EU ETS Maritime at Full Phase-In: Which Voyage Legs Carry Allowances

Carbon cost on an ocean movement into Europe is not a levy on the carton. It is a duty to surrender emission allowances, resting on one company named in a vessel's compliance paperwork and calculated leg by leg rather than per parcel. The line a seller sees inside a quotation raises legal questions first: who holds the duty, how much of a voyage counts, and what proof arrives with the charge.

Key facts

• The debtor is a shipping company. The duty is written against the company identified by a ship's Document of Compliance; cargo interests and freight intermediaries surrender nothing.
• Legs decide the share. Emissions between two European Union ports, and at berth in them, count at the whole of the reported total. A voyage starting or ending outside the Union counts at 50 per cent.
• The phase-in is a ladder. Operators surrendered 40 per cent of emissions reported for 2024 during 2025, 70 per cent of those reported for 2025 during 2026, and the full share of reported emissions from 2027 onwards.
• Cost travels, duty stays. A surcharge can bill the cargo side for a carrier's allowance expense without making that side answerable to a member state authority.

Who the scheme writes the duty to

Read the obligation as a name on a document. The rules identify a shipping company for each ship, and the on-board marker of that identity is its Document of Compliance. Whoever holds it, operator, technical manager or charterer, reports the ship's emissions for a year and surrenders allowances against them.

A booking confirmation appears nowhere in that chain. An emissions charge on an invoice is a private allocation of a cost that legally sat elsewhere: whoever pays cannot file or correct the reporting position behind it, and the carrier passes no regulatory exposure across the counter.

Which legs count, and by what share

The arithmetic runs on voyage structure rather than distance. Emissions between two member-state ports count completely, as do emissions at berth or waiting in those waters. A voyage beginning or finishing outside the Union counts at 50 per cent, the remainder left for the third country to decide action on.

One rotation can carry two shapes at once. A box transshipped inside a member state adds a leg counted in full; days waiting off a European berth add berth emissions treated the same way. A flat per-container figure for every routing is a rounded average, not a reading of the rule.

The ladder, the reporting year, the deadline

Each step is tied to a reporting year rather than to the calendar in which you book. During 2025 operators surrendered 40 per cent of emissions reported for 2024; during 2026 the figure is 70 per cent of emissions reported for 2025; from 2027 onwards the full share of reported emissions falls due.

The first deadline fell due in September 2025 in all member states, covering emissions reported as taking place from 1 January 2024 to 31 December 2024. A line quoted now is priced against a position the operator settles later, so you cannot verify it and the carrier can revise it.

Gas coverage moved separately. Carbon dioxide was the original scope, while methane and nitrous oxide joined only as from 2026, so two notices issued a year apart can differ for a vessel whose routing never changed.

From a legal duty to one line on a quotation

Between register and invoice sits a commercial choice, made three ways: a named charge revised on a published cycle; the cost folded into an all-in rate with no heading; or an adjustment fixed for one booking. Each is lawful, and none is equally easy to interrogate.

Ask what the figure moves against. A basis tied to leg share, reporting period and named service can be checked against your booking record; a basis tied to market temperature cannot. Ask whether a European transshipment is billed at the intra-Union share: if every routing is billed alike, the figure describes the tariff rather than the rule.

Timing belongs in another box. Our Europe ocean service is published as an approximate 28-38 day port-to-port window that shifts with the booked schedule, and a surcharge basis and a transit window are separate negotiations.

What a cargo-side team can put on paper

We are not a shipping company in the sense the scheme uses: we hold no Document of Compliance and surrender no allowances. An emissions charge on our invoice came from a line first and passes on under its published basis.

Three artefacts we can produce: the port pair and sailing dates as booked, including whether the routing transships inside a member state, since that selects the share; the carrier's own wording for the charge, quoted not paraphrased; and a note when a routing change alters the leg structure mid-contract. The lane matrix sits under DDP sea and air.

Three things we will not do: estimate what a vessel ought to have held, call a carbon line a reimbursable carrying a regulatory document of its own, or sign a clause putting a client into a filing position with a member state authority. The liability terms state who answers for which paperwork.

Three questions that settle it in writing

Does a parcel touching Europe only at its destination port carry the full share?

No. A movement out of Shenzhen to Rotterdam begins outside the Union, so that leg enters at half and the remainder is left for the third country to act on. Berth time at Rotterdam, and any onward hop between two member-state ports, comes in at the whole. Two boxes on one service can therefore sit under different totals inside the same container, because the legs each travelled differ.

Can the line go if I buy free-on-board or nominate my own carrier?

You change whose quotation carries it, not whether the duty exists. On a free-on-board term the buyer's nominated line still holds the Document of Compliance obligation for the vessel it sails, so the charge reappears at the destination end. Nominating another service changes arithmetic rather than scope: a European transshipment adds a leg counted in full, while a direct sailing that never waits at an EU berth keeps only the half-share.

What evidence should I demand before accepting an emissions charge?

Three items, in order. The leg description, meaning the port pair and sailing the figure is stated against, since 50 per cent and the whole of a leg are not interchangeable. The reporting period referenced, because surrender happens against emissions reported for an earlier year. And the revision rule with its validity window, so a re-quoted figure arrives with a stated trigger.

Reviewed 3 November 2026 (2026-11-03). The shares, phase-in steps, gas dates and deadline above are read from the shipping section of the Commission climate site, climate.ec.europa.eu, and should be re-checked there on the day a contract relies on them. Issued under the FulfillDock by SBT brand, which Shenzhen Shibotong International Logistics Co., Ltd. has carried since its 2011 registration and runs from picking floors in Dongguan, Shenzhen and Suzhou. No monetary figure appears above: a carbon line is a basis to interrogate, not a number to copy. Wider questions route through the FAQ page.