Two charges, not one: the EU ETS surcharge and the FuelEU surcharge
An ocean booking that touches an EU port can arrive with two emissions-related surcharges on the invoice: an "ETS surcharge" and a "FuelEU surcharge". They look similar and land on the same bill, but they come from two separate EU instruments and they charge for two different things. Reading them as one "emissions surcharge" is the mistake to avoid, because they move independently and for different reasons.
The first is the EU Emissions Trading System (EU ETS), which since January 2024 has been extended to cover carbon dioxide emissions from large ships calling at EU ports (European Commission). The second is FuelEU Maritime, Regulation (EU) 2023/1805, which has applied from 1 January 2025 (EUR-Lex). One puts a price on the ship's emissions; the other sets a limit on how emissions-intensive the ship's energy is allowed to be.
Neither is a forwarder filing. Under the EU ETS the shipping company always remains the responsible entity for surrendering allowances (European Commission), and under FuelEU Maritime the responsible party is the ISM Company, the entity responsible for the ship under the International Safety Management Code, in practice the shipowner or operator (European Commission). The forwarder and the shipper file nothing under either instrument; they meet the cost only as a carrier pass-through line on the invoice, which is why it appears as a surcharge rather than as something to submit.
Carriers do not always split the two. A carrier invoice often carries a single bundled "emissions surcharge" line that can include EU ETS cost, FuelEU cost, or both, so a bundled line must never be attributed to one instrument alone. When the split matters for a dispute or a customer query, ask the carrier for the breakdown. The sections below take each charge in turn, then explain why the amounts move.
EU ETS surcharge vs FuelEU surcharge at a glance
Here are the two instruments side by side, with their European Commission and EUR-Lex sources stated in full in the sections that follow. The cells carry no amounts, because neither charge is a fixed rate. Ships are measured in gross tonnage (GT), and each instrument states its scope threshold in its own wording, so the two are shown exactly as each regulation writes them rather than merged.
| What it is | EU instrument | What it charges | Who owes it | Ships in scope | Applies from |
|---|---|---|---|---|---|
| A carbon market extended to shipping | EU ETS (maritime extension) | The market price of the allowances the carrier must buy and surrender for its in-scope emissions | The shipping company | Ships of 5,000 GT and above calling at EU ports, regardless of flag (EC) | January 2024 (EC) |
| A limit on the greenhouse-gas intensity of on-board energy | FuelEU Maritime, Regulation (EU) 2023/1805 | The cost of meeting a tightening intensity target; a separate penalty backs a compliance deficit | The ISM Company (shipowner or operator) | Ships above 5,000 GT calling at EU ports, irrespective of flag (EC) | 1 January 2025 (EUR-Lex) |
The EU ETS surcharge: the carrier buys allowances for its emissions
Since January 2024, the EU Emissions Trading System has been extended to cover carbon dioxide emissions from all large ships of 5,000 GT and above entering EU ports, regardless of the flag they fly (European Commission). From 2026 the system also covers methane and nitrous oxide emissions, having covered carbon dioxide alone before that (European Commission), so the emissions base the charge is calculated on widens at the 2025-to-2026 boundary.
The charge itself is an allowance cost. Shipping companies have to purchase and surrender EU allowances for each tonne of reported carbon dioxide, or carbon dioxide equivalent, emissions in the scope of the system (European Commission). The European Commission calls this tradable unit EU allowances (EUA); companies buy and sell them through a trading account in the Union Registry, so the price is set by that market rather than fixed by the regulation. This is why no page can quote a stable per-container ETS figure: the underlying allowance price trades continuously, in the way a bunker adjustment factor tracks a moving fuel price.
How much of a voyage's emissions the charge covers depends on the route. The system covers 100% of emissions on voyages between two EU ports and while ships are within EU ports, and 50% of emissions on voyages that start or end outside the EU (European Commission). A Shanghai to Rotterdam import, for example, is charged on 50% of its voyage emissions, while a Rotterdam to Hamburg leg is charged on 100%.
The share of covered emissions a carrier must actually surrender allowances for is still ramping up. Shipping companies surrender allowances for 40% of their emissions reported in 2024, 70% of their emissions reported in 2025, and 100% of their reported emissions from 2026 onward (European Commission). The percentage attaches to the emissions of a reporting year, and the allowances fall due the following year, so the ETS component of a surcharge rises year over year from this phase-in alone, before any change in the allowance price.
