Carbon pricing is becoming a compliance maze
EU ETS, FuelEU Maritime and the IMO's emerging framework all work differently — and without coordination, owners face paying, reporting and calculating twice. By Philippos Ioulianou, EmissionLink.
The following is a contributed opinion piece by Philippos Ioulianou of EmissionLink.
The European Commission's pledge to stop shipping companies being charged twice for the same emissions has been welcomed across the sector. The principle is clear enough; the practice is anything but. Without detailed guidance on how duplicate carbon costs will actually be avoided, owners and managers are left to find their own way through an increasingly tangled regulatory landscape.
At EmissionLink we welcome the Commission's acknowledgement of the problem, but eliminating double charging will take far more than a statement of intent. It is a substantial administrative, commercial and technical challenge — and one the industry has to start preparing for now. With no guidance yet issued, the reality is that shipping already sits in a crowded regulatory minefield: EU ETS and FuelEU are in force, and the IMO is edging, slowly, towards its own global net-zero framework. Each system has a different scope, timeline, calculation method and commercial logic, which is exactly why avoiding duplicate charges is so difficult.
Consider a vessel trading into Europe: it may be exposed to EU ETS, FuelEU and, in time, IMO carbon rules at once. The obligations will not always fall to the same party, the data will not always be calculated the same way, and the cost will not always be recoverable under existing charterparty terms.
So the risk is not only paying twice — it is reporting twice, calculating twice, or standing up parallel compliance processes that drain time and breed confusion. How will EU and IMO obligations be reconciled? How will equivalent payments be recognised? How will the schemes interact without penalising the same tonne of emissions more than once — and what evidence will owners need to prove they have not been? The answers will decide whether carbon regulation is seen as a fair transition tool or just another line of cost.
Accurate, auditable emissions data will matter more than ever, but data alone is not enough. Owners also need the expertise to interpret that data across schemes and make the right commercial calls. At EmissionLink we have already delivered accurate FuelEU emissions data for more than 600 vessels, and that experience has shown us how complex this is in practice. Every vessel has its own operating profile, every voyage carries a regulatory consequence, and every compliance decision can affect cost exposure, penalties, pooling options, charterparty recovery and future planning.
A clear, agreed approach covering all of this may eventually arrive, but it will not make today's obligations vanish. Owners, managers and operators need to understand their exposure now — across EU ETS, FuelEU Maritime and the future IMO framework. This is where expert support becomes critical: the task is no longer simply filing the right figure in the right system, but understanding how the schemes interact, how they hit the business, and how to avoid double penalties, duplicated processes and avoidable costs.
Carbon pricing will also only keep its credibility if the revenues are visibly used to support maritime decarbonisation. At a ShipEnergy forum during Posidonia, I argued that EU member states must set out a clear path for how EU ETS and FuelEU revenues are used. Those funds should flow back into the sector — not become a general revenue stream for governments. Demanding that shipping pay more while failing to invest in the infrastructure that makes decarbonisation possible is not a transition strategy; it is taxation with a green label. The Commission is right to recognise the risk of duplicate carbon costs. What the industry needs now are rules that are practical, transparent and enforceable — and a clear sense of how they will actually support the transition to lower emissions.
