FuelEU Maritime Guide

Guide on the calculation and impact of FuelEU Maritime on your ship

 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

EXECUTIVE SUMMARY
FuelEU requires shipowners to comply with (1) a Green House Gas (GHG) intensity limit
of energy used on board a ship, expressed in gCO2 eq per MJ, and (2) the use of shore
power (onshore power supply or OPS) or other zero-emission technology in port for
containerships and passenger ships. The GHG intensity limit is reduced over time,
resulting in an 80% cut by 2050.

Non-compliance with either the GHG intensity limit or the use of shore power will lead
to severe ‘penalties’ for shipowners: approximately €750,000 in 2025 for a containership
used as benchmark in this guide, consuming 12,000 mT HFO and 1,400 mT MDO per
annum. Payment of penalties means compliance to FuelEU Maritime, but costs will be
increased significantly in the future, up to €90M for containership benchmark.

The goal of this guide itself is to provide the reader with detailed information on the
requirements, calculation of and compliance to FuelEU Maritime. As the regulations are
continuously changing and this guide is static, use the website to gather the latest
information regarding FuelEU, or ask the helpdesk for clarifications at any time.

Key Points

• FuelEU Maritime applies to all ships of above 5,000 gross tonnage that serve the
purpose of transporting passengers or cargo for commercial purposes, regardless
of their flag, arriving at or departing from EU/EEA ports (learn more).

• Fishing, naval ships, wooden ships of primitive build, ships propelled by non-
mechanical means and government ships used for non-commercial purposes are
exempt. More exemptions exists in specific cases (learn more).

• FuelEU Maritime mandates shipowners to (1) monitor and report fuel consumption
and voyage information to verifier each year to determine GHG intensity of the ship
and (2) adhere to the use of shore power when moored for containerships and
passenger ships (learn more).

• Compliance to FuelEU Maritime without mitigations would mean payment of yearly

penalties in the order of €750,000 for a containership operating solely in EU waters.
Mitigation options include refitting, changing fuel, banking, borrowing and pooling
(learn more).

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 2
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

Figure 1. Watch the full masterclass on FuelEU Maritime for more practical case studies and examples.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 3
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

Contents

EXECUTIVE SUMMARY 2

1.0 ABOUT FUELEU MARITIME 6

1.1 Introduction 6
1.2 Legislator and jurisdiction 8
1.3 Requirements 9
1.4 Applies to … 12
1.5 Exemptions and exceptions 13

2.0 CALCULATING FUELEU MARITIME 14

2.1 GHG Intensity calculation 14
2.2 Penalty calculation 22
2.3 WtT and LCV values 25

3.0 IMPACT OF FUELEU MARITIME 27

3.1 Compliance and non-compliance 27
3.2 Penalties costs 27
3.3 Mitigation options and costs 29

4.0 FREQUENTLY ASKED QUESTIONS 37

5.0 APPENDIX 48
5.1 References 48
5.2 GHG Intensity terms and notations 49
5.3 RED biofuels tables 50
5.4 GHG Intensity penalty terms and notations 53
5.5 Fuel change compliance years 54

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 4
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

Disclaimer
Sustainable Ships will not be held responsible for any damages that could arise from
using the information provided in this report or on its platform. All costs provided in this
blog are estimates, based on experience, publicly available data or anecdotal evidence
from research. Any numbers are for feasibility study purposes only. Contact and review
all numbers with your verifier. View all terms and conditions here.

REGULATIONS CHANGE.

THIS PDF GUIDE DOES NOT.

CONTACT HELPDESK WHEN IN DOUBT.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 5
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

1.0 ABOUT FUELEU MARITIME

1.1 Introduction
In July 2021, the European Commission put forward the 'fit for 55' package of legislative
proposals, aimed at ensuring the success of the European Green Deal. The FuelEU
Maritime regulation is one of the proposals resulting from this deal and, together with
four other proposals, seeks to steer the EU maritime sector towards decarbonization.

FuelEU Maritime aims to drive uptake of low-carbon fuels by introducing greenhouse

gas (GHG) limits on the carbon intensity of the energy used on board ships, and
mandates the use of shore power (onshore power supply or OPS) in EU ports. Apart from
stated exemptions, GHG limits are enacted from 2025 onwards, shore power from 2030
onwards. To ensure decarbonization, increasingly stringent requirements are enforced
for the GHG limits every five years. GHG intensity of energy used on board ships will have
to be reduced by 2% as of 2025, 6% as of 2030, 14.5% as of 2035, 31% as of 2040, 62% as
of 2045 and 80% as of 2050.

FuelEU Maritime takes into account greenhouse gas emissions from CO2, CH4 and N2O
from the entire supply chain ('Well to Wake'), and aims to increase the use of Renewable
and Low-carbon Fuels (RLF) as well as Renewable Fuels from Non-Biological Origin
(RFNBOs), sometimes referred to as e-fuels. These fuels should represent 86-88% of the
international maritime transportation fuel mix by 2050 to contribute to the EU’s targets.
The production and distribution are addressed in the Renewable Energy Directive (RED)
and the Alternative Fuels Infrastructure Regulation (AFIR) respectively. Fuels bought
outside the EU and used onboard are also subject to these regulations.

FuelEU Maritime puts the responsibility for compliance on the shipping company and
applies to all ships of above 5,000 gross tonnage that serve the purpose of transporting
passengers or cargo for commercial purposes, regardless of their flag, arriving at or
departing from EU/EEA ports. Ships subject to FuelEU Maritime are required to monitor
fuel consumption, data and voyage information and report these to an accredited
verifier each year. The verifier calculates greenhouse gas (GHG) intensity for the
reporting year, determines compliance to the regulation and calculates penalties.
Shipowners can mitigate penalties by several means, including banking, borrowing or
pooling. Upon compliance, ships will have to carry a valid FuelEU compliance certificate.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 6
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 7
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

1.2 Legislator and jurisdiction

The European Commission (EU) is the main legislative body responsible for FuelEU
Maritime. In the European Parliament, the Committee on Transport and Tourism (TRAN)
led the work on this regulation.

FuelEU Maritime will be enforced from the 1st of January 2025 onwards, with the exception
of Articles 8 and 9, which will apply from 31 st of August 2024. FuelEU Maritime applies to
European waters and ports.

In addition to the FuelEU Maritime legislation, the Renewable Energy Directive (RED)
legislation and EU Monitoring, Reporting and Verification (MRV) Regulation are
important, as these are used to determine specific properties of biofuels and penalties
in the FuelEU legislation and the reporting and monitoring conditions specifically.