The FuelEU surcharge: the cost of meeting a tightening intensity target
Where the EU ETS prices emissions, FuelEU Maritime limits how emissions-intensive a ship's energy may be. It sets targets for reducing the yearly average greenhouse-gas (GHG) intensity of the energy used on board ships, calculated on a life-cycle "well-to-wake" basis that covers both producing the fuel and burning it (European Commission). Regulation (EU) 2023/1805 has applied since 1 January 2025, with the monitoring-plan articles applying from 31 August 2024 (EUR-Lex).
The target tightens on a fixed schedule. The regulation takes a reference value of 91.16 grams of carbon dioxide equivalent per megajoule and reduces it by 2% from 1 January 2025, 6% from 2030, 14.5% from 2035, 31% from 2040, 62% from 2045, and 80% from 2050 (EUR-Lex, Article 4). Because the required intensity falls in five-year steps, the compliance cost embedded in a FuelEU surcharge steps up over the life of the regulation.
FuelEU applies to commercial ships above 5,000 GT that carry passengers or cargo and call at EU ports, irrespective of flag (European Commission). Its threshold is written as "above 5,000 GT", which is worded differently from the EU ETS "of 5,000 GT and above"; the two instruments use their own wording, and this page states each as its regulation does. The regulation is marked as having European Economic Area (EEA) relevance, but the extension to Iceland, Liechtenstein, and Norway takes effect only following incorporation into the EEA Agreement, which as of July 2026 is still pending and not yet in force (European Commission; Norwegian Maritime Authority). So the operative scope today is EU ports.
The responsible party is the ISM Company, the entity responsible for the ship's compliance with the International Safety Management Code, in practice the shipowner or the operator (European Commission). As with the EU ETS, the forwarder files nothing.
FuelEU also carries a penalty, and it is important not to read that penalty as the surcharge. For a ship that finishes a reporting period with a GHG-intensity compliance deficit, the FuelEU penalty is set in the regulation at EUR 2,400 per equivalent metric tonne of very low sulphur fuel oil (VLSFO), with one tonne of VLSFO treated as equivalent to 41,000 megajoules (EUR-Lex, Article 23 and Annex IV). That figure is the penalty a non-compliant ship pays when it misses the target, not the amount of a carrier surcharge, and no carrier passes through a flat EUR 2,400 per tonne. It matters here only because it is one reason carriers price FuelEU compliance into a surcharge at all: staying compliant is cheaper than the penalty.
Why the amounts move (and why we do not publish a per-carrier table)
Both surcharges move, and none of the reasons is a fixed number. On the EU ETS side, the cost is the market price of the EU allowances the carrier buys and surrenders, which trades continuously (European Commission), so it changes with the carbon market. The share of emissions the carrier must cover is also ramping up, from 40% of 2024 emissions to 70% of 2025 and 100% from 2026 (European Commission). The emissions base itself widens when methane and nitrous oxide join carbon dioxide in scope from 2026 (European Commission). And the amount charged on any one booking depends on whether the voyage stays inside the EU, at 100%, or reaches outside it, at 50% (European Commission).
On the FuelEU side, the intensity target tightens in five-year steps, from a 2% reduction in 2025 toward 80% by 2050 (EUR-Lex), so the compliance cost priced into the surcharge steps up over time. The FuelEU line can also move within a single year. The regulation lets a company manage a ship's compliance balance rather than only pay the penalty: banking and borrowing compliance surplus between reporting periods, and pooling surplus across two or more ships (European Commission). Because a carrier's FuelEU cost depends on its own fuel mix and which of these routes it takes, the FuelEU component can be repriced mid-year, separately from the regulation's fixed five-year target steps.
Put together, the allowance price trades continuously, carrier tariffs change at the turn of the year, and the FuelEU line can shift mid-year with the carrier's compliance position. A fixed per-carrier surcharge table would be stale the quarter it published, which is why this page explains the mechanism instead of listing amounts. For the current figure on a given lane, read the carrier's own live surcharge tariff. A booking whose deadlines straddle the year boundary is the acute case, because the phase-in percentage and the FuelEU target step both move at 1 January; see container shipping cut-offs for how those deadlines fall.
