- The first report on the implementation of the ETS extension to maritime transport shows no significant evidence of evasion or circumvention trends.
- The report on the EU maritime Monitoring, Reporting and Verification (MRV) review highlights the opportunities and challenges on the possible inclusion of smaller ships into the EU MRV system.
On 18 March, the Commission adopted its first report on the implementation of the EU Emissions Trading System (ETS) extension to maritime transport, which began on 1 January 2024. The report provides an initial analysis of the impacts of this recent policy development that covers around 12 000 large ships and is key to ensure the fair contribution of shipping to the EU’s climate objectives.
The report looks specifically into the potential risk of evasion and circumvention. However, it does not find any evidence of major changes in the market being directly attributable to the introduction of the EU ETS. For instance, the analysis of traffic data does not show evidence of a general trend in relocation of container transhipment activities, nor does it bring to light any clear evidence suggesting that shipping companies are adding stops at neighbouring non-EU ports. Furthermore, the data provides no evidence of a modal shift towards road transport or an increase in the use of smaller ships, which might have suggested evasive behaviour. Forward-looking indicators, including route announcements and planned investments in ports, similarly reveal no discernible trends indicating a general change in market behavior due to the ETS extension, despite identifying a few isolated cases of potential circumvention. Furthermore, the report finds no evidence of reduced shipping services to EU islands or outermost regions.
Limitations of the analysis are also highlighted in the report (e.g. impacts of the Red Sea crisis on maritime traffic, limited time of application of the ETS to the sector, or data availability) as well as the need to cautiously interpret its findings. As a result, the Commission is committed to continue its monitoring activities, actively seeking the support and collaboration of Member States, agencies, and relevant stakeholders to swiftly identify new trends, patterns, and emerging issues.
In tandem, the Commission adopted another maritime report assessing the potential inclusion of small ships between 400 and 5 000 gross tonnage under the scope of the EU regulation for the Monitoring, Reporting and Verification (MRV) of maritime greenhouse gas (GHG) emissions.
The analysis identifies that over 5 300 smaller vessels – emitting around 11 million tonnes of CO2 every year – are currently not covered by the legislation. Including these ships could increase the amount of emissions covered by the legislation by around 9%, while expanding the number of regulated ships by around 42%.
In line with the Commission’s commitment to avoid disproportionate administrative burden, the analysis examined the administrative cost of MRV procedures. Recurring annual MRV-related administrative costs for smaller vessels are projected to be similar, if not slightly higher, than for larger vessels. Consequently, the balance between administrative costs and additional monitored GHG emissions is less favourable for smaller ships. In turn, the report notes that the net present value of additional administrative costs for companies and competent authorities is higher than the monetary potential of GHG emission savings attributable to the MRV maritime Regulation alone. Yet, the analysis suggests that these findings could shift if the GHG emission savings from the possible integration of smaller vessels in other GHG mitigation policies, such as the EU ETS and FuelEU, were considered. An assessment of these potential additional benefits will be considered in the context of the 2026 review of the EU ETS Directive.
Both studies are the result of a collaborative effort by a consortium of contractors, the European Maritime Safety Agency and Commission services, including discussions with experts from Member States and stakeholders on the ETS implementation.
These two reports follow the publication of the 2024 Commission’s report on CO2 Emissions from Maritime Transport, which provides a comprehensive comparison of data and an analysis of trends in emissions and energy efficiency over the years.
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