• FuelEU - Regulation (EU) 2023/1805 of the European Parliament and of the Council
on the use of renewable and low-carbon fuels in maritime transport, and amending
Directive 2009/16/EC - COM(2021) 562 14.7.2021 2021/0210(COD).
• RED - Directive 2023/2413 on the promotion of the use of energy from renewable
sources.
• EU MRV - Regulation 2015/757 – on the monitoring, reporting and verification of
carbon dioxide emissions from maritime transport, and amending Directive
2009/16/EC.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 8
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

1.3 Requirements
Broadly speaking, FuelEU Maritime requirements consist of:

(1) Provisions setting a limit of GHG intensity [gCO2 eq / MJ] of energy used on board
FuelEU Maritime puts the responsibility for compliance on the shipping company. Ships
subject to FuelEU Maritime are required to monitor fuel consumption, data and voyage
information as per their FuelEU Monitoring and Reporting Plan. The shipowner is required
to report this information each year to an accredited verifier as per their FuelEU Report.
Data collected by EU MRV Regulations is to be used when carrying out FuelEU Maritime
calculations and reporting. The verifier calculates greenhouse gas (GHG) intensity for
the reporting year, determines (non-)compliance to the regulation and calculates
penalties. Failure to comply with the regulations means a shipping company exceeds
the GHG intensity limit set for that reporting year. In that case, the shipping company is
obliged to pay a penalty for the excess. The GHG intensity limit will be strengthened
every five years: 2% as of 2025, 6% as of 2030, 14.5% as of 2035, 31% as of 2040, 62% as of
2045 and 80% as of 2050 in comparison to a reference value of 91.16 [gCO 2eq/MJ].

Annual GHG intensity can be calculated on a shipping company basis (fleet-wide), or

even between two or more shipping companies, provided they are administered by the
same verifier. In this scenario, if a ‘surplus’ of GHG compliance budget exists for one
vessel, it can be transferred to another ship(s) for the same reporting year. This practice
is called pooling. Additionally, ships may use banking or borrowing to mitigate penalties.

(2) Provisions mandating the use of shore power (onshore power supply / OPS)
Containerships and passenger ships at berth in an EU port will be required to connect
to an onshore power supply (OPS) or use other zero-emission technologies as of
January 1st, 2030 for all electricity while moored in EU/EEA ports. Exemptions will be
allowed in certain emergency situations, or for ships at berth for under two hours, and
specific non-AFIR ports.

Figure 2. FuelEU Maritime GHG intensity reductions are strengthened every five years, leading to an intensity
reduction of 80% by 2050. GHG intensity limits are determined in article 4 of the FuelEU Maritime regulation.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 9
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

GHG Intensity requirements

• Shipowner is required to make a FuelEU Monitoring Plan.
• Shipowner is required to report yearly data to verifier in FuelEU Report.
• Calculation and approval is performed by verifier or Recognized Organization (RO).
• GHG intensity limit is strengthened every five years, from 2% in 2025 to 80% in 2050 1.
• Shipowner can ‘pool’ ships, ‘bank’ or ‘borrow’ budget in order to mitigate penalties.

Shore Power requirements

• Containerships and passenger ships are required to connect to shore power.

FuelEU Monitoring and Reporting Plan requirements

• In accordance with the framework of reporting under EU MRV.
• Ship type, name, IMO number, shipowner and information of the shipping company.
• Sources of energy used on board while in navigation and at berth.
• Procedures for monitoring the fuel consumption of each fuel type.
• Procedures for monitoring departure and arrival ports, including date and time.
• Procedures for monitoring Well to Tank and Tank to Wake emission factors of energy.
• Standards and characteristics of shore power or a zero-emissions technology.
• Value of the established total electrical power demand of the ship at berth.
• Shall be updated and assessed by verifier as appropriate 2.

FuelEU Report requirements

• Departure and arrival ports, including date and time.
• Amount of fuel used while at berth and at sea.
• Amount of electricity supplied to the ship using shore power (OPS).

Verifier requirements
• Calculate yearly average GHG intensity of the energy used on board.
• Calculate GHG intensity emissions and balance, including RFNBO usage.
• Calculate number of non-compliant port calls for the use of shore power (OPS).

1
The limit is calculated using a reference value of 91,16 grams of CO2 equivalent per MJ, see FuelEU article 4.
2
E.g. when changing owner, after refits, when new types of fuels are used etc.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 10
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

Table 1. Timeline of yearly process for FuelEU Maritime.

Date Requirement

Shipping company is required to submit a FuelEU Monitoring Plan to the verifier,

which sets out the methods of monitoring and reporting the amount of energy (fuel
type and consumption) used by ships during voyages and at berth. Ships calling
2024 August 31 an EU/EEA port for the first time after 31st of August 2024 are required to submit a
FuelEU Monitoring Plan to the verifier within two (2) months of that port call. The
Monitoring Plan is assessed for the conformity with the requirements before the
monitoring period starts and then recorded in the FuelEU database by the verifier.

All data and information defined in the FuelEU Monitoring plan is to be recorded
2025 January 1
from this date onwards.

All data and information recorded from the previous reporting years shall be
2026 January 31
submitted to the verifier as a FuelEU Report for each ship.

Shipping company shall record banking, borrowing and pooling – as necessary –

2026 April 30
in the FuelEU database after the FuelEU Report is verified and recorded.

2026 June 30 Shipping company receives a FuelEU Document of Compliance of the ship, issued
Compliance by verifier, if company meets the provisions of the GHG intensity and use of OPS.

2026 June 30 Shipping company shall pay necessary amount of penalty before date. Upon
Non-compliance confirmation of payment, company receives a FuelEU Document of Compliance.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 11
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

1.4 Applies to …
FuelEU Maritime applies to all ships of above 5,000 gross tonnage that serve the purpose
of transporting passengers or cargo for commercial purposes, regardless of their flag,
arriving at or departing from EU/EEA ports from 2025 onwards. Shore power (OPS)
requirements apply to containerships and passenger ships in AFIR ports from 2030.

The requirements would apply to the energy used during the stay within a port in the
EU, the energy used on voyages between two EU ports, half of energy used on voyages
departing from or arriving in ports located in EU outermost regions and half of energy
used on voyages between an EU port and a third-country port.

GHG Intensity
• All ships of above 5,000 GT regardless of flag in EU.
• January 1st 2025 onwards.

Shore power
• Containerships and passenger ships over 5,000 GT.
• January 1st 2030 onwards for AFIR ports.

Figure 3. Application of FuelEU Maritime and the amount of fuel used when calculating GHG intensity from
different ports.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 12
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

1.5 Exemptions and exceptions

Exemptions are subject to verification by the competent authority (verifier) of the
member state of the port of call or any duly authorized entity, after consulting relevant
entities where appropriate.

GHG intensity
• Warships, naval auxiliaries, fish-catching or fish-processing ships, wooden ships of
a primitive build, ships not propelled by mechanical means, or government ships
used for non-commercial purposes are exempt.
• For voyages departing from or arriving at non-EU ports or ports in outermost regions
of the Union, 50% of fuel onboard is used in calculations.
• GHG intensity of Renewable Fuels of Non-Biological Origin (RFNBO) are halved (see
calculations). This measure applies until the 31st December 2033.
• Ships having ice class IC, IB, IA, IA Super or equivalent may exclude additional energy
consumption due to sailing in ice conditions until the 31st of December 2034.
• Certain voyages between member state ports and ports of the same member state
located in an island with fewer than 200,000 permanent residents are exempt.
• Member states may exempt voyages between a port of call located in an outermost
region and another port of call located in an outermost region.

