Overlap Between FuelEU and IMO Rules Raises Industry Concerns

A Changing Regulatory Seascape

The maritime industry is entering a crucial phase in its decarbonisation journey. As regulators around the world introduce new measures to curb greenhouse gas emissions, shipowners are preparing to comply with overlapping frameworks that are both ambitious and complex. Two of the most important developments are the European Union’s FuelEU Maritime regulation and the International Maritime Organization’s Net-Zero Framework.

Both frameworks aim to accelerate the transition to low-emission fuels and more efficient operations. Yet, their coexistence raises a key question: will shipowners end up paying double for the same emissions?

Understanding the EU’s FuelEU Maritime

FuelEU Maritime, launched on January 1 this year, forms part of the EU’s broader Fit for 55 package. It requires ships above 5,000 gross tonnage calling at EU ports to reduce the greenhouse gas intensity of their fuel mix.

The regulation incentivises the adoption of low and zero emission fuels, such as biofuels, methanol, and LNG, through a penalty system. If a vessel’s fuel mix exceeds permitted thresholds, operators must pay fines. This complements the EU Emissions Trading System (ETS), which began extending to maritime shipping in 2024.

By 2030, the EU aims to reduce CO2 emissions from shipping by 55 percent compared to 1990 levels. FuelEU Maritime is thus a central part of Europe’s decarbonisation strategy.

The IMO’s Global Net-Zero Framework

While the EU’s rules target regional emissions, the IMO is introducing a global approach. Its Net-Zero Framework, endorsed at the Marine Environment Protection Committee’s 83rd session, will gradually tighten greenhouse gas intensity standards for ships.

Starting in 2028, vessels will be required to cut fuel intensity by 4 percent compared with 2008 levels, increasing to 30 percent by 2035. Alongside technical measures like route optimisation and efficiency upgrades, the IMO also introduces carbon pricing with penalties ranging from $100 to $380 per tonne of CO2 equivalent.

This marks a shift toward a truly international system, giving shipowners worldwide clearer expectations.

The Risk of Overlap

A challenge emerges if both FuelEU Maritime and the IMO’s framework apply simultaneously. A ship of 5,000 gt or more calling at EU ports could face double penalties, one from Brussels and another from the IMO.

Industry voices, such as Lloyd’s Register CEO Nick Brown, have expressed concern over this possibility. Paying twice for the same emissions would undermine fairness and efficiency.

Some shipowner associations, including the Union of Greek Shipowners, argue that the EU should scrap regional regulations once the IMO system is in place. They believe a single global framework would prevent duplication and streamline compliance.

Diverging Perspectives

Not everyone agrees. Policy experts highlight that aligning regulations at the lowest level of ambition could weaken Europe’s competitiveness and stall innovation. For example, the EU ETS is expected to price a broader share of emissions compared to the IMO’s proposal, raising more funds to support the development of green shipping technologies.

Others emphasise that shipping is inherently global. Ships cross jurisdictions every day, and harmonised rules could provide the clarity and predictability that investors, financiers, and shipowners urgently need.

Why Alignment Matters

Regardless of differing opinions, one point is clear: alignment is necessary. Investors want certainty to back next generation fuels and ship designs. Shipowners need clarity on compliance pathways. Policymakers seek mechanisms that balance ambition with practicality.

Without alignment, companies may remain stuck in short term compliance mode instead of planning for long term decarbonisation. A unified system could unlock investment and accelerate the scaling of technologies critical to the sector’s transition.

Preparing for the Transition

For shipowners, the safest strategy is to prepare for both regulatory regimes. This means investing in energy efficiency, exploring low carbon fuels, and adopting technologies that reduce emissions. Even if the frameworks eventually converge, early action will put operators in a stronger position to adapt.

Holistic planning; considering fuels, operations, and investments together, will be key.

Conclusion

The maritime sector is navigating uncertain but exciting waters. The coexistence of FuelEU Maritime and the IMO Net-Zero Framework highlights both the urgency of decarbonisation and the complexity of global regulation. While duplication is a real risk, it also creates an opportunity for collaboration between regional and international bodies.

The industry’s long term competitiveness will depend on clear rules, ambitious goals, and aligned frameworks. By adopting sustainable practices today, shipping companies can position themselves not just for compliance, but for leadership in the global transition toward cleaner transport.

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