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What Is FuelEU Maritime? Rules, Targets and Project Impact

10 min read · Aug 10, 2026 · By Alex

FuelEU Maritime is the EU regulation that caps the greenhouse gas intensity of the energy a ship uses. Moreover it lowers that cap on a fixed calendar. The rule is the maritime sibling of ReFuelEU Aviation, and both sit in the EU package that aims to cut net emissions by at least 55 % by 2030. For a developer of green methanol or green ammonia, it turns a fuel specification into a compliance asset. I read the regulation and the Commission guidance, and the figures below reflect the position on 3 November 2026.

In short

In short, the limit starts at 91.16 gCO2eq/MJ and falls by 2 % in 2025, 6 % in 2030 and 80 % in 2050.
Moreover renewable fuels of non-biological origin count twice until 31 December 2033.
In addition, ships can pool balances, bank a surplus or borrow from the next year.
Therefore a ship that misses the limit pays EUR 2,400 per tonne of VLSFO equivalent.
So FuelEU Maritime creates a buyer with a compliance reason, not a contract.

What FuelEU Maritime is

The text is Regulation (EU) 2023/1805 of 13 September 2023 on the use of renewable and low-carbon fuels in maritime transport. It applies from 1 January 2025, except for the monitoring plan rules in Articles 8 and 9, which applied from August 2024.

In practice the method is goal-based and technology-neutral. The text does not name a winning fuel. It names a maximum intensity and lets the market find the cheapest route under it. By contrast with a mandate, which forces a volume, this regulation forces a performance.

As a result a shipowner can comply with LNG, with biodiesel blends, with methanol, with ammonia, with shore power or with wind assistance. Meanwhile the EU emissions trading system for shipping charges for the emissions a ship produces, not for the intensity of the energy it buys. The two bills arrive separately.

The FuelEU Maritime GHG intensity limit and its schedule

Article 4 sets the mechanism. The yearly average intensity of the energy used on board must stay under a limit. That limit is the reference value of 91.16 grams of CO2 equivalent per megajoule, reduced by a fixed percentage each period.

From 1 January	Cut against 91.16 gCO2eq/MJ	Resulting limit
2025	2 %	89.34 gCO2eq/MJ
2030	6 %	85.69 gCO2eq/MJ
2035	14.5 %	77.94 gCO2eq/MJ
2040	31 %	62.90 gCO2eq/MJ
2045	62 %	34.64 gCO2eq/MJ
2050	80 %	18.23 gCO2eq/MJ

In practice the calculation runs well to wake. It covers extraction, production, transport and combustion on board, and it counts methane and nitrous oxide with CO2. Thus a fuel with a clean exhaust and an energy-intensive production route scores worse than its marketing suggests.

In practice the regulation prices the whole chain. That is why certification of the production pathway carries as much weight as the molecule itself.

How compliance is calculated, and why the denominator matters

Under FuelEU Maritime, each ship carries a compliance balance. The balance is the gap between the limit and the actual intensity, multiplied by the energy the ship used. So a positive balance is a surplus. Then a negative balance is a deficit. As a result a large ship with a small gap can carry the same deficit as a small ship with a large gap.

The calendar is tight. First a ship reports to its verifier by 31 January. Then the verifier records the balance in the FuelEU database by 1 May. Finally the company pays any penalty and obtains the FuelEU document of compliance by 30 June. So the first reporting year was 2025, and the first documents fell due on 30 June 2026. Moreover a ship without a valid document risks detention and refusal of port access under Articles 24 and 25.

Today this already shapes fuel demand. The International Energy Agency puts maritime biodiesel demand at 1.6 billion litres, or 0.05 EJ, by 2030. That figure is only 0.7 % of maritime fuel consumption, and the agency links nearly all of it to this regulation. For example it expects blending and credit purchases to dominate before 2030, because LNG, biodiesel and biomethane cost less per tonne of abatement than e-fuels. In other words the first compliance market rewards the cheapest gap, not the greenest molecule.