Shore power
• Shore power only applies to containerships and passenger ships.
• Non-AFIR ports start from 1st January 2035.
• Port calls less than 2 hours are excluded.
• Ships using zero-emission technologies when moored are excluded 3.
• Unscheduled calls for safety or saving life at sea are excluded.
• Exceptional risk to grid stability or emergency situations are excluded.
• Unavailability to connect to a shore power connection in port.
• Ships that require the use of onboard power generation for maintenance or
functional testing for survey or inspection.

3
These include fuel cells, batteries, wind or solar power.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 13
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

2.0 CALCULATING FUELEU MARITIME

 FuelEU Maritime calculations consist of GHG intensity (2.1) and penalties (2.2).
 Full formula for GHG Intensity calculation can be found in Annex I of the regulation.
 Full formula for penalties calculation can be found in Annex IV of the regulation.
 WtT and LCV values and assumptions for biofuels and RFNBOs are provided in (2.3).
 Skip the reading and use the quickscan to determine your intensity and penalties.

2.1 GHG Intensity calculation

GHG intensity of a ship is calculated by summing the Well to Tank emissions of the fuels
used onboard (WtT) with the Tank to Wake emissions of the fuels used (TtW). This is
multiplied by a reward factor from to wind-assisted propulsion, if installed on board.

The GHG intensity unit is “grams of CO2 equivalent per MJ energy used on board”.
Greenhouse gasses (GHGs) covered by FuelEU Maritime are carbon dioxide (CO2)
methane (CH4) and nitrous oxide (N2O). The emissions from these different GHGs are
converted into CO2 equivalent emissions for each type of fuel used on board. The sum
of these parts is the total GHG intensity of the ship. GHG intensity is thus independent of
fuel consumption in case only a single fuel is used, and a weighted average in case
multiple fuels are used.

The full formula as per FuelEU Maritime regulations is designated as Equation (1), which
is shown in Figure 4. The three different parts are explained in the subsequent sections.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 14
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

2.1.1

2.1.2

2.1.3

Figure 4. GHG Intensity formula as taken from FuelEU Maritime regulation, Annex I. It is referred to as Equation
(1) in the regulation. Explanation of terms and notations is provided in Appendix 5.2. Click on the paragraph
blocks for an explanation of the respective parts.

Figure 5. To illustrate the calculations, a containership is used as a benchmark throughout the guide. Use the
FuelEU quickscan to determine and validate these values yourself.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 15
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

2.1.1 Well to Tank

The formula and containership benchmark are provided in the tables to the right. It
should be noted that:

• The mass of fuel shall be determined using the amount reported in accordance with
the framework of the reporting under EU MRV Regulations for voyages within the
scope of FuelEU based on the monitoring methodology chosen by company.
• FuelEU Maritime Annex I states that for the purposes of the regulation, the sum of the
shore power energy consumed multiplied by the CO2-eq. emission factor in the
numerator shall be set to zero.
• CO2 equivalent WtT and lower caloric values (LCV) are elaborated in 2.2.2.
• No shore power energy (Ek) has been consumed for this example.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 16
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

Well to Tank formula

Containership benchmark

12,000,000,000 * 13.500 * 0.0405 + 1,400,000,000 * 14.400 * 0.0427

= 13.6

12,000,000,000 * 0.0405 * 1.0 + 1,400,000,000 * 0.0427 * 1.0

Main Aux

Fuel type HFO Fuel type MDO

Fuel consumption 12,000 mT per year Fuel consumption 1,400 mT per year

Well to Tank Well to Tank

CO2eq WtT 13.500 gCO2eq / MJ CO2eq WtT 14.400 gCO2eq / MJ

LCV 0.0405 MJ / gFuel LCV 0.0427 MJ / gFuel

RWD 1.0 RWD 1.0

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 17
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

2.1.2 Tank to Wake

The formula and containership benchmark are provided in the tables to the right. It
should be noted that:

• The mass of fuel shall be determined using the amount reported in accordance with
the framework of the reporting under EU MRV Regulations for voyages within the
scope of FuelEU based on the monitoring methodology chosen by company.
• GWP values are 1 for CO2, 28 for CH4 and 265 for N2O as per EU Regulation 2022/996.
• Slip only applies to LNG engines.
• Lower calorific values (LCV) are elaborated in 2.2.2.
• No shore power energy (Ek) has been consumed for this example.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 18
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

Tank to Wake formula

Containership benchmark

120,000,000,000 * 3.163 + 14,000,000,000 * 3.255

= 77.9
120,000,000,000 * 0.0405 * 1.0 + 14,000,000,000 * 0.0427 * 1.0

Main Aux

Fuel type HFO Fuel type MDO

Fuel consumption 12,000 mT per year Fuel consumption 1,400 mT per year

CO2eq WtT 13.500 gCO2eq / MJ CO2eq WtT 14.400 gCO2eq / MJ

LCV 0.0405 MJ / gFuel LCV 0.0427 MJ / gFuel

Tank to Wake Tank to Wake

CO2eq TtW 3.163 gCO2eq / gFuel CO2eq TtW 3.255 gCO2eq / gFuel

Cf (CO2) 3.1140 gCO2 / gFuel Cf (CO2) 3.2060 gCO2 / gFuel

Cf (CH4) 0.00005 gCH4 / gFuel Cf (CH4) 0.00005 gCH4 / gFuel

Cf (N2O) 0.00018 gN2O / gFuel Cf (N2O) 0.00018 gN2O / gFuel

GWPCO2 1

GWPCH4 28

GWPN2O 265

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 19
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

2.1.3 Wind-assisted propulsion

Wind-assisted propulsion is the practice of using sails or foils to assist in propulsion of
the ship and hence reduce fuel consumption. Where wind-assisted propulsion is
installed on board, a reward factor can be applied, determined as per the formula on
the right. It should be noted that:

• PWind is the available effective power of the wind-assisted propulsion systems and
corresponds to feff * Peff as calculated in accordance with the 2021 guidance on
treatment of innovative energy efficiency technologies for calculation and
verification of the attained energy efficiency design index (EEDI) and energy
efficiency existing ships index (EEXI) (MEPC.1/Circ.896);
• PProp is the propulsion power of the ship and corresponds to PME as defined in the 2018
guidelines on the method of calculation of the attained EEDI for new ships (IMO
resolution MEPC.364(79)) and the 2021 guidelines on the method of calculation of
the attained EEXI (IMO resolution MEPC.333(76)). Where shaft motor(s) are installed,
PProp = PME + PPTI(i),shaft.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 20
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

Reward factor wind

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 21
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

2.2 Penalty calculation

The principles of FuelEU penalties are laid down in article 23(2) of the FuelEU Maritime
regulation. The calculation and formulas of said penalties and compliance balance are
provided in Annex IV.

