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FuelEU Maritime Pooling: A Viable Strategy

FuelEU Maritime Pooling: A Viable Strategy

 

FuelEU allows for pooling compliance deficits and surpluses as one way to secure compliance. OceanScore analyses continues to show that pooling is a viable strategy. Pooling – considering all costs including EU ETS and different bunker costs and LCVs – currently appears to be comparable and a bit cheaper than bio fuel based compliance strategies and certainly significantly cheaper than paying penalties.  

Surprising Price Trends

Currently, poolprices are (surprisingly) low. €200 +/- per tonne of CO2e are being quoted for larger volumes on OceanScore’s FuelEU Pooling Marketplace even if they do not reflect the full cost of generating compliance surpluses through using bio fuels. The simple reason for these low pooling prices are the expected oversupply of compliance surpluses – beyond what is needed to compensate all the deficits currently generated – in combination with the fact that many of the compliance surpluses are generated by LNG and LPG carriers at zero additional fuel costs.

The Straightforward Reality of Pooling

Pooling actually is very simple: Once compliance balances have been verified by March 31 of any year, compliance pools can be registered in Thetis by a simple tick during the next 30 days until April 30. One more simple pool check by a verifier, that’s it.

Avoiding Unnecessary Complexity

So why make it unnecessarily complex? Tokenization. Block Chain. Complex KYC – Know your Customer – and onboarding processes. Shipping – especially 3rd party management – is a tough, low margin business. These “artificial” complexities are not necessary. They add no benefits and only complicate and cause unnecessary costs.

What to watch out for?

 

  • Anything complex that is not intuitively necessary – it’s probably not needed. And it probably adds cost that is not needed either. Avoid it
  • Exclusive deals. We have seen attempts to lock shipping companies into exclusive deals that do not allow them to pool with anyone else but the pool provider. Avoid it. The pool prices in these structures appear to be really unattractive – once someone is locked in.
  • High one-off costs and pool management fees: Pooling should be simple, not expensive. All it takes is you agreeing with someone to flag your pool in Thetis. Just agree with another DOC holder you know to pool – and then do it. Zero extra cost. Just find that partner and do the deal. Once. And next year decide again – it might be the same partner. Why not.
  • Missing liquidity: Everyone in the pooling market is a start up. No one has done this before. So make sure there is a solid “installed base”, a credible number of offers that could be your counterparty. We have seen a lot of talk – often not backed up by pool places really reliably offered.

How OceanScore Can Help

 

So, if someone tries to sell you high fixed annual cost, high pool management fees, multi year exclusive pool solutions – ignore it. Don’t be tricked by smart language around tokenization, know your customer solutions, pool verifications – none of that is needed. There will be enough low cost, straight forward pools in the market. 

Doubt this? Want to avoid the risk of being left hanging dry? Well, just reach out to OceanScore. Our FuelEU Pooling Marketplace does what is needed and has been build with the support of a large number of shipping companies and compliance surplus providers: Simple, straight forward and low / no cost. And certainly not exclusive. We want to convince you, not corner you. 


Frequently Asked Questions

What exactly is FuelEU pooling?

Pooling allows shipping companies with compliance surpluses to transfer these to companies with deficits. It’s a regulatory mechanism that helps the industry meet FuelEU Maritime requirements collectively rather than individually.

Is pooling allowed under FuelEU rules?

Yes. The FuelEU regulation explicitly allows pooling as a compliance mechanism.

When can I register a pool?

You can register a pool in Thetis between April 1 and April 30, after compliance balances have been verified by March 31.

What are the risks of exclusive pooling deals?

Exclusive agreements may limit your options and often come with higher costs. It’s best to work with flexible, non-exclusive partners.

Why are current pooling prices low?

There is an expected oversupply of compliance surpluses, particularly from LNG and LPG carriers, which helps keep prices down.

Do I need blockchain or tokenization to pool?

No. These technologies are not required by the regulation and often complicate the process unnecessarily.

 

Oceanscore in the news

  • OceanScore launches free-to-use digital platform to trade FuelEU biofuel compliance credits
    April 7, 2025

    OceanScore launches free-to-use digital platform to trade FuelEU biofuel compliance credits

    Hamburg-based technology platform OceanScore has launched a platform to facilitate the trading of biofuel surpluses and deficits under the FuelEU Maritime Regulation pooling scheme, learns bunkering publication Manifold Times. The platform is designed to be simple and user-friendly, allowing bunker companies to find buyers for their surplus biofuels and shipping companies to find suppliers. It is free-to-use, with a low fee for signing on, and is intended to complement OceanScore's main software solutions.
    Read article
  • OceanScore has the answers to the maritime regulatory conundrum
    March 6, 2025

    OceanScore has the answers to the maritime regulatory conundrum

    The maritime sector is facing increasingly stringent regulations aimed at reducing emissions, with FuelEU Maritime and the EU Emissions Trading Scheme (EU ETS) taking centre stage. OceanScore, a company providing compliance solutions, is offering innovative ways to help shipping companies meet these challenges and optimise their compliance strategies.
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  • OceanScore to launch combined EU ETS and FuelEU solution in Singapore
    January 8, 2025

