The maritime industry’s response to EU ETS and FuelEU Maritime regulations has largely focused on the concerns of vessel owners and managers, specifically, how to secure reimbursement for compliance costs through efficient invoicing and collection processes while maintaining transparency and managing risk. However, commercial pools, operators, and charterers face fundamentally different challenges that require distinct approaches.

The Commercial Operator’s Perspective

For those operating vessels closer to the cargo side—particularly when EU ETS and fuel costs are integrated into freight rates—the regulatory landscape presents unique operational complexities. The introduction of FuelEU Maritime has created several key challenges that demand careful attention:

• Annual Compliance Dynamics: FuelEU compliance operates on a full-year basis, creating significant variability in compliance positions. A deficit accumulated throughout the year can be transformed into a surplus through a single voyage using compliant fuel blends, and conversely, a comfortable surplus can quickly become a deficit.
• Vessel Pooling Opportunities: The regulation permits vessel pooling arrangements, where positively compliant vessels can offset deficits from others within the same pool. This mechanism introduces both opportunities and complexities in compliance management.
• Charter Agreement Considerations: When chartering vessels, operators must navigate multiple options regarding who assumes responsibility for securing compliance, requiring careful optimisation of contractual arrangements.

The Need for Strategic Oversight

The various pathways available under FuelEU Maritime demand diligent management and forward-thinking approaches. The regulatory framework’s flexibility, while beneficial, creates a complex decision-making environment where timing, vessel deployment, and fuel choices can significantly impact compliance outcomes.

Through collaboration with customers across different market segments, we have observed that successful navigation of these regulations requires continuous monitoring and strategic planning capabilities that extend beyond traditional operational tools.

Technology Solutions for Complex Challenges

Our work with commercial pools and operators has led to the development of focused support systems designed specifically for their needs. The Compliance Forecaster provides operators with continuously updated forecasts of their vessels’ and fleet’s ETS and FuelEU exposure, incorporating trading profiles and specific consumption patterns to deliver comprehensive annual projections that inform both strategic and operational decisions.

The system’s simulation capabilities allow operators to model different deployment and bunker strategies at the vessel level, whether for extended periods or specific voyages. These simulations account for realistic sailing distances, in-port consumption patterns, and the effects of various fuel types and blends, considering their GHG intensity, ETS implications, and lower calorific values.

Market Transparency and Strategic Options

The FuelEU Pooling Marketplace addresses the challenge of surplus acquisition when forecasts indicate potential deficits. Operators must choose between purchasing compliant fuel blends or acquiring surplus through pooling agreements—decisions that depend heavily on market data, particularly the often opaque pricing of surplus positions in pooling arrangements.

This marketplace provides the transparency necessary for informed decision-making while offering direct access to favourable pooling arrangements when that path proves most advantageous.

Looking Forward

The maritime industry’s adaptation to EU environmental regulations continues to evolve, with commercial operators and pools requiring specialised tools and approaches that differ significantly from those needed by traditional vessel owners and managers. Success in this regulatory environment depends on maintaining current information, understanding compliance trajectories, and having access to flexible strategic options.

As these regulations mature and market mechanisms develop, the ability to forecast, simulate, and optimise compliance strategies will likely become increasingly crucial for commercial operators seeking to navigate these waters successfully while maintaining operational efficiency and competitive positioning.

Want to learn more about OceanScore’s FuelEU Pooling Marketplace? 
Get in touch with our team.