Directly applicable across the EU with no transposition required, FuelEU sets a well-to-wake greenhouse gas intensity limit on the energy used by ships calling at European ports. It is the one European fuel instrument with a genuine compliance unit — though it can only be moved between ships by pooling.
Applies to 100% of energy used on intra-EEA voyages and at berth, and 50% of energy used on voyages into or out of the EEA, regardless of the ship's flag.
FuelEU requires ships calling at EEA ports to cut the greenhouse gas intensity of the energy they use, measured well-to-wake and tightening at set intervals to 2050. The regulation does not name which fuel to burn — compliance can come from cleaner fuel, onshore power at berth, or pooling with better-performing ships — but the obligation itself is a binding carbon intensity reduction on the fuel a ship consumes.
A ship's compliance balance is expressed in grams of CO₂e. There is no central credit registry: surplus moves between ships only through pooling, and the other two flexibilities operate within a single ship's own account.
Six features that determine how FuelEU compliance is actually managed — including the one most often misquoted.
As a regulation rather than a directive, FuelEU applies directly and identically across the EU. This is the opposite of RED III, and it is why FuelEU has a single compliance architecture where road fuels have twenty-seven.
The intensity limit covers the full fuel pathway including upstream production, not just what is burned on board. A fuel that looks clean at the stack can perform very differently on a well-to-wake basis.
There is no central registry of tradable credits. Surplus moves between ships only by forming a verified pool, which makes counterparty identification part of the compliance process rather than a market transaction.
The penalty formula is expressed against a fuel-energy equivalent of the deficit, not directly per tonne of CO₂e. Converting it into a headline carbon price materially overstates it — a common error in secondary commentary.
Alongside the intensity limit, obligations on the use of onshore power at berth phase in at major ports, with their own separate non-compliance charge.
All energy on intra-EEA voyages and at berth counts, and half of the energy on voyages into or out of the EEA. Trade pattern therefore affects exposure as much as fuel choice does.
Where you stand under Canada Clean Fuel Regulations (CFR), what it costs, and which levers reduce the bill — mapped by the team.
Six ways we support shipping companies and fuel suppliers under FuelEU.
Modelling a fleet's balance across ships and periods, including how voyage patterns change the counted energy.
Structuring pools across a fleet or with counterparties, and the verification the database requires.
When carrying surplus forward beats pooling it, and when borrowing is worth its surcharge rather than a deficit.
Well-to-wake intensity assessment for alternative marine fuels, and what actually moves a balance rather than a headline emissions figure.
Monitoring plans, reporting and the verification cycle, aligned with EU ETS maritime obligations where both apply.
Implementing acts, the review clause and the RFNBO trigger, tracked for their effect on a specific fleet.
Published analysis from Climate Decode on European fuel obligations and the wider clean fuel markets.
The directive covering road, rail and aviation fuels — and why it has no EU-wide credit.
The allowance market that maritime operators also face, alongside the FuelEU intensity limit.
Seven programmes pricing the same barrel, each with its own unit, trajectory and clearing price.
Reduction percentages are measured against the reference greenhouse gas intensity set in the regulation. Pooling prices are bilateral and not published by any regulator, so any figure circulating for a pooled tonne comes from a commercial index and should be treated accordingly.
It requires a reduction in the greenhouse gas intensity of the energy a ship uses, which in practice is a carbon intensity requirement on the fuel it burns. The regulation does not name a specific fuel: a company can meet the limit through cleaner fuel, onshore power at berth, or by pooling with better-performing ships. The reduction itself is mandatory.
The company operating the ship, which may be the shipowner or the entity that has assumed responsibility for ship operation. It applies to ships above 5,000 gross tonnage calling at EEA ports, regardless of flag.
All energy used on voyages between EEA ports and at berth in EEA ports, and half the energy used on voyages into or out of the EEA. A fleet's exposure therefore depends on trade pattern as much as on fuel choice.
Not in the usual sense. There is no central registry of tradable credits. A surplus moves between ships only through a verified pool, and pool prices are bilaterally negotiated — the regulation sets no price and no regulator publishes one.
The penalty formula is expressed against a fuel-energy equivalent of the compliance deficit rather than directly per tonne of CO2e. Converting the headline figure into a carbon price materially overstates the implied cost, which is a frequent error in secondary commentary. The calculation should be run on the specific deficit.
They are separate obligations that can apply to the same voyage. The EU ETS requires surrender of allowances against emissions; FuelEU sets an intensity limit on the energy used. Meeting one does not discharge the other, and both need to be modelled together for a realistic view of cost.
See how Climate Decode delivers end-to-end CFR support — from eligibility assessment and CI modelling through credit commercialisation and stackability analysis.