The FuelEU Maritime penalty consists of a penalty for the GHG intensity, an RFNBO
subtarget and a shore power penalty for non-compliant port calls. These three parts of
the penalty are elaborated upon in the subsequent sections. It should be noted that
after payment, a company is compliant with FuelEU regulation.

2.2.1 GHG Intensity penalty

If the actual GHG intensity of the ship exceeds the GHG target of the reporting year as
validated by verifier, a penalty is imposed on the shipping company. This penalty is
calculated by dividing the absolute ‘compliance balance’ by the actual GHG intensity,
multiplied by a penalty factor. The compliance balance is derived by taking the
difference between the actual GHG intensity and the GHG intensity target, multiplied by
the amount of energy used on board of the ship. Combining these to formulas leads to
a simplified formula for calculating FuelEU penalties, shown below. It should be noted
that:

• If a ship has a compliance deficit for two consecutive reporting periods or more, that
amount shall be multiplied by 1 + (n -1)/10, where n is the number of consecutive
reporting periods for which the company is subject to a FuelEU penalty for that ship.
• Pooling, borrowing and banking have not been taken into account in this example.

Figure 6. Simplified formula for the calculation of FuelEU penalties.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 22
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

GHG intensity penalty formula

For terms and notations, check Appendix 5.4.

Containership benchmark

89.34 - 91.50 2,400

* ( 120,000,000,000 * 0.0405 + 14,000,000,000 * 0.0427 ) * = € 753,617
91.50 41,000

Check Appendix 5.5 for a complete overview of penalties from 2025 to 2050.

Input Output

GHG target 89.34 gCO2eq / MJ Compl. Balance -1,177,933,296 [gCO2eq]

GHG actual 91.50 gCO2eq / MJ FuelEU Penalty € 753,617 [€ / year]

Fuel consumption 12,000 HFO mT per year

Fuel consumption 1,400 MDO mT per year

LCV HFO 0.0405 MJ / gFuel

LCV MDO 0.0427 MJ / gFuel

Shore power E k 0 MJ per year

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 23
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

2.2.2 RFNBO Subtarget

Article 5(3) states the incorporations of an ‘RFNBO subtarget’, which refers to the
requirement for ships to use a certain percentage of Renewable Fuels of Non-Biological
Origin (RFNBO) in their yearly energy usage on board. The subtarget states that if the
share of RFNBO in the yearly energy used on board by ships is less than 1% for the
reporting period of 2031, a subtarget of 2% shall apply for such fuels in the yearly energy
used on board by a ship from 1 January 2034. This subtarget does not apply if the
monitoring results available before 1 January 2033 demonstrate that the share of RFNBO
is already more than 2%. If a ship has a compliance deficit for the subtarget for RFNBO
as referred to in Article 5(3), the FuelEU penalty shall be calculated in accordance with
the formula specified in Part B of Annex IV. Due to its uncertain nature, far ahead in the
future, this penalty has not been taken into account in the FuelEU Quickscan.

2.2.3 Shore power penalty

The administering State in respect of a company shall ensure that for any of its ships
which made at least one non-compliant port call, after a possible validation by its
competent authority, the company shall pay by 30 June of the verification period an
amount equal to the FuelEU penalty resulting from the multiplication of € 1.50 by the
established total electrical power demand of the ship at berth in kW, and by the total
number of hours rounded up to the nearest whole hour, spent at berth by the ship in
non-compliance with the requirements set out in Article 6. This penalty has not been
included in the FuelEU Quickscan or the calculations, as the nature and amount of non-
compliant port calls cannot be determined upfront.

It can be calculated however that the penalty for a non-compliant port call is €1,500
per hour with a power demand of 1,000 kW, or €36,000 per day.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 24
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

2.3 GWP, WtT and LCV values

FuelEU Maritime describes three different types of fuel, each which its own subset of
requirements, Well to Tank values and lower calorific values (LCVs) to be used when
calculating GHG intensity. These three different fuel types are fossil, biofuels and RFNBO
(Renewable Fuels of Non-Biological Origin). Requirements of these fuel types are
elaborated upon in Annex I. Default values are provided in Annex II. Sustainable Ships
adheres to default values where possible, but does assume some values in the case
default values have been emitted by regulation. The specific input numbers used for all
calculations are shown to the right. It should be noted that:

• In the case of fossil fuels, only the default values contained in Annex II shall be used.
• For biofuels and RFNBOs, actual values as described under the Renewable Energy
Directive (RED) methodology may be used.
• Global Warming Potential (GWP) values used for all calculations are taken from EU
Regulation 2022/996 and are 1 for CO2, 28 for CH4 and 265 for N2O.
• NOTE - The regulation states that “unless a value is demonstrated in accordance
with Article 10, the highest default value of the fuel class in the same column shall
be used”. If uphold to by the letter of the law, this practice will lead to significant
errors. For example, as e-DME or e-LPG do not have a stated LCV value, the highest
default value is to be used, which is H2 at 0.12 MJ per gram fuel. This is physically
incorrect and can subsequently lead to large errors. In order to obtain GHG intensity
numbers and penalties that will be more aligned with reality, Sustainable Ships has
in the cases where specific numbers are omitted, assumed values that are believed
to most closely match typical values. To make sure your assumptions are correct,
always talk to your fuel supplier or verifier when using biofuels or RFNBOs.

2.3.1 Calculation of WtT for Biofuels

To calculate WtT values for liquid biofuels, the value “E” needs to be established in
accordance with the methodologies laid down in RED Directive (EU) 2018/2001. E is
defined as the ‘total emissions from the use of the fuel, which is based on the particular
biofuel and its production pathway, as laid down in RED and elaborated upon in
Appendix 5.3. However, the values of E need to be adjusted by subtracting E with the
CfCO2 divided by LCV. This is required under this FuelEU, which separates the WtT and the
TtW calculations, to avoid double counting of emissions. This applies to all biofuels
except bio-H2.
.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 25
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

Table 2. This table is the default fuel and emission factors table used by Sustainable Ships for calculating GHG
intensity, taken from Annex II of the FuelEU Maritime regulation and RED where possible. In particular with
regards to the pathways for the actual LCVs and WtT values can vary significantly. Always check with fuel
supplier or verifier for the correct numbers as per the biofuels or RFNBO certificates.
Pathway name Fuel Class LCV E CO2eq WtT Fuel Consumer Unit Class Cf (CO2) Cf (CH4) Cf (N2O) Cslip

