Climate change mitigation places maritime transport in a critical position, as nearly 90% of global trade is carried by sea. For this reason, the European Union’s inclusion of the maritime sector in the Emissions Trading System (EU ETS) under the “Fit for 55” package marks the beginning of a new era, both environmentally and economically.
For Türkiye, this transformation holds strategic importance, ensuring the continuity of trade with the EU and facilitating integration into international carbon markets.
As is well known, the European Union’s FuelEU Maritime Regulation and the inclusion of maritime transport within the scope of the EU ETS constitute two of the most significant steps taken to reduce greenhouse gas emissions in the shipping sector. FuelEU Maritime aims to lower the carbon intensity of fuels used on board ships and to promote the use of low-carbon, environmentally friendly alternatives. At the same time, the EU seeks to achieve a systematic reduction of emissions in maritime transport and the wider commercial shipping industry through the support of vessels equipped with green technologies and the implementation of market-based mechanisms such as the Emissions Trading System (EU ETS).
EU Emissions Trading System (EU ETS) and Its Application to Maritime Transport
As of January 2024, the EU ETS has been extended to cover all large vessels of 5,000 gross tonnage and above that call at, or depart from, ports within the European Union, irrespective of the flag they sail under. These ships are required to hold carbon allowances corresponding to their verified CO₂ emissions.
The system covers:
- Voyages between EU ports: 100% of emissions.
- Voyages to or from non-EU ports: 50% of emissions. For the remaining share of emissions, the third country has the possibility to determine appropriate measures.
While the system currently covers only CO₂ emissions, methane (CH₄) and nitrous oxide (N₂O) will be included from 2026.
The transition period foresees a gradual increase in allowance surrender obligations:
- 2025: 40% of 2024 emissions,
- 2026: 70% of 2025 emissions,
- 2027 onwards: 100% of annual emissions.
Accordingly, the first reporting covered the emissions generated between 1 January 2024 and 31 December 2024, and the corresponding allowance surrender took place in September 2025.
Ship operators must monitor, report, and verify emissions and surrender the corresponding allowances. Non-compliance may result in financial penalties or access restrictions to EU ports.
The scope of the system covers not only the emissions produced by ships, but also the methodology by which these emissions are attributed to specific voyages and ports. At this point, the concepts of the ‘port of call’ and the ‘neighbouring container transhipment port’ gain particular importance.
Port of Call and Neighbouring Container Transhipment Port
Under the EU ETS, a port of call refers to a port where a ship engages in commercial activities such as loading, unloading, or crew change. Stops made solely for refuelling, maintenance, or technical purposes do not qualify as ports of call.
On the other hand, in order to prevent container vessels from attempting to avoid ETS obligations by making calls at nearby non-EU ports, the EU has introduced the concept of the ‘neighbouring container transhipment port’ into its legislation. For a port to qualify as such:
- It must be located outside the EU but within 300 nautical miles of an EU port.
- More than 65% of its total container traffic must consist of transhipment operations within the most recent 12-month period for which data is available.
Ports meeting these criteria are classified as neighbouring container transhipment ports, and voyages to such ports are not recognised as ports of call under the ETS framework.
For example, if a container vessel sailing from Singapore to Italy calls at Port Said solely for bunkering, Port Said would not be considered a port of call under this regulation. However, if loading or unloading operations take place in Port Said, the port may qualify as a port of call, as such activities constitute commercial operations. Conversely, if Port Said meets the criteria outlined above (such as having a transhipment ratio exceeding 65% and being located within 300 nautical miles of an EU port), it would fall within the definition of a neighbouring container transhipment port and would therefore still not be recognised as a port of call. In such a case, the vessel’s entire voyage between Singapore and Italy would be accounted for under the ETS, and the ship operator would remain responsible for surrendering allowances corresponding to the fuel consumption and carbon emissions generated along this route.
In addition to the financial obligations imposed on the maritime sector by the ETS, the EU has also introduced FuelEU Maritime — a separate regulation that directly targets fuel-related emissions.
