EU Maritime Decarbonisation

What is FuelEU Maritime? — EU Regulation 2023/1805 Explained

FuelEU Maritime sets a Well-to-Wake GHG intensity limit on the energy used on board ships calling at EU/EEA ports. This guide explains what FuelEU is, the 2025 baseline and reduction trajectory, pooling, penalties, and how it interacts with the EU ETS and the IMO Net-Zero Framework.

Varuna Sentinels BV — Maritime Compliance Specialists
Last updated: April 22, 2026

Definition: What is FuelEU Maritime?

FuelEU Maritime is Regulation (EU) 2023/1805, in force from 1 January 2025, setting a declining GHG-intensity limit (g CO2-eq/MJ, Well-to-Wake) on the energy used on board ships calling at EU/EEA ports. It complements the EU ETS (which prices CO2 at the ship level) by pricing the carbon intensity of the fuel used, regardless of quantity.

Who is in scope?

The reduction trajectory

Declining GHG intensity versus the 2020 reference (91.16 g CO2-eq/MJ):

Use our FuelEU Balance Calculator to estimate your annual compliance balance.

The compliance balance: surplus, deficit, pooling

Each ship calculates an annual FuelEU compliance balance (surplus or deficit) per voyage and aggregated annually. Deficit ships have three options:

  1. Bank surplus from future years (up to 2 years forward).
  2. Pool compliance with other ships in the same shipping company.
  3. Pay the FuelEU penalty — EUR 2,400 per tonne of very low-sulphur fuel oil energy equivalent above the limit, multiplied by the GHG-intensity gap.

RFNBO and the multiplier

Renewable Fuels of Non-Biological Origin (RFNBOs — e-ammonia, e-methanol, green hydrogen) count toward the GHG-intensity reduction until 2033. From 2034, the multiplier phases out. A sub-target of 2% RFNBO from 2034 applies if the Commission determines uptake is below 1% by 2031.

How FuelEU interacts with EU ETS and the IMO Net-Zero Framework

Monitoring, reporting & verification (MRV)

FuelEU uses the same MRV framework that already underpins EU ETS for shipping (Regulation 2015/757). Shipping companies submit a FuelEU Report via THETIS-MRV annually by 31 March, verified by an accredited verifier. The Document of Compliance must be on board and checked at Port State Control.

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Frequently Asked Questions

When did FuelEU Maritime enter into force?
The regulation entered into force on 12 October 2023 and became applicable on 1 January 2025, with the first compliance year running through 2025 and the first FuelEU Report due by 31 March 2026.
Who is the 'shipping company' responsible for FuelEU compliance?
The same entity that is the ISM Company under the ISM Code, unless otherwise specified in writing to the administering EU member state.
Can I pool ships from different companies?
No, a FuelEU pool is restricted to ships under the same ISM Company. Cross-company pooling is not permitted.
Is FuelEU the same as EU ETS?
No. EU ETS prices Tank-to-Wake CO2 (quantity times intensity). FuelEU prices Well-to-Wake GHG intensity (intensity only). A ship may owe both.
Where does the FuelEU penalty money go?
Revenues from FuelEU penalties accrue to the EU Innovation Fund and are earmarked for maritime decarbonisation projects.

Need a tailored compliance plan?

Book a 30-minute call with our maritime compliance specialists. We will review your fleet’s obligations and map a continuous-compliance workflow using the VS Solutions stack (VSIMS, VSMPS, LCA, ESG Portal, CBT, Live Reporting).

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