RFNBO treatment under FuelEU Maritime

Article 5 gives renewable fuels of non-biological origin a multiplier of two for the intensity calculation, from 1 January 2025 to 31 December 2033. In practice one megajoule of e-methanol counts as two megajoules of compliant energy. However the multiplier disappears on 1 January 2034. A fuel contract that assumes it continues is mispriced.

Thus two conditions frame the benefit. First the fuel must meet the RFNBO definition in the renewable energy directive, including the rules on renewable electricity and on the CO2 source. Second the Commission monitors the share of RFNBO in the energy used on board and publishes it at the latest 18 months after each reporting period. So the multiplier is a temporary design feature, not a permanent one.

The 2034 RFNBO sub-target and what it does to an e-methanol case

Article 5 also holds a conditional obligation. If the monitored RFNBO share stays below 1 % for the reporting period 2031, a sub-target of 2 % applies to those fuels from 1 January 2034. The sub-target does not apply if earlier monitoring shows a share above 2 %. The Commission can also suspend it where production capacity is insufficient, distribution is uneven or the price is too high.

In practice for a developer this is a floor with an escape hatch. On one hand, 2 % of maritime energy is a large volume in absolute terms. On the other hand, the waiver conditions are broad, and a ship can meet the sub-target with other fuels that deliver equivalent savings. So I treat the sub-target as upside in a model, never as contracted revenue.

Pooling, banking and the price of a compliance surplus

In addition Article 21 lets two or more ships pool their balances, provided the total pool balance is positive. No ship may end the allocation worse than it started. So a ship can join only one pool per reporting period. In addition the regulation keeps separate pools for the intensity target and for the RFNBO sub-target.

Moreover Article 20 adds banking and borrowing. A company can roll a surplus into the next year, or borrow an advance surplus from the following year up to 2 % beyond the limit. Repayment carries a multiplier of 1.1, and a ship cannot borrow in two consecutive periods.

Overall this design has a commercial consequence that is easy to miss. The Commission guidance states that surplus units cannot pass between ships outside a pool. As a result the value of a green fuel inside a fleet is capped by the cheapest abatement in that same fleet. For example, if a biodiesel blend closes the gap at a lower cost per tonne than e-methanol, the pool clears at the biodiesel price. Then the e-methanol earns a premium only when the pool needs it for the sub-target or for a customer claim.

Penalties: what non-compliance costs

Article 23 sets the FuelEU Maritime penalty for a ship with a compliance deficit, and Annex IV holds the formula. The Annex applies a factor of EUR 2,400 for each equivalent tonne of VLSFO, with one tonne at 41,000 MJ. Thus the penalty tracks the energy gap, not the fuel actually burned.

Then the amount rises with repetition. A company multiplies it by 1 + (n – 1)/10, where n is the number of consecutive periods with a deficit. In effect a repeated shortfall costs 10 % more each year. In addition a separate penalty covers a non-compliant port call for shore power, at EUR 1.5 per kilowatt of established demand per hour at berth. That second penalty is small for a single call and material for a weekly liner service.

Which ships and ports are in scope

FuelEU Maritime covers ships above 5,000 gross tonnage that carry passengers or cargo for commercial purposes, whatever their flag. Today these ships make up 55 % of the fleet and about 90 % of the CO2 emissions of the sector, as the Commission notes. In practice scope covers all energy used at berth in an EU port of call and on voyages between EU ports. In addition it covers one half of the energy on voyages to or from a third country.

Still two details matter for a Southeast Asian owner. First, stops at neighbouring container transhipment ports on the Commission list do not count as port calls, so a carrier cannot shorten an EU voyage on paper. Second, container and passenger ships must use onshore power from 1 January 2030 in ports covered by the alternative fuels infrastructure regulation, and from 1 January 2035 in all EU ports that build capacity. By contrast a ship that trades only inside Asia carries no FuelEU obligation.