Neither the EU ETS nor FuelEU Maritime is a forwarder filing. The EU ETS obligation to surrender allowances is the shipping company's, and the FuelEU obligation is the ISM Company's, the shipowner or operator. The forwarder's job is quoting and margin protection: carry both surcharge lines at their current value, keep them right across the year boundary when the phase-in and the target step, and reconcile them against the carrier's invoice, so a stale or omitted line does not come out of the margin.
Where Expedion fits (quoting and margin protection)
These two surcharges turn into desk work at quote and invoice time, and the work is quoting and margin protection rather than filing: the EU ETS and FuelEU lines must be quoted at the value in force for the sailing, carried across the year boundary as the phase-in and the target step, and reconciled against the carrier's invoice, or a line that is stale or missing comes out of the margin. Expedion is a managed AI workforce for freight forwarding operations, and its agents work the booking and documentation desks on your existing carriers and your own TMS, the desks where quotes are assembled and carrier charges are reconciled. It does not file or calculate either charge, and it holds no EU ETS or FuelEU obligation, which stays with the shipping company and the ISM Company. This capability is in supervised production with design partners, not general availability.
Because the EU ETS and FuelEU components move with the allowance price, the phase-in, and the target step, a quote built on last quarter's numbers understates the cost. Each line is quoted at the value in force for the sailing, not a remembered rate.
At the January turn the phase-in percentage and the FuelEU target step both move, so a booking that straddles the boundary needs the stepped value rather than the prior year's, on the quote and again on the invoice.
The pass-through is the carrier's own charge, so each line is checked against the carrier's live surcharge tariff and the invoice rather than assumed, which is where a bundled or mislabelled line gets caught.
Frequently asked questions
Is the EU ETS surcharge the same as the FuelEU surcharge?
No. They come from two separate EU instruments. The EU ETS surcharge passes through the cost of the emission allowances a shipping company must buy and surrender for a ship's carbon dioxide emissions, extended to shipping since January 2024. The FuelEU surcharge passes through the cost of meeting FuelEU Maritime's limit on the greenhouse-gas intensity of a ship's energy, which has applied since 1 January 2025. They are priced differently and move for different reasons, so a change in one does not track the other.
My invoice shows a single emissions surcharge line. Which instrument is it?
It can be either or both. A single bundled emissions surcharge line can carry EU ETS cost, FuelEU cost, or a combination, so a bundled line must never be attributed to one instrument alone. If the split matters, for a dispute or a customer query, ask the carrier for the breakdown between the EU ETS and FuelEU components.
Do I, the forwarder, have to file anything under the EU ETS or FuelEU?
No. Under the EU ETS the shipping company is the responsible entity for surrendering allowances, and under FuelEU Maritime the responsible party is the ISM Company, the shipowner or operator responsible for the ship under the International Safety Management Code. The forwarder and the shipper file nothing under either instrument and meet the cost only as a carrier pass-through surcharge.
Why does the surcharge amount change?
For the EU ETS line, the main drivers are the market price of the EU allowances the carrier buys, which trades continuously, and the phase-in that raises the share of emissions covered from 40% of 2024 emissions to 70% of 2025 and 100% from 2026 (European Commission). For the FuelEU line, the intensity target tightens in five-year steps, from a 2% reduction in 2025 toward 80% by 2050 (EUR-Lex), and a carrier's own fuel mix and compliance route can move the line within a year. Because these move continuously, no fixed per-carrier table stays current, so check the carrier's live tariff for the amount on a given lane.
What ships are in scope?
The EU ETS covers large ships of 5,000 gross tonnage and above calling at EU ports, regardless of flag (European Commission). FuelEU Maritime applies to ships above 5,000 gross tonnage carrying passengers or cargo and calling at EU ports, irrespective of flag (European Commission). Those are the two instruments' own wordings, stated as each regulation writes them. FuelEU is marked as having European Economic Area relevance, but its extension to Iceland, Liechtenstein, and Norway takes effect only after incorporation into the EEA Agreement, which as of July 2026 is still pending, so the operative scope today is EU ports.
Does Expedion calculate or file my emissions surcharges?
No. Neither charge is a forwarder filing: the EU ETS obligation is the shipping company's and the FuelEU obligation is the ISM Company's, so nothing is filed or calculated on the forwarder's side under either instrument. What the surcharges create is quoting and reconciliation work, keeping the two lines quoted current and checked against the carrier's invoice. Expedion works the booking and documentation desks where that quoting and reconciliation happens, and it is offered to design partners today rather than being generally available.