    OceanScore to launch combined EU ETS and FuelEU solution in Singapore

    Hamburg-based technology platform OceanScore will introduce the Compliance Manager, its new solution that will help effectively manage FuelEU Maritime Regulation and EU Emissions Trading System (EU ETS) on one platform, in Singapore. Albrecht Grell, Managing Director, and Leo Grayson, Head of Commercial, APAC, will discuss the FuelEU regulation in depth, what it means for Asian players, and best practices and strategies for efficient compliance. The event will be held from 3 to 5pm (Singapore time) on 23 January. The venue of the event will be at OceanScore Singapore, c/o Blue Net Chartering Asia Pte. Ltd., 20 Cecil Street, PLUS, #24-02.
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  • OceanScore reviews the first year of EU ETS: what have we learned and what lies ahead?
    December 5, 2024

    OceanScore reviews the first year of EU ETS: what have we learned and what lies ahead?

    OceanScore says many shipping companies struggle to track whether invoices have been accepted, EUAs delivered or payments made without a centralized system. OceanScore client Hammonia Reederei states: "As a high-quality third-party manager, transparency is at the core of how we work with our customers - no hidden charges, no hidden fees. Managing ETS exposure across multiple owners and charterers is a complex task, but OceanScore's ETS Manager has made it efficient and straightforward. Their solution not only streamlines our processes but also helps us provide clear, transparent cost breakdowns around ETS compliance to our customers, reinforcing our commitment accountability to trust and accounting. Looking ahead, Grell says "temporary solutions may suffice for now in tackling some of these challenges, but they are not sustainable long-term", especially with implementation of FuelEU from next year that he believes will amplify pressure for automated data-driven systems to cope with the complexity. "The lessons from these challenges highlight the need for systematic, scalable solutions to manage emissions compliance effectively, ensuring long-term success under the EU ETS framework. The growing need for robust tools is clear. Transparency, efficiency and collaboration across stakeholders will be crucial to tackle the challenges ahead," he concludes.
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  • UK eyes expanding its ETS to deepsea shipping – closing EU loophole
    December 2, 2024

    UK eyes expanding its ETS to deepsea shipping – closing EU loophole

    Apart from the hit to the EU’s decarbonisation goals, OceanScore MD Albrecht Grell said the UK loophole would tie-up ship capacity, inflate freight rates and could cause disruption as carriers queue up at UK ports. “We need to consider that UK ports do not have the capacity to handle significant increases in throughput, so more port congestion, time lost, would have to be considered,” he said. Mr Grell added that he did not expect the loophole to last for long at any rate, as the EU is planning to review its ETS from 2026.
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  • OceanScore reviews BIMCO FuelEU clause for time charter parties
    November 29, 2024

    OceanScore reviews BIMCO FuelEU clause for time charter parties

    The current BIMCO draft provides a foundation but leaves substantial room for improvement and charter party specific clarifications, said Hamburg-based technology platform OceanScore on Wednesday (27 November). OceanScore added it is already working with customers to implement forward-thinking FuelEU strategies that fill these gaps, supporting smart decision making and efficient processes between the different stakeholders.
    Read article
  • OceanScore supports tricky bunker selection process under FuelEU Maritime
    November 14, 2024