- - MJ / gFuel gCO2eq / MJ gCO2eq / MJ g / gFuel g / gFuel g / gFuel %

HFO Fossil 0.0405 - 13.5 ALL ICEs 3.114 0.00005 0.00018 0

LFO Fossil 0.0410 - 13.2 ALL ICEs 3.151 0.00005 0.00018 0

MDO Fossil 0.0427 - 14.4 ALL ICEs 3.206 0.00005 0.00018 0

MGO Fossil 0.0427 - 14.4 ALL ICEs 3.206 0.00005 0.00018 0

LNG Otto - Medium Speed

Fossil 0.0491 - 18.5 LNG Otto (dual fuel medium
2.750speed) 0 0.00011 3.1

LNG Otto - Slow Speed Fossil 0.0491 - 18.5 LNG Otto (dual fuel slow2.750
speed) 0 0.00011 1.7

LNG Diesel - Slow SpeedFossil 0.0491 - 18.5 LNG Diesel (dual fuel slow
2.750
speed) 0 0.00011 0.2

LNG - LBSI Fossil 0.0491 - 18.5 LBSI 2.750 0 0.00011 2.6

LPG Fossil 0.0460 - 7.8 ALL ICEs 3.000 0.00005 0.00018 0

H2 Fossil 0.1200 - 132 Fuel cells & ICEs 0.000 0 0.00018 0

NH3 Fossil 0.0186 - 121 Fuel cells & ICEs 0.000 0 0.00018 0

Methanol Fossil 0.0199 - 31.3 ALL ICEs 1.375 0 0.00018 0

Ethanol Biofuels 0.0270 35.4 -35.4 ALL ICEs 1.913 0.00005 0.00018 0

Bio-diesel Biofuels 0.0370 27.3 -49.3 ALL ICEs 2.834 0.00005 0.00018 0

HVO Biofuels 0.0440 37.4 -33.4 ALL ICEs 3.115 0.00005 0.00018 0

Bio-LNG Otto - Medium Speed

Biofuels 0.0500 30.0 -25.0 LNG Otto (dual fuel medium
2.750speed) 0 0.00011 3.1

Bio-LNG Otto - Slow Speed

Biofuels 0.0500 30.0 -25.0 LNG Otto (dual fuel slow2.750
speed) 0 0.00011 1.7

Bio-LNG Diesel - Slow Speed

Biofuels 0.0500 30.0 -25.0 LNG Diesel (dual fuel slow
2.750
speed) 0 0.00011 0.2

Bio-LNG - LBSI Biofuels 0.0500 30.0 -25.0 LBSI 2.750 0 0.00011 2.6

Bio-methanol Biofuels 0.0200 13.4 -55.4 ALL ICEs 1.375 0 0.00018 0

Other Biofuels 0.0410 24.9 -51.1 ALL ICEs 3.115 0.00005 0.00018 0

Bio-H2 Biofuels 0.1200 - 30.0 Fuel cells & ICEs 0.000 0 0.00018 0

e-diesel RFNBO 0.0427 - 27.3 ALL ICEs 3.206 0.00005 0.00018 0

e-methanol RFNBO 0.0199 - 13.4 ALL ICEs 1.375 0.00005 0.00018 0

e-LNG Otto - Medium Speed

RFNBO 0.0491 - 30.0 LNG Otto (dual fuel medium
2.750speed) 0 0.00011 3.1

e-LNG Otto - Slow SpeedRFNBO 0.0491 - 30.0 LNG Otto (dual fuel slow2.750
speed) 0 0.00011 1.7

e-LNG Diesel - Slow Speed

RFNBO 0.0491 - 30.0 LNG Diesel (dual fuel slow
2.750
speed) 0 0.00011 0.2

e-LNG - LBSI RFNBO 0.0491 - 30.0 LBSI 2.750 0 0.00011 2.6

e-H2 RFNBO 0.1200 - 30.0 Fuel cells & ICEs 0.000 0 0.00018 0

e-NH3 RFNBO 0.0186 - 30.0 Fuel cells & ICEs 0.000 0 0.00018 0

e-LPG RFNBO 0.0460 - 30.0 3.000 0.00005 0.00018 0

e-DME RFNBO 0.2880 - 30.0 1.910 0.00005 0.00018 0

1. Values in red are N/A values as per the regulation where possible, or assumed to closely match reality otherwise.
2. Values in blue are TBM values as per the regulation where possible, or assumed to closely match reality otherwise.
3. Where a cell indicates either TBM or N/A, the regulation originally requires that unless a value is demonstrated in
accordance with Article 10, the highest default value of the fuel class in the same column shall be used. Sustainable
Ships has deviated from this practice in some regards, as non-sensical results would be achieved, such as an LCV of
0.12 MJ per gram for e-LPG and e-DME or methane slip for non-methane fuels. Again, always check these values with
your verifier and fuel supplier!
4. LCV values as prescribed in RED, these may not (!) concur with FuelEU values. WtT values as described by RED. Typical
values are adopted of the first available pathway described in RED. LNG is not prescribed in RED and requires your
supplier and verifier to validate numbers. In these cases, an average of all available numbers are assumed.
5. Values assumed equal to biofuels – this is an incorrect assumption (!) but it is required to determine intensity and
penalties. These values can be adjusted in the FuelEU Quickscan.
6. Bio-LNG is not mentioned in RED, therefore the average typical and default values of all different biofuels are used. Check
with verifier to ensure numbers are correct.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 26
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

3.0 IMPACT OF FUELEU MARITIME

 Penalty for the containership benchmark are €753k per year in 2025.
 After payment, a company is considered compliant with FuelEU regulation.
 Mitigation options are refits, change of fuel, banking, borrowing and pooling.
 Use the FuelEU Quickscan to determine the cost impact for your own vessel.

3.1 Compliance and non-compliance

Compliancy to FuelEU Maritime means (1) ship GHG intensity actual is lower than GHG
intensity target of the reporting year or (2) payment of penalties.

Non-compliancy to FuelEU Maritime means that your ship GHG intensity actual is higher
than the GHG intensity target of the reporting year. In this case the shipping company,
manager or bareboat charterer who has assumed responsibility for the operation of the
ship from the shipowner, is obliged to pay a penalty for the excess. The company shall
remain responsible for the payment of FuelEU penalties, without prejudice to any
contractual agreements with commercial operators of the ship or client. After payment,
the company is deemed to comply with the regulation.

3.2 Penalties costs

For the containership benchmark, the yearly penalties in a business as usual scenario
are shown in Table 3. The costs for this scenario will increase dramatically over time.
Starting at €753,617, penalties rise to millions of euros from 2030 onwards due to an
increase in reduction factor as well as the penalty multiplier for multiple years of
compliance balance deficit.

Mitigation options to reduce these costs include refits, fuel change, banking, borrowing
and pooling, each described in the subsequent sections.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 27
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

Table 3. Penalties over time in a business as usual scenario for the containership benchmark, with 12,000 mT
HFO consumption and 1,400 mT MDO consumption per year.

