Pooling became the dominant compliance route under FuelEU Maritime in its first reporting year, with 92% of vessels using the mechanism and only 2% relying on borrowing, according to Skuld. The remaining vessels either paid the FuelEU penalty or met the target through LNG or other lower-GHG energy sources.
Pooling allows vessels with a compliance surplus to transfer it to other ships, while borrowing lets companies defer a compliance deficit to the following year with a 10% surcharge.
Compliance surplus averaged around EUR /tCO2eq (about $/tCO2eq), well below the EUR /tCO2eq (about $/tCO2eq) penalty for VLSFO. Prices remained relatively stable through 2025 before falling to about EUR /tCO2eq (about $/tCO2eq) in May 2026 after the April 30 pooling deadline.
Joe Bettles, climate policy manager at the Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping, said shipping companies had been able to comply with the targets, with most using pooling. “This shows that FuelEU is working as intended,” Bettles said.
Meeting the requirements involves an estimated 3.22m tCO2eq of emissions reductions compared with an all-VLSFO fleet. LNG is estimated to have delivered around one-third of the required reduction, while biofuel blends accounted for the remainder.
Biodiesel represented 68% of the renewable and low-carbon energy used for compliance, with bio-LNG the next-largest contributor. FuelEU Maritime took effect on 1 January 2025 and generally applies to ships above 5,000 gt calling at EU and EEA ports regardless of flag. The initial requirement is a 2% reduction in the greenhouse-gas intensity of energy used on board, rising progressively to 80% by 2050.
Skuld, formally Assuranceforeningen Skuld (Gjensidig), is a member-owned Norwegian marine insurer established in Oslo in 1897. It provides marine insurance and risk-management services to shipowners, charterers, traders and offshore and energy operators and is a member of the International Group of P&I Clubs.
The Mærsk Mc-Kinney Møller Center for Zero Carbon Shipping is an independent, not-for-profit research and development organisation founded in 2020 and based in Copenhagen. It focuses on technologies, regulation and industry pathways for reducing greenhouse-gas emissions from shipping.
