Two years after the extension of the European Union Emissions Trading System (EU ETS) to maritime transport, the sector's balance is far from positive. Shipowners bear an additional cost that they do not consider effective for decarbonization; Asian operators are forced to create accounts in member states to report and settle their obligations without receiving any return from those revenues; and environmental organizations criticize that the surcharge per ton of fuel, between 70 and 80 euros during the last year, is insufficient to make alternative fuels competitive against fossil ones. The shipping quota in the emissions trading market, between 60 and 80 million annual credits, represents less than 10% of the total volume traded, leaving the sector without real capacity to influence the price of rights.
In this context, the scheduled review of the EU ETS that the European Commission must undertake opens a window of opportunity that the shipping industry wants to seize. From malt manufacturers to French municipal incinerators or American airlines, nearly all European industrial emitters have approached Brussels to present their reform demands. Maritime transport is no exception, and the World Shipping Council (WSC), the association that groups the main container lines in the world, has articulated its requests around three axes: closing the price gap of green fuels, harmonizing compliance obligations between various European regulations, and ensuring that the ETS is withdrawn when the International Maritime Organization (IMO) adopts an equivalent global regulatory framework.
Simon Berghoff, vice president of Environment and Climate at WSC and former regulatory head at A.P. Moller-Maersk, has indicated that the maritime sector "is the new student regarding the ETS" and that the experience gained in these first two years has allowed for the identification of areas for improvement. Furthermore, he has emphasized that the evolution of the system in aviation, where the CORSIA mechanism already works as a partial alternative to the ETS, provides important signals about how Brussels could act if the IMO successfully approves its own global regulations.
The first axis of the WSC proposal addresses the main obstacle to maritime energy transition: sustainable maritime fuels cost between 100% and 400% more than fossil fuels. To close that gap without resorting to direct financial transfers from European budgets, the association proposes a mechanism for sustainable maritime fuels inspired by the one that aviation already uses for sustainable aviation fuels (SAF). Specifically, the WSC intends to reserve 100 million emission rights for the shipping sector, at a rate of about 10 million per year over a decade. Operators who use green fuels would receive additional rights according to a scale proportional to the sustainability of the fuel used: 95% of the cost covered for electrofuels (e-fuels), the most expensive but also the cleanest option; 70% for advanced biofuels; and 50% for other alternatives. Berghoff described the current system as "a lot of stick and little carrot" and defended that his proposal, by not depending on the direct redistribution of funds collected by member states, avoids the bureaucratic complexities of existing European funding programs, such as the Innovation Fund, which tend to be oriented towards capital investments rather than operational costs.
A volume of 100 million emission rights amounts to about 8 billion euros at the current market price, a figure that may seem high. However, Berghoff has argued that it should be evaluated in the context of a ten-year period subject to interim reviews, and that the real problem for the sector is not the investment in more efficient ships, but access to green fuels at commercially viable prices. "My members and the companies of the World Shipping Council are perfectly capable of investing in energy-efficient ships, and they have been doing so for a long time," he noted. "The issue is really how to access those green fuels at a commercially viable price."
The second pillar of the proposal focuses on administrative simplification. Currently, the entity responsible for regulatory compliance is not aligned between the ETS, the FuelEU Maritime regulation, and the MRV regulation (monitoring, reporting, and verification). This fragmentation is particularly burdensome for non-European shipowners, who must base their compliance on the member state where they register the most port calls, which does not always coincide with the country where they have their operational headquarters. The WSC requests that a single entity be designated as responsible in all three regulations. At the same time, Berghoff has warned against the temptation to establish automatic cost pass-through clauses between owners and charterers, because this would eliminate the commercial flexibility that allows both parties to negotiate the distribution of costs based on market conditions and the energy efficiency of each ship. "If an automatic transfer is established, the commercial freedom of those negotiations is eliminated," he explained, "and what may work in a market favorable to shipowners can be very detrimental when the market tilts toward charterers."
The third axis of the WSC strategy directly addresses the relationship between European legislation and the global regulatory framework that the IMO has been negotiating for years. The so-called Net Zero Framework of the IMO, approved at MEPC 83 in April 2025, was to be formally adopted in an extraordinary session in October of that same year, but negotiations were interrupted without agreement, and the session was postponed to autumn 2026. The recent MEPC 84 meeting, held in spring 2026, was limited to an exchange of positions without substantive decisions, and two additional intersessional meetings were scheduled without a defined timeline for potential adoption of the framework. If the IMO fails to approve a global system, the scope of the ETS could expand from 50% of emissions from journeys originating or destined for the EU to 100%, a scenario that would entail a significant increase in costs for the sector.
At the recent Posidonia 2026 fair held in Athens in early June, the European Commissioner for Sustainable Transport and Tourism, Apostolos Tzitzikostas, provided what is considered the firmest signal to date regarding this: "European companies will not pay twice, neither in Europe nor in the IMO." Berghoff dubbed these statements as "fantastically positive," but noted that the promise depends on the IMO effectively approving a regulatory framework and that European member states accept that maritime transport ceases to contribute to the ETS once equivalent international standards exist. The definition of what constitutes an "equivalent" regime will likely be one of the most complex debates in the coming months.
There is an additional element that complicates the picture. The FuelEU Maritime regulation, the sister regulation of the ETS that sets progressive limits on the greenhouse gas intensity of fuels used by ships, is not undergoing the same review process. Berghoff has acknowledged that it is not sufficient to call for its elimination because this regulation contains essential provisions regarding port electrification and onshore power supply (OPS) that the IMO has not yet addressed globally. In fact, the WSC argues that part of the funds raised through the ETS should be allocated to financing the electrification of the ports in the TEN-T core network, given that the legislation requires shipowners to use OPS from 2030 but does not resolve the issue of the upfront investment that ports must make to have the operational infrastructure ready on time.
The review of the EU ETS occurs at a time of maximum regulatory uncertainty for international maritime transport, with the European regulation already in full implementation phase — starting January 2026, shipping companies must acquire rights for 70% of their verified emissions from 2025, moving towards 100% in 2027 — and with the global IMO framework still suspended in a diplomatic process whose outcome no one can guarantee. The industry's ability to influence the final architecture of the system will depend on both the technical strength of its proposals and the political will of member states to accept that the revenues generated by the maritime ETS return to the sector that generates them, instead of being diluted in the general budgets of the Union.
