FuelEU Maritime: the first year

FuelEU Maritime caps the greenhouse gas intensity of the energy a ship uses on voyages to, from and between EU and EEA ports, counted from well to wake. 2025 was the first reporting period; its reports, verification, pooling and penalties ran in 2026. This guide goes through those steps and what they mean for 2026 data.

Rules as checked on 2026-10-19. Each rule names its article.

Which ships and which energy

The GHG intensity limit

The limit is a reference value of 91.16 gCO₂e/MJ lowered in steps. Each step applies from 1 January of its year until the next one. Art. 4(2)

FromReductionLimit, gCO₂e/MJ
20252%89.34
20306%85.69
203514.5%77.94
204031%62.90
204562%34.64
205080%18.23

The intensity is well to wake: the emissions of producing and delivering the fuel plus those of burning it, with default values per fossil fuel in Annex II. Biofuels, RFNBO and other fuels get their lower values only when certified; otherwise they count as the least favourable fossil pathway. Methane and nitrous oxide count with global warming potentials of 25 and 298, not the 28 and 265 of the EU ETS. Renewable fuels of non-biological origin (RFNBO) count 2 times in the energy until 2033. Art. 4(1), Art. 5(1), Art. 10, Annex I (Equation (1), RWD), Annex II; Directive (EU) 2018/2001 Annex V

Compliance balance and penalty

Example: a typical container ship in 2025

The same ship as in the EU ETS guide and the calculators' preset: the median container ship in the EU MRV data (EU MRV public data 2025 (THETIS-MRV, version 62, full-year reports)), 930 t of HFO between EU/EEA ports, 4,160 t to or from them, 170 t of MDO/MGO at berth. Annex II default factors, fossil fuels only.

Fuel in scope3,010 t HFO + 170 t MDO/MGO
Energy in scope129.2 TJ
Ship's GHG intensity91.69 gCO₂e/MJ
Limit for 202589.34 gCO₂e/MJ
Compliance balance−303.9 t CO₂e
Penalty, first deficit€193,991
Penalty, second deficit in a row€213,390

With the default factors, HFO (91.74 gCO₂e/MJ) and MDO/MGO (90.77) are both above even the first limit, so a ship running on them alone has a deficit: it needs other fuels, a pool or borrowing, or it pays the penalty. The limit stays at 89.34 gCO₂e/MJ until 2029, so the same fuel gives the same deficit each year until then. Try your own fuel mix in the FuelEU calculator, which can also add the EU ETS cost of the same fuel.

Banking, borrowing and pooling

The Regulation sets no price for surplus moved between ships in a pool. The FuelEU calculator lets you enter a price you have been quoted to compare pooling with the penalty.

Deadlines

For 2025 data, the first period, these steps ran from 31 January 2026 to 30 June 2026. For 2026 data the same steps fall in 2027:

EU MRV, EU ETS and IMO dates are in the shipping compliance calendar.

What comes next

Proposed changes (not law)

On 17 July 2026 the Commission proposed amending the MRV and FuelEU Regulations (COM(2026) 620): one monitoring plan and one report per ship for EU MRV / EU ETS and FuelEU, and EU MRV extended to oil tankers, chemical tankers, gas carriers, LNG carriers, ro-pax ships and passenger ships from 400 GT up to 5,000 GT. It is a proposal: the calculator and this page follow the rules in force. On 2026-10-19 it was awaiting a vote in the European Parliament’s environment committee (ENVI) (2026/0210(COD)). The EU ETS changes proposed at the same time are in the EU ETS guide.

Related