Reduction Factor GHG Intensity Target Compliance balance Penalty Penalty multiplier

- gCO2eq / MJ gCO2eq € / year -

2025 2.0% 89.34 -1,177,933,296 € 753,617 1

2026 2.0% 89.34 -1,177,933,296 € 828,978 1.1

2027 2.0% 89.34 -1,177,933,296 € 904,340 1.2

2028 2.0% 89.34 -1,177,933,296 € 979,702 1.3

2029 2.0% 89.34 -1,177,933,296 € 1,055,063 1.4

2030 6.0% 85.69 -3,168,065,488 € 3,040,291 1.5

2031 6.0% 85.69 -3,168,065,488 € 3,242,977 1.6

2032 6.0% 85.69 -3,168,065,488 € 3,445,663 1.7

2033 6.0% 85.69 -3,168,065,488 € 3,648,349 1.8

2034 6.0% 85.69 -3,168,065,488 € 3,851,035 1.9

2035 14.5% 77.94 -7,397,096,396 € 9,465,009 2

2036 14.5% 77.94 -7,397,096,396 € 9,938,259 2.1

2037 14.5% 77.94 -7,397,096,396 € 10,411,510 2.2

2038 14.5% 77.94 -7,397,096,396 € 10,884,760 2.3

2039 14.5% 77.94 -7,397,096,396 € 11,358,011 2.4

2040 31.0% 62.90 -15,606,391,688 € 24,961,591 2.5

2041 31.0% 62.90 -15,606,391,688 € 25,960,055 2.6

2042 31.0% 62.90 -15,606,391,688 € 26,958,518 2.7

2043 31.0% 62.90 -15,606,391,688 € 27,956,982 2.8

2044 31.0% 62.90 -15,606,391,688 € 28,955,446 2.9

2045 62.0% 34.64 -31,029,916,176 € 59,556,835 3

2046 62.0% 34.64 -31,029,916,176 € 61,542,063 3.1

2047 62.0% 34.64 -31,029,916,176 € 63,527,291 3.2

2048 62.0% 34.64 -31,029,916,176 € 65,512,519 3.3

2049 62.0% 34.64 -31,029,916,176 € 67,497,747 3.4

2050 80.0% 18.23 -39,985,511,040 € 89,536,569 3.5

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 28
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

3.3 Mitigation options and costs

There are several ways to mitigate non-compliance or penalties. These can be divided
into five options:

1. Refits
2. Fuel change
3. Banking
4. Borrowing
5. Pooling

Ultimately, the trick is to combine all different options – including the business as usual
scenario where penalties are paid for compliance – in order to derive the cheapest
possible scenario to comply for your ship(s). These options, including some case
studies with reference material will be made available in soon.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 29
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

3.3.1 Refits
Refits that prevent the combustion of speed for the same output of work, effectively
improve your greenhouse gas intensity rating and will thus reduce penalties. The
Decarbonizer can be used freely to determine the impact for several types of refits on
your vessel.

The most important options for any vessel, in particular containership and passenger
ships, are arguably shore power and wind-assisted propulsion, as these will result in
additional benefits when calculating GHG intensity. These two are elaborated upon in
the subsequent sections.

Figure 7. Use the Decarbonizer to determine mitigation options and adjust ship and technology parameters.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 30
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

Shore Power
Estimated CAPEX costs for the containership are in the order of €740k excluding design
and engineering. With an average of 10,000 kWh consumed per day while moored, this
will lead to a reduction in penalties of approximately €181k, which in turn leads to a
payback rate of approximately 4 years. This example does not include a reduction of
fuel consumption due to the use of shore power, so the savings might actually be higher.

Shore Power

CAPEX € 740,000

kWh consumption 10,000 kWh per day when moored

Shore power days 90 days

MJ Ek 3,240,000 MJ input for FuelEU

FuelEU penalty savings - € 181,234

Wind-assisted propulsion
Assuming 100 kW of effective power per sail with 8 sails, the total effective maximum
propulsion power is 800 kW. With a main engine of 15,000 kW assumed, P Wind / Pprop is
0.053, leading to a reward factor of 0.99. Even with no (!) fuel consumption reduction,
this will lead to savings of €314k, resulting in a payback time of 7 years. This example
does not include a reduction of fuel consumption due to the use of shore power, so the
savings might actually be higher.

Wind-assisted propulsion

CAPEX Estimate € 2,233,000

Reward factor 0.99

FuelEU penalty savings - € 314,607

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 31
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

3.3.2 Fuel change

Apart from more standard refits to improve fuel efficiency, the most impacting measure
to reduce GHG intensity and avoid penalties is to change your fuel. The FuelEU Maritime
regulations lists 32 different fuels (or pathways), with three distinct fuel types: fossil,
biofuels and RFNBO (Renewable Fuels of Non-Biological Origin).

Each of these types of fuels will ensure compliance until a certain timeframe. For
example, the use of HFO and MDO will generally result in a penalty as per 2025, LNG not
until 2035. Pending on the specific pathway 4, penalties can be avoided until 2040 or
beyond.

Figure 6 highlight the most important fuels and their estimated GHG intensity. Table 4
shows which fuels ‘should last’ until which year, i.e. should lead to a GHG intensity lower
than GHG intensity target. These tables should provide guidance for determining which
fuel is compliant to the FuelEU regulation the longest. For a complete table of
timeframes for all different fuel types, refer to Appendix 5.5. It should be noted that:

• For biofuels and RFNBOs, multiple pathways are available which do not always have
to impact GHG intensity positively, see section 2.3.
• Except for biofuels, most fuels will incur a CAPEX cost when a vessel is refitted to
accommodate this type of fuel (engine refit, piping, tanks, etc.). This is included in
the Decarbonizer for several general types of fuels.
• To promote the use of renewable fuels of non-biological origin (RFNBOs), FuelEU
includes a 'multiplier' to be used when calculating the GHG intensity, in effect
allowing the energy from RFNBOs to count twice, which makes RFNBOs highly
attractive until the multiplier is adjusted (not expected before 2031).
• A single ‘green’ ship with a very low GHG intensity can be pooled to compensate for
other ships in your fleet. Check section 3.3.5 for more information.

4
More specifically the Well to Tank emissions as determined in RED, see section 2.3.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 32
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

Figure 8. Overview of GHG intensity of different fuels and the corresponding limits for different time periods.
Source: ClassNK. Check Appendix 5.5 for all different FuelEU fuel pathways with Sustainable Ships’
assumptions and calculations.

Table 4. This table shows until when a fuel type would be considered compliant (lower than GHG intensity
target) as per the current FuelEU regulations. It is the year you would start paying fines in a business as usual
scenario. For LNG, it depends on the type of engine. Check the appendix for all specific fuel pathways.