    OceanScore supports tricky bunker selection process under FuelEU Maritime

    “Fuel selection is the most important lever under FuelEU,” said OceanScore Managing Director, Albrecht Grell. “Your choice of fuel can either create a surplus or a deficit in your compliance balance, directly affecting your costs.” Grell added: “Choosing the right fuel can help avoid penalties and even create revenue by pooling surpluses. But not all alternative fuels are the same, and their viability often depends on future pooling prices, which are hard to predict.” FuelEU charts a course for reducing emissions in shipping, with a target near net-zero by 2050. For now, two main options are available to meet the greenhouse gas (GHG) threshold of 89.3g CO2e/MJ until 2029: LNG and LPG: These fuels, when used in dual-fuel engines, will meet the rules and can generate surplus compliance balances. However, their benefits will decline until 2040 as limits tighten. Biofuels: These are a good option for most vessels. They are usually used in blends (eg. B20-B30) with conventional fuels. These blends will be compliant until 2040; higher blends or pure biofuels will be needed thereafter. One issue is that EU ETS and FuelEU Maritime treat biofuels differently. Under EU ETS, biofuels are considered zero-emission, meaning companies do not need to buy carbon credits. But under FuelEU, the rules are stricter. “FuelEU doesn’t count all biofuels equally,” Grell explained. “Fuels made from food or feed crops are treated like conventional fuels in terms of emissions. Only waste-based biofuels are fully compliant, and even then, their specific GHG values are above zero.” This difference matters. Standard biofuels, such as those from rapeseed or sunflower seeds, still benefit from ETS discounts but fall short under FuelEU. For full compliance, waste-based biofuels are needed, such as those from used cooking oil or animal fat. Further complications are added when considering the different rules behind the 50% discounts applied to voyages to and from the EU under the two regulations. OceanScore, which provides advanced solutions to facilitate efficient regulatory compliance, is assessing the impact of alternative fuels based on their relative carbon intensities, calorific values (LCVs), prices, and ETS cost incurred, reflecting these in its FuelEU Planner. The challenge goes beyond selecting fuels with low GHG intensity and factors such as the vessel's ice class or whether voyages are intra-EU or international also influence compliance balance. If companies bunker more expensive alternative fuels like biofuels, there is no guarantee it will always pay off. “FuelEU allows for pooling of compliance surpluses and deficits,” Grell added. “Surpluses generated by using compliant biofuels can be sold in the compliance market to vessels in deficit.” OceanScore’s analysis indicates that the compliance market will be in surplus by 1 January 2025. “This surplus will put downward pressure on pooling prices, meaning it might be cheaper to buy a compliance surplus in the pool rather than generate it through compliant bunkering on your own vessels,” Grell said. “Both approaches would be compliant with FuelEU regulation and need to be considered at least from a commercial angle.” Given this, any sound compliance strategy must look beyond fuel selection alone and consider the broader market dynamics. “Our FuelEU Planner integrates these variables into a comprehensive scenario simulation,” continued Grell. “This is crucial because tackling FuelEU successfully requires charterers, managers, and owners to collaborate using a shared, fact-based approach.” Grell outlines several key steps for shipping companies to optimise their compliance strategies. First, they must gain a thorough commercial understanding of the economics of different fuels, considering their prices, LCVs, EU ETS costs, and the cost of pooling FuelEU compliance balances. At the same time, the technical and operational feasibility of using biofuels across different vessels should be assessed. While tests so far indicate that biofuels can be used without significant issues, lingering concerns over engine compatibility and tank systems remain. “Engine manufacturers need to give the green light, and bunker providers must be identified in key ports,” Grell noted. “For now, many companies focus biofuel usage on a smaller portion of their fleet to simplify operations and reduce risks.” However, one of the biggest hurdles remains contractual. “How do you protect the DOC holder, who is responsible for penalties, from the fuel decisions of the charterer? How do you fairly share the costs of biofuels and the value of surpluses? And how do you manage uncertainties tied to deployment patterns and fuel accountability under FuelEU?” Grell asked. Without clear contractual terms, companies risk major financial and operational pitfalls. “To align incentives across owners, managers, and operators, you need clauses in agreements like Shipman and Charter Parties,” he stated. “The ‘polluter pays’ principle is not embedded in FuelEU, so a robust data-driven understanding of the entire value chain is essential to avoid costly disputes.” OceanScore’s FuelEU Planner provides a clear path through the complexity. By simulating fuel use, compliance costs, and pooling options, the tool enables companies to budget effectively and negotiate data-driven contracts. “We make the complex FuelEU regulations easier to manage,” Grell concluded. “With our solutions, companies can understand the commercial impacts of their fuel choices, gain full transparency and confidently manage their compliance strategy.” You might also like Veolia, Enagás, and Barcelona City Council inaugurate first urban cold recovery network from LNG terminal
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  • 欧州燃油規制への対応最適 化 オーシャンスコアが新ツール、都内セミナーで紹介
    September 20, 2024

    欧州燃油規制への対応最適 化 オーシャンスコアが新ツール、都内セミナーで紹介

    アルブレヒト・グレル専務は「FuelEUはEU-ETSに 比べると極めて複雑で、海運会社は燃料選択など難しい選択を求め と説明する。 サイトの利便性向上 FuelEUは、個船のGHG排出量の過不足(コンプライアンス・バランス)を、
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  • EU―ETS排出枠 日本管理船 年1億ユーロ オーシャンスコア試算 370 隻・170万枠
    September 20, 2024

    EU―ETS排出枠 日本管理船 年1億ユーロ オーシャンスコア試算 370 隻・170万枠

    船舶のGHG(温室効果ガス)データ管理サービスを提供する独オーシャンスコア(本社・ハンブルク)の試 算によると、EU―ETS(欧州連合の排出量取引制度)の100%適用が始まる2026年以降、日本の船主・船舶管理会社が管理するEU寄港船の排出枠(EUA)コストは年1億ユーロ(約165億円)規模に上る見通しだ。EUに寄港する日本管理船約370隻のEUAは年170万枠に達する見込みで、世界の海運全体のEUA年8
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  • OceanScore calculates €175m potential costs for Greek shipping with FuelEU Maritime
    September 12, 2024

    OceanScore calculates €175m potential costs for Greek shipping with FuelEU Maritime

    Greek shipping companies are set to face a total bill of over €175m in penalties incurred under FuelEU Maritime after it takes effect next year but can also capitalise on the use of alternative fuels both to curb their financial exposure and generate compliance surpluses, according to OceanScore.
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