FuelEU Maritime requires suppliers to supplement Bunker Delivery Notes with information on GHG intensity and the lower calorific value of the biofuel. For RFNBOs, suppliers are required to provide well-to-tank GHG emission factors and related certificate indentifying the fuel procustion pathway. In case of fuel blends, parameters should be given separately for each component.

For recognition in the EU ETS and FuelEU Maritime schemes, suppliers should follow the approved certification schemes.

In case of fuel blends, companies should request suppliers to provide parameters separately for each component and make the information available to the verifier. Data such as low calorific values or well-to-wake intensity is not required for fossil fuels. For more information related to reporting requirements, please refer to the Veracity resource page.

In case of a change of responsible company, any compliance balance surplus (banking) or deficit (borrowing) follows the ship. Therefore, the shipping companies should execise due dilligence and agree on a compensation.

Carbon Capture and Storage is not a recognized technology under FuelEU Maritime as of now. The European Commission will consider inclusion of this technology in the next revision of the regulation, scheduled for 2027.

For ships having ice classes IA, IA Super or equivalent (including PC1–PC7 polar classes), additional energy consumption due to the technical characteristics of ship can be excluded from the FuelEU Maritime scope and calculations of FuelEU compliance balance. For ships having ice classes IC, IB, IA or IA Super or equivalent (including PC1–PC7 polar classes), additional energy consumption due to sailing in ice conditions can be excluded from the FuelEU Maritime scope and calculations of compliance balance. Additional energy consumption is allocated to different fuel types to calculate the adjusted mass of fuel consumption. Voyages within ice edge need to be marked in OVD reporting. For more information related to reporting requirements, please refer to the Veracity resource page.

DNV will enable the option to submit a Monitoring Plan for assessment when details of the FuelEU Monitoring Plan template are formally confirmed. Significant changes are not expected, and companies are encouraged to start preparing a draft of the FuelEU Monitoring Plan already now using DNV’s online form. The online form is in line with the the most current FuelEU Monitoring Plan template.

The FuelEU Monitoring Plan handling process will be very similar to the MRV Monitoring Plan process. Ultimately, assessed FuelEU Monitoring Plans need to be registered on the Thetis portal by the end of 2024.

An assessed FuelEU Monitoring Plan should be registered in the Thetis portal by the end of 2024. The deadline of 31 August 2024 applies to the submission of the Monitoring Plan on the DNV portal.

The deadline for submitting the FuelEU Monitoring Plan to the verifier is 31 August 2024. By submitting a FuelEU Monitoring Plan on the DNV portal, our customers are fulfilling their obligations under Article 8 of the FuelEU Maritime regulation.

When implementing the regulation, the verification activities explicitly require companies to provide the verifier with an outline of the control system, complemented by additional data pursuant to the FuelEU Maritime regulation.

Many sections of the FuelEU Monitoring Plan are common with the EU MRV Monitoring Plan. Companies are requested to re-use MRV Monitoring Plan data to ensure consistency in monitoring and reporting. Additional sections are mainly related to onshore power supply equipment, zero-emission technology and well-to-wake emission monitoring.

DNV’s FuelEU Monitoring Plan online form strictly follows the FuelEU plan template and is synchronized with the approved MRV Monitoring Plan. All steps of plan preperation are explained in an intuitive way, with a natural workflow between plan sections and extensive information in each table. Copying functionality allows companies to prepare a master plan that can be re-used across their fleet or fleet groups. Automatic validation rules help to navigate through complex regulatory requirements, indicating missing information or wrong input before the plan is sent for assessment.

The following is required by Article 6 of the FuelEU Maritime regulation:

• From 1 January 2030, container and passenger ships must connect to shore power while at berth in all Trans-European Network (TEN-T) ports.
• From 1 January 2035, container and passenger ships must connect to shore power in all EU member state ports where shore power is available (exceptions: emergency, lack of compatibility and availabilty, port stay shorter than two hours, when zero-emission technology is used, unscheduled port stay, risk of electrical grid stability, and on-board tests).

This zero emission requirement for energy used at berth is considered fulfilled when a zero-emission technology (ZET) is used for all of the ship’s electrical power demand while moored at the quayside. However, the ship does not have to meet the zero-emission requirement for energy used at berth in the following cases:

• Port stays shorter than two hours
• Unscheduled port calls related to safety or saving life at sea
• Unavailability of OPS connection points in a port
• Risk to electrical grid stability due to insufficiently available shore power
• Incompatibility with onshore power equipment, provided that the ship’s installation is certified in accordance with the technical specifications set out in Annex II of Regulation (EU) 2023/1804
• Force majeure scenarios such as emergency situations representing immediate risk to life, the ship or the environment
• When maintenance tests or functional tests, carried out for a limited period for survey or inspection purposes, require the use of on-board energy generation

A pool may include vessels verified by different verifiers, but pool composition is approved only by one verifier.

Based on verified ship data in the FuelEU database, a company will group vessels together and notify the verifier of their intention to pool the group of vessels. Where a pool is organized across different companies, consent is needed from every company involved.