Main fuels compliance ‘expiration’ years

HFO 2025

MDO 2025

LNG 2035

Biofuels 2025-2040

RFNBOs 2040-2050

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 33
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

3.3.3 Banking5
Banking refers to the ability of a company to carry forward a compliance surplus to the
following reporting period in order to offset future compliance deficits. It allows
companies to strategically manage their compliance and avoid penalties for non-
compliance in a particular year. Once the FuelEU document of compliance is issued, the
company can no longer bank any surplus.

• Banking is specific to the individual ship's compliance balance and cannot be

transferred to other ships within the company.
• Banking for two consecutive reporting periods is not allowed.

More information on banking will be made available soon.

5
Banking is explained in article 20 of the FuelEU Maritime regulation.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 34
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

3.3.4 Borrowing6
Borrowing refers to the ability of a company to borrow an advance compliance surplus
from the following reporting period if the ship has a compliance deficit for the current
reporting period. This allows the company to offset the deficit by using a surplus from
the next reporting period. The advance compliance surplus shall be added to the ship’s
compliance balance in the current reporting period and the advance compliance
surplus - multiplied by 1.1 - shall be subtracted from the same ship’s compliance
balance in the following reporting period.

• Borrowing is not allowed when a ship is participating in a pool.

• Borrowing is specific to a single ship's compliance balance and cannot be
transferred to other ships within the company.
• A compliance surplus may not be borrowed for two consecutive reporting periods.
• A compliance surplus may not exceed more than 2% of the intensity limit of the year,
multiplied by the energy consumption of the ship.

More information on borrowing will be made available soon.

6
Borrowing is explained in article 20 of the FuelEU Maritime regulation.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 35
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

3.3.5 Pooling7
Pooling under FuelEU Maritime refers to the practice of combining the compliance
balances of multiple ships to meet the regulations' requirements and incentivize
investment in advanced technologies. It requires calculating compliance balances,
registering ships' intentions to participate in a pool, and selecting a verifier.

A pool is valid only if the total pooled compliance balance is positive, if ships which had
a compliance deficit do not have a higher compliance deficit after the allocation of the
pooled compliance, and if ships which had a compliance surplus do not have a
compliance deficit after the allocation of the pooled compliance. Furthermore it should
be noted that for the same reporting period:

• Borrowing is not allowed when pooling.

• Pooling can be set up by two or more shipping companies.
• A ship’s compliance balance may not be included in more than one pool.

More information on pooling will be made available soon.

7
Pooling is explained in article 21 of the FuelEU Maritime regulation.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 36
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

4.0 FREQUENTLY ASKED QUESTIONS

1. Use the Regulator AI to ask and clarify questions not stated here.

4.1 What is FuelEU Maritime?

FuelEU Maritime is part of the Fit for 55 package directed at shipping. A key proposal,
FuelEU, aims to decarbonize the EU maritime sector by promoting low-carbon fuels and
mandating the use of shore power in EU ports. Key points of the FuelEU Maritime
regulation include:

• Greenhouse Gas (GHG) Limits: Starting in 2025, ships must reduce their GHG
intensity progressively, with specific reduction targets set for every five years until
2050.
• Shore Power: Mandatory use of shore power in ports starts in 2030.
• GHG Emissions Scope: Emissions from CO2, CH4, and N2O are considered across the
entire supply chain ('Well to Wake').
• Fuel Targets: By 2050, 86-88% of maritime fuels should be Renewable and Low-
carbon Fuels (RLF) or Renewable Fuels from Non-Biological Origin (RFNBOs).
• Regulation Coverage: Applies to ships over 5,000 gross tonnage used for
commercial purposes at EU/EEA ports, regardless of their flag.
• Compliance and Reporting: Shipping companies must monitor and report fuel
consumption and voyage data annually. Compliance is assessed, and penalties
can be mitigated through various means, including banking, borrowing, or pooling
of compliance credits.
• Supporting Regulations: Production and distribution of fuels are covered by the
Renewable Energy Directive (RED) and the Alternative Fuels Infrastructure
Regulation (AFIR).

In summary, the FuelEU Maritime regulation is a comprehensive effort to reduce the

carbon footprint of the EU maritime sector through stringent GHG limits, the adoption of
renewable fuels, and the use of shore power, with robust compliance and reporting
mechanisms in place.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 37
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

4.2 How is FuelEU Maritime calculated?

The formula to calculate ‘GHG intensity’ as stated by the FuelEU Maritime is stated in
Annex I of the regulation, and explained in detail in chapter 2.0 of this guide. In short:

GHG intensity of a ship is calculated by summing the Well to Tank emissions of the fuels
used onboard (WtT) with the Tank to Wake emissions of the fuels used (TtW). This is
multiplied by a reward factor from to wind-assisted propulsion, if installed on board.

The GHG intensity unit is “grams of CO2 equivalent per MJ energy used on board”.
Greenhouse gasses (GHGs) covered by FuelEU Maritime are carbon dioxide (CO2)
methane (CH4) and nitrous oxide (N2O). The emissions from these different GHGs are
converted into CO2 equivalent emissions for each type of fuel used on board. The sum
of these parts is the total GHG intensity of the ship. GHG intensity is thus independent of
fuel consumption in case only a single fuel is used, and a weighted average in case
multiple fuels are used.

4.3 To which ship types does FuelEU Maritime apply?

FuelEU Maritime applies to all ships of above 5,000 gross tonnage that serve the purpose
of transporting passengers or cargo for commercial purposes, regardless of their flag,
arriving at or departing from EU/EEA ports.

The requirements would apply to the energy used during the stay within a port in the
EU, the energy used on voyages between two EU ports, half of energy used on voyages
departing from or arriving in ports located in EU outermost regions and half of energy
used on voyages between an EU port and a third-country port.

GHG Intensity
• All ships of above 5,000 GT regardless of flag in EU.
• January 1st 2025 onwards.

Shore power
• Containerships and passenger ships over 5,000 GT.
• January 1st 2030 onwards for AFIR ports.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 38
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

4.4 Which vessels are exempt from FuelEU Maritime?

Exemptions are subject to verification by the competent authority (verifier) of the
member state of the port of call or any duly authorized entity, after consulting relevant
entities where appropriate.

Exempt ship types

Warships, naval auxiliaries, fish-catching or fish-processing ships, wooden ships of a
primitive build, ships not propelled by mechanical means, or government ships used for
non-commercial purposes are exempt.

More exemptions
• For voyages departing from or arriving at non-EU ports or ports in outermost regions
of the Union, 50% of fuel onboard is used in calculations.
• GHG intensity of Renewable Fuels of Non-Biological Origin (RFNBO) are halved (see
calculations). This measure applies until the 31st December 2033.
• Ships having ice class IC, IB, IA, IA Super or equivalent may exclude additional energy
consumption due to sailing in ice conditions until the 31st of December 2034.
• Certain voyages between member state ports and ports of the same member state
located in an island with fewer than 200,000 permanent residents are exempt.
• Member states may exempt voyages between a port of call located in an outermost
region and another port of call located in an outermost region.
• Shore power only applies to containerships and passenger ships.
• Non-AFIR ports start from 1st January 2035.
• Port calls less than 2 hours are excluded.
• Ships using zero-emission technologies when moored are excluded 8.
• Unscheduled calls for safety or saving life at sea are excluded.
• Exceptional risk to grid stability or emergency situations are excluded.
• Unavailability to connect to a shore power connection in port.
• Ships that require the use of onboard power generation for maintenance or
functional testing for survey or inspection.

