request verification through their customer portal.
A webinar hosted by EMSA and DG MOVE on June 24, 2025, provided a high-level overview of the FuelEU report and compliance balance modules in Thetis, with a recording available for further insights.
Clarifications on Implementation and Flexibility
The report offers important clarifications on the use of FuelEU’s flexibility mechanisms:
- Pooling: While pooling allows for sharing compliance surpluses between vessels, it does not always result in a zero compliance balance for a ship. A surplus after pooling can be banked for future use, but a deficit will trigger a penalty.
- Borrowing: Borrowing (drawing on future compliance surpluses) and pooling come with limitations; notably, borrowing is not permitted after pooling has been applied.
Delay in EEA Agreement Incorporation
Currently, Norway and Iceland are excluded from the FuelEU Maritime regulation because it has not yet been incorporated into the EEA Agreement. Consequently, ports in Norway and Iceland are treated as third-country ports for FuelEU purposes. Once incorporated, FuelEU will apply to 100% of energy used on voyages between EU and EEA ports, but retroactive application is not expected. The EEA Joint Committee has meetings scheduled throughout 2025, but an official date for incorporation remains unconfirmed.
FuelEU Regulation Exemptions
It is crucial to understand that FuelEU exemptions differ from those of the EU ETS. Key exemption principles and specific lists published by individual member states must be consulted for proper compliance.
- Outermost Regions (OMRs) Exemptions: For voyages starting or ending in an Outermost Region (like the Azores or Canary Islands), only 50% of the energy used is included in the regulation’s scope (Article 2(1)(c)). France, Portugal, and Spain have requested temporary exemptions (until December 31, 2029) for specific ports and routes within nine OMRs. These apply to energy used on voyages between ports of call within OMRs and within those ports. Any OMR port on these exemption lists is fully exempt from FuelEU’s energy scope, unlike the EU ETS which only exempts ports in relation to an exempted voyage.
Recommendations for Compliance
The ESSF provides several key recommendations for shipping companies:
- Ensure Alignment on Internal Processes and Contracts: Verify that in-house or outsourced calculations accurately reflect FuelEU principles and that these principles are also embedded in commercial contracts.
- Monitor Regulatory Developments: Stay updated on methane slip certification guidelines, the incorporation of FuelEU into the EEA Agreement for Norway and Iceland, and any new resources or guidance from the European Commission.
- Ensure Accurate and Timely Reporting: Follow up on FuelEU partial report verification when there’s a change of company. When bunkering alternative fuels, ensure eligibility criteria are met by obtaining a Proof of Sustainability (PoS) or Proof of Compliance (PoC) from the fuel supplier. Finally, ensure that all applicable exemptions are correctly incorporated into performance monitoring and reporting systems.
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Source: DNV