The pooling intention will be rejected by the verifier if the applicable rules are not fulfilled. Each ISM company is responsible for paying the penalty, can apply other mechanisms (for instance borrowing from the next reporting period). One may also decide to create a different pool which fulfils the applicable requirements and then pay a penalty for vessels excluded from the pool.

Pooling does not guarantee that individual ships do not pay a penalty – one can assign the compliance balance to each ship in different ways, ending up with deficits on some vessels and surpluses on others. Allocation of compliance is decided by pool members and needs to follow three basic rules (see other questions in the Pooling category).

The vessel will likely face a deficit the year after advance compliance surplus is borrowed, which can be compensated by pooling with other ships.

Surplus is assigned to an individual ship (surplus may come as an outcome of pooling). The surplus can be shared next year within a different pool.

Basic rules governing FuelEU Maritime vessel pooling are:

• The total pool compliance balance must be positive
• Ships with a deficit before pooling do not have a higher deficit after pooling
• Ships with a surplus before pooling do not have deficit after pooling

Based on verified ship data in the FuelEU database, a company will group vessels together and notify the verifier of their intention to pool the group of vessels. Where a pool is organized across different companies, consent is needed from every company involved.

The pooling intention will be rejected by the verifier if the applicable rules are not fulfilled. Each ISM company is responsible for paying the penalty, can apply other mechanisms (for instance borrowing from the next reporting period). One may also decide to create a different pool which fulfils the applicable requirements and then pay a penalty for vessels excluded from the pool. Please see other question in this category for details on pooling rules.

Pooling does not guarantee that individual ships do not pay a penalty – one can assign the compliance balance to each ship in different ways, ending up with deficits on some vessels and surpluses on others. Allocation of compliance is decided by pool members and needs to follow three basic rules (see other questions in the Pooling category).

In case the vessel has a compliance deficit the year after advance compliance surplus is borrowed, this can be compensated by pooling with other ships.

Surplus units are assigned to individual ships based on the actual GHG intensity of energy used on-board and as a result of reallocating surplus units between ships in a pool. In any case the ship does not need to join the same pool the following year, and the surplus can be shared within a different pool.

Basic rules governing FuelEU Maritime vessel pooling are:

• The total pool compliance balance must be positive
• Ships with a deficit before pooling do not have a higher deficit after pooling
• Ships with a surplus before pooling do not have deficit after pooling

The FuelEU Maritime regulation applies to ships above 5000 GT sailing to, from and between EU/EEA ports, regardless of the vessel’s flag. All ship types, except offshore ships, are covered under this regulation.

The UK is not part of the EU anymore, so it does not fall directly into the FuelEU Maritime scope. As per the geographical scope of the voyage, 50% of energy used on voyages from UK ports to EU/EEA ports and vice versa is within the scope of the FuelEU Maritime regulation.

If the vessel did not perform any voyages within the scope of the FuelEU Maritime regulation in a given year, a FuelEU report does not need to be submitted and a Document of Compliance is not issued or required.

FuelEU Maritime is another measure complementing the EU ETS system to achieve climate targets. Unlike the other measures, the FuelEU Maritime regulation focuses on types of energy used on board and looks at life cycle emissions, aiming to boost the use of alternative fuels and innovative technologies. Flexibility mechanisms such as pooling, borrowing and banking differentiate the regulation from the EU ETS / EU MRV scheme.

The FuelEU Maritime regulation is applicable from 1 January 2025. From this date on, ships within the scope of the regulation need to monitor data pursuant to the regulation.

The FuelEU regulation promotes the use of sustainably produced renewable and low-carbon fuels to achieve climate neutrality while ensuring the smooth operation of maritime transport without distortions in the internal market. In doing so, the regulation respects technological neutrality and fosters innovation with complementing energy efficiency measures.

Well-to-wake life cycle emissions of fuel are within the scope of the regulation, including carbon dioxide (CO2), methane (CH4) and nitrous oxide (N2O) emissions.

In FuelEU Maritime, the responsible company is the ISM company, whereas in EU MRV / EU ETS the responsible company is either the ISM company or the registered shipowner.

The scope of energy depends on the geographical voyage scope:

• 50% of energy used on voyages from or to EU/EEA ports
• 100% of energy used on voyages between EU/EEA ports and throughout port stays in EU member state ports

A permanent exception to the above are voyages to or from EU outermost region ports, where 50% of energy used on voyages is within the scope of the regulation. Port stays in EU outermost region ports are treated as any other port stay in a member state port (100% energy in scope).

For biofuels, lower calorific values and well-to-wake GHG intensity are not standarized and should be included in the reporting to DNV. For renewable fuels of non-biological origin (RFNBOs), well-to-wake GHG intensity is not standarized and should be included in the reporting to DNV. Lower calorific values for such fuel types are pre-defined in Annex II of the FuelEU regulation.

For more information related to reporting requirements, please refer to the Veracity resource page.