Responding to evolving maritime emissions regulations

RESPONDING TO EVOLVING MARITIME EMISSIONS REGULATIONS

Published: 10 July 2025

With increasing global focus on sustainability, new regulations on emissions and environmental compliance are set to impact the maritime industry. Recognising the importance of regulatory compliance, Britannia P&I, in collaboration with HFW, has developed comprehensive guidance documents covering FuelEU, EU ETS, CII and EEXI regulations. These resources provide shipowners and charterers with clear regulatory overviews and practical compliance guidance. We encourage all members to stay ahead of these changes, and we will continue to provide timely updates and expert insights.

These fuel regulations articles were written in consultation with the leading global law firm HFW. Whilst care has been taken to ensure the accuracy of this information at the time of publication, the information is intended as guidance only. It should not be considered as legal advice.

Read the full guidance.

CII (Carbon Intensity Indicator) Regulations:

CII and EEXI (Energy Efficiency Existing Ships Index) have global effect and are imposed by MARPOL in accordance with Marine Environment Protection Committee (MEPC) 328(76).

What?

An ongoing operational tool used to measure the carbon intensity generated by the operational performance / commercial activities of individual ships (e.g. CO₂emissions per deadweight ton miles in accordance with the Annual Efficiency Ratio (AER) Metric).

When?

A ship is required to develop, and keep updated, an enhanced Ship Energy Efficiency Management Plan (SEEMP).
Ships collect and report fuel consumption data during annual reporting period.
By 31 March in the subsequent verification period, the consumption data is verified.
After 30 April in the verification period, the verified consumption data is compared to the required baseline carbon intensity for the ship and an annual CII Rating of “A” to “E” will be allocated to ships.
The benchmark for carbon intensity (required CII) reduces by 2% each year until 2026, after which the IMO will consider revisions to the benchmark and the AER Metric.

How?

Ships can implement operational changes to improve carbon intensity. These changes include consumption of low carbon fuels, technical energy efficiency measures, ship speed optimisation, weather routing, route planning, and just in time arrival.

EEXI Regulations:

What?

A technical measure which requires ships to meet a target energy efficiency design parameter.

When?

EEXI is a singular obligation, where ships need to certify that they meet the target design parameters. This has to be certified at the first annual, intermediate or renewal survey or the initial survey, whichever is the first, on or after 1 January 2023.

Although ships should now be compliant with EEXI, revisions to EEXI could materialise after 2026 (in line with the IMO review process under Regulation 28 of MARPOL Annex VI), which could make the target energy efficiency design parameter more stringent.

EU Emissions Trading System (EU ETS) Directive:

The EU has expanded its Emission Trading System to maritime services and introduced the Monitoring, Reporting and Verification (MRV) Regulation for emissions from ships.

What?

One EUA permits a company to emit one tonne of greenhouse gases (GHG) (at present only CO₂) and EEA and non-EEA shipping companies calling at EEA ports must pay for and surrender a sufficient quantity of EUAs to meet all that shipping company’s verified emissions. EU ETS has extra-territorial effect applying to voyages from ports of call outside of the EEA.

When?

In the reporting period, shipping companies must monitor the ship’s emissions for a full calendar year in accordance with an approved monitoring plan.

From 1 January of the year following the reporting period, the verification period begins, and shipping companies must prepare an emissions report, which must be verified by an accredited verifier by 31 March.
By 30 September in the verification period, shipping companies must surrender sufficient EUAs to cover the verified emissions for all ships in their fleet.
Who is responsible? The default compliance entity for both EU ETS and MRV Regulation is the registered shipowner. However, responsibility for compliance can be shifted to the ISM Doc Holder (if not also the owner) by filing a document mandate with the applicable EU Member State Administering Authority.

Costs Recovery

EU ETS adopts the polluter pays principle and imposes obligations on EU Member States to introduce legal rights for the shipping company to recover the costs of surrendering EUAs from commercial operators.

FuelEU Regulations:

As part of the EU’s Fit for 55 legislative package, the EU has introduced FuelEU a new regulation on maritime emissions and fuel and energy used on board ships.

The objective of FuelEU is to bridge the price gap between fossil fuel (high GHG intensity energy) and low GHG intensity alternative fuels.

FuelEU establishes two target requirements. From 1 January 2025, FuelEU sets a maximum GHG Intensity Limit (which is reduced every five years from 2025) for energy used on board ships. From 1 January 2030, a further target is introduced for containerships and passenger ships, which must use onshore power supply for some EEA port calls.

In future, a further target may be applied, where energy used on board ships must come from Renewable Fuels of Non-Biological Origin (RFNBOs).

What?

The fuel and energy used on board ships during qualifying voyages and port calls must fall below the GHG Intensity Limit each year. Where the ship’s annual GHG Intensity is above the limit, this generates a negative Compliance Balance, a deficit. Where it is below the limit, this generates a positive Compliance Balance, a surplus. Ships with a surplus will be compliant, whereas ships with a deficit must take further steps to comply, either to pay a FuelEU penalty or adopt a flexibility mechanism (borrowing or pooling) permitted under FuelEU to reduce their deficit.

When?

During the reporting period, ships must monitor fuel/energy consumption on qualifying voyages and port calls.

The year following the reporting period is the verification period. By 31 January in the verification period, the shipping company must prepare a FuelEU report and submit it to be verified.
By 31 March in the verification period, the verifier will verify the FuelEU Report and record on the FuelEU Database the ship’s compliance balance.
From 1 April to 30 April in the verification period, shipping companies can adopt a regulatory flexibility mechanism (banking, borrowing or pooling). This means ships with a Deficit can borrow or pool in order to reduce their deficit and ships with a surplus can bank or pool.
By 1 May in the verification period, updated compliance balances will be recorded on the FuelEU Database to account for the use of a flexibility mechanism. Any ships with a deficit after 1 May in the verification period must pay a FuelEU Penalty.
By 30 June in the verification period, ships with a surplus or deficit (only where the FuelEU Penalty is paid) will receive a FuelEU Document of Compliance (DOC).

How?

Compliance may be achieved by switching to more energy efficient fuels with reduced GHG Intensity for their ships or adoption of one of the flexibility mechanisms described above.

Who is responsible?

The compliance entity is the International Safety Management (ISM) DOC Holder (so generally this will be the ship manager) and, unlike for EU ETS, there is no way of changing compliance responsibility to another entity.