What is the FuelEU Maritime surcharge on my sea freight invoice?

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Senseible · Accepted Answer

It is the carrier passing on its cost of meeting FuelEU Maritime, an EU rule since 1 January 2025 that caps the greenhouse gas intensity of energy used by large ships calling at EU ports. Carriers recover cleaner fuel costs or penalties through it. It is a freight cost, separate from the EU ETS surcharge. Ships over 5,000 gross tonnes carrying cargo or passengers to, from and between EU ports. A limit on the well-to-wake greenhouse gas intensity of energy used on board, against a reference of 91.16 g CO2e per MJ. The cut starts at 2% in 2025 and tightens in steps to 80% by 2050. Voyages between an EU and a non-EU port count at 50% of the energy used, so an India to Rotterdam leg is half covered. Ships that miss the limit pay a penalty; companies can bank surpluses or pool ships to meet it. The EU ETS line pays for allowances covering the CO2 a ship emits. The FuelEU line pays for the fuel standard: buying biofuel or LNG blends, or the penalty for not doing so. A ship can owe both. Each carrier names and prices them differently, so read the tariff notice for each. Is the charge per container or per tonne, and on which legs? Is it based on the fleet's actual compliance position, a pooled position or a flat estimate? How often is it revised, and is it already inside an all-in rate? Can you get shipment-level emissions data that reflects the cleaner fuel used? Book the charge with freight cost, paid by whoever pays freight under the Incoterm. Do not convert it into tonnes of CO2e. Your Scope 3 freight figure changes only if the carrier gives you shipment-level emissions that reflect the lower-intensity fuel, calculated under the GLEC Framework.

What is the FuelEU Maritime surcharge on my sea freight invoice?

What the regulation requires

How it differs from the EU ETS surcharge

Questions to ask your carrier or forwarder

Accounting and emissions treatment

What Senseible does here