FuelEU Maritime and the EU ETS on the same voyage

In practice the trading system and this regulation are separate instruments with separate bills. The ETS prices the CO2 a ship emits on EU-linked voyages. By contrast this regulation limits the intensity of the energy the ship buys. As a result a ship can be fully compliant on intensity and still owe an ETS bill. It can also hold surplus compliance units that cut its ETS liability by nothing.

So two clauses belong in every term sheet for a fuel supplier. One clause allocates the ETS cost. Another allocates the FuelEU penalty and the value of any surplus. In addition the two clauses should stay separate, because they move with different prices and different compliance cycles.

What FuelEU Maritime changes for a fuel producer in Southeast Asia

First the regulation creates a revenue signal, and a bounded one. So a shipowner will pay a premium up to the cost of the cheapest alternative, and never more than the penalty it avoids. Second it changes the contract. A credible supply deal now needs a carbon intensity value with a tolerance, a chain of custody, a pooling clause and a change-in-law clause. Third it changes the lender’s view, because a regulation is demand and not revenue.

For example, a green methanol project in Malaysia or Indonesia that sells to a European liner can show a compliance value per tonne. That value supports a premium. Still the lender asks who signs, for how long, and what happens if the limit tightens faster than the fuel qualifies. So the bankable story is a contract with a shipowner, a pool manager or a trader, with the regulation as support rather than substitute. See Maritime Fuel Bankability, Marine Fuel Offtake and Sustainable Maritime Fuels.

What FuelEU Maritime does not do

In short FuelEU Maritime names no supplier, fixes no price and guarantees no buyer. It mandates no volume of e-fuels before 2034, and even then the sub-target depends on the 2031 monitoring and can be waived. Furthermore it covers only half of the energy on voyages that link the EU to the rest of the world. So that leaves most of an Asian ship’s fuel outside the rule.

Finally the regulation anticipates its own replacement. If the International Maritime Organization adopts a global fuel standard, the Commission must report to the European Parliament and the Council. That report must examine the ambition of the global measure and the case for alignment without duplication. Therefore this limit is the most certain signal available today, and it is not a permanent one. See IMO Net-Zero Framework for the global track.

Sources

Sources

Regulation (EU) 2023/1805 of 13 September 2023 on the use of renewable and low-carbon fuels in maritime transport, Official Journal L 234, 22.9.2023, pages 48 to 100 (Articles 2, 4, 5, 6, 20, 21, 23 and Annex IV).
European Commission, Decarbonising maritime transport: FuelEU Maritime (application dates, targets, shore power, Norway and Iceland note dated 18 December 2025).
European Commission, Questions and answers on Regulation (EU) 2023/1805 (RFNBO sub-target, pooling and penalty procedure).
International Energy Agency, Renewables 2025, chapter on renewable transport fuels (maritime biodiesel demand and the IMO framework assumptions).
DNV, FuelEU Maritime FAQ (penalty factor of EUR 2,400 per tonne of VLSFO equivalent and pooling mechanics).

FAQ

What is FuelEU Maritime?

FuelEU Maritime is an EU regulation that caps the GHG intensity of the energy used on board ships above 5,000 gross tonnage calling at EU ports, and it tightens the cap from 2025 to 2050.

Is it the same as the EU ETS for shipping?

No. The ETS prices the CO2 a ship emits on EU-linked voyages, while FuelEU Maritime limits the intensity of the energy it buys.

Does it favour green methanol or ammonia?

It favours any fuel with a low well-to-wake intensity, and it counts RFNBOs twice until 31 December 2033, which helps e-methanol and e-ammonia most.

Does the RFNBO multiplier last?

No. It expires on 31 December 2033, and from 2034 a conditional 2 % sub-target may apply instead.

Does it apply to ships outside Europe?

Only to ships above 5,000 gross tonnage on voyages to, from or between EU ports, and then to half of the energy on voyages that connect the EU to a third country.