FuelEU Maritime Regulation
The FuelEU Maritime regulation, which aims to reduce greenhouse gas emissions, is an EU initiative designed to lower the carbon intensity of marine fuels and promote the use of cleaner, low-carbon energy sources. Although separate from the EU ETS, it is intended to operate as a complementary mechanism by accounting not only for emissions produced during fuel combustion but also for greenhouse gas emissions arising from the extraction, processing and transport of the fuel. In this way, the entire fuel life cycle (“well-to-wake”) is taken into consideration, and emission intensity is assessed on an energy basis (gCO₂e/MJ) rather than solely on the amount of CO₂ released.
The implementation rules mirror those of the EU ETS: the system applies at a rate of 100% to voyages between EU Member States and the European Economic Area (EEA), and at a rate of 50% to voyages to or from non-EU countries. In this way, maritime transport activities outside the EU are also partially brought within the scope of the regulation.
In addition, as of 2030, container and passenger ships over 5,000 GT will be required to use onshore power supply (OPS) when berthed for more than two hours at EU ports. This measure aims to reduce fuel consumption and associated carbon emissions during port stays, as well as to minimise air pollution and noise generated while ships are alongside.
FuelEU Maritime constitutes the second pillar of the EU’s decarbonisation strategy for maritime transport, operating alongside the ETS. However, the two systems differ significantly in terms of scope and operational design.
Key Differences Between FuelEU Maritime and MRV-ETS
FuelEU Maritime aims to limit the carbon emissions arising from the fuels used by ship operators within the maritime sector by imposing a defined greenhouse gas (GHG) energy-intensity limit. Under this system, each vessel is assigned an annual average emissions-intensity target. If a ship’s yearly performance exceeds this target, the operator becomes subject to an administrative penalty. Therefore, it can be said that FuelEU Maritime is a performance-based environmental regulation that imposes sanctions only when the designated emissions-intensity thresholds are exceeded.
By contrast, the MRV-ETS system (Monitoring, Reporting, Verification & Emissions Trading System) requires the monitoring, reporting and verification of all carbon emissions resulting from a ship’s fuel consumption. Under the ETS, carbon allowances must be purchased or surrendered for these emissions, thereby turning each tonne of CO₂ into a financial obligation with a market value. These allowances are acquired or surrendered within the framework of the European Union Emissions Trading System.
Key distinctions:
- FuelEU Maritime: Focuses on reducing the carbon intensity of fuels; penalties apply only when performance targets are exceeded.
- MRV-ETS: Monetises all verified emissions through carbon allowances.
Another difference between the two systems is the (non-)transferability of allowances between vessels. Under the EU ETS, the allowances corresponding to the verified emissions of each individual ship cannot be transferred or redistributed among other ships; each vessel must surrender allowances strictly in line with its own emission levels. In other words, emission allowances under the ETS are defined on a ship-by-ship basis, and there is no possibility of balancing emissions or submitting joint compliance across multiple vessels.
By contrast, FuelEU Maritime allows fleet-level performance assessment and pooling among vessels operated by the same company. Under this system, vessels that perform better than their emission-intensity target may transfer their surplus performance to offset the shortfall of vessels that exceed the target. Such a mechanism exists only under FuelEU Maritime; as noted above, the ETS does not permit any sharing of allowances or joint compliance between ships.
Together, both frameworks serve as complementary tools in the EU’s pursuit of carbon-neutral maritime transport.
Conclusion
The EU ETS and FuelEU Maritime regulations represent a structural transformation that goes beyond reducing carbon emissions in maritime transport; they are reshaping the dynamics of trade, investment and competition. This transition carries strategic significance not only for environmental compliance, but also for economic sustainability and competitiveness in international markets.
Türkiye’s ports occupy a pivotal position in this transition, as they sit at the heart of the trade network closest to the European Union. Aligning port infrastructure and maritime operations with EU regulatory requirements will not only preserve Türkiye’s integration with the EU market but also strengthen its ambition to become a low-carbon hub for regional maritime transport.
In this context, as the Climate Law enters into force and work continues establishing the TR-ETS system, it is crucial for Turkish maritime companies to understand the EU ETS and FuelEU Maritime regulations and to make the necessary preparations in a timely manner. To be adequately prepared for the transition, companies should closely monitor regulatory developments from now on, develop their carbon-management strategies, and take steps towards sustainable operational transformation.