8
These include fuel cells, batteries, wind or solar power.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 39
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

4.5 How does FuelEU Maritime work?

Broadly speaking FuelEU Maritime requirements consist of:

1) Provisions setting a limit of GHG intensity [gCO2 eq / MJ] of energy used on board.
Shipping companies will need to calculate emissions per unit of energy used on
board, based on their reported fuel consumption and the emissions factors of their
respective fuels.
2) Provisions mandating the use of shore power (onshore power supply / OPS) or zero-
emission technology in port for containerships and passenger ships for all power
while moored while in EU/EEA port.

FuelEU Maritime puts the responsibility for compliance on the shipping company. Ships
subject to FuelEU Maritime are required to monitor fuel consumption, data and voyage
information as per their FuelEU Monitoring and Reporting Plan. The shipowner is required
to report this information yearly to an accredited verifier as per their FuelEU Report.
According to Annex I of the regulation, data collected by EU MRV Regulations is to be
used when carrying out FuelEU Maritime calculations and reporting. The verifier
calculates greenhouse gas (GHG) intensity for the reporting year, determines (non-)
compliance to the regulation and calculates penalties. This process is repeated yearly
as per the schedule shown below.

Failure to comply with the regulations means a shipping company exceeds the GHG
intensity limits. In this case the shipping company is obliged to pay a penalty for the
excess, after which the company is deemed to comply with the regulation.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 40
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

4.6 What is banking, borrowing, pooling?

Banking, borrowing and pooling provide flexibility for companies to balance out their
compliance over time and avoid penalties for non-compliance in a particular year.
More information and examples can be found in section 3.3.

Banking refers to the ability of a company to carry forward a compliance surplus to the
following reporting period in order to offset future compliance deficits. It allows
companies to strategically manage their compliance and avoid penalties for non-
compliance in a particular year. Banking is specific to the individual ship's compliance
balance and cannot be transferred or applied to other ships within the company.
Banking for two consecutive reporting periods is not allowed. Once the FuelEU
document of compliance is issued, the company can no longer bank any surplus.

Borrowing refers to the ability of a company to borrow an advance compliance surplus

from the following reporting period if the ship has a compliance deficit for the current
reporting period. This allows the company to offset the deficit by using a surplus from
the next reporting period. The advance compliance surplus shall be added to the ship’s
compliance balance in the current reporting period and the advance compliance
surplus - multiplied by 1.1 - shall be subtracted from the same ship’s compliance
balance in the following reporting period. A compliance surplus may not be borrowed
for two consecutive reporting periods, or for an amount exceeding more than 2% of the
intensity limit of the year, multiplied by the energy consumption of the ship. Borrowing
is specific to a single ship's compliance balance and cannot be transferred to other
ships within the company. Borrowing is not allowed when a ship is participating in a
pool.

Pooling under FuelEU Maritime refers to the practice of combining the compliance
balances of multiple ships to meet the regulations' requirements and incentivize
investment in advanced technologies. It requires calculating compliance balances,
registering ships' intentions to participate in a pool, and selecting a verifier. A pool is
valid only if the total pooled compliance balance is positive, if ships which had a
compliance deficit do not have a higher compliance deficit after the allocation of the
pooled compliance, and if ships which had a compliance surplus do not have a
compliance deficit after the allocation of the pooled compliance.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 41
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

4.7 Is shore power required under FuelEU Maritime?

Containerships and passenger ships at berth in an EU/EEA port will be required to
connect to an onshore power supply (OPS) as of January 1st, 2030 for AFIR ports.

Exemptions are subject to verification by the competent authority (verifier) of the

member state of the port of call or any duly authorized entity, after consulting relevant
entities where appropriate. These exemptions are outlined in the introductory articles of
the FuelEU regulations, i.e. (5) ships that:

a) Are moored at the quayside for less than 2 hours, calculated on the basis of time of
arrival and time of departure monitored and recorded in accordance with Article 15;
b) use zero-emission technologies which comply with the general requirements for
such technologies provided for in Annex III and are listed and specified in the
delegated and implementing acts adopted in accordance with paragraphs 6 and
7 of this Article, for all their electrical power demand at berth, while moored at the
quayside;
c) due to unforeseen circumstances beyond the control of the ship, have to make an
unscheduled port call, which is not made on a systematic basis, for reasons of safety
or saving life at sea, other than those already excluded under article 3, point (10);
d) are unable to connect to OPS due to the unavailability of OPS connection points in a
port;
e) are unable to connect to OPS because exceptionally the electrical grid stability is at
risk, due to insufficient available shore-power to satisfy the ship’s required electrical
power demand at berth;
f) are unable to connect to OPS because the shore installation at the port is not
compatible with the onboard on-shore power equipment, provided that the
installation for shore-connection on board the ship is certified in accordance with
the technical specifications set out in annex II to Regulation (EU) 2023/1804 for the
shore-connection systems of seagoing ships;
g) for a limited period of time, require the use of onboard energy generation, under
emergency situations representing immediate risk to life, the ship or the
environment or for other reasons of force majeure;
h) while remaining connected to OPS, for a period of time limited to what is strictly
necessary, require the use of onboard energy generation for maintenance tests or
for functional tests carried out at the request of an officer of a competent authority
or the representative of a recognized organization (RO) undertaking a survey or
inspection.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 42
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

4.8 How are FuelEU Maritime penalties calculated?

The principles of FuelEU penalties and the compliance balance of a ship are laid down
in article 23(2) of the FuelEU Maritime regulation. The calculation and formulas of said
penalties and compliance balance are provided in annex IV. In a nutshell, penalties can
be calculated as follows.

The compliance balance per ship is calculated by multiplying the total amount of
energy used in the reporting year with the difference of the GHG intensity target and
actual achieved GHG intensity. In case of a negative balance, FuelEU penalties are
determined by dividing the balance with the actual achieve GHG intensity times 41,000
and multiplying this with 2,400.

Figure 9. Formulas to calculate compliance balance and penalties for FuelEU, taken from Annex IV of the
regulation. Check section 3.2 on cost and penalties for more information.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 43
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

4.9 What are the consequences of failing to pay the FuelEU Maritime penalty?
According to Article 23(2) of the FuelEU regulation, if a ship has a compliance deficit and
the company fails to pay the penalty by the specified deadline for two or more
consecutive reporting years, the competent authority of EU/EEA member state of the
port of call becomes responsible that the company pays the penalty

If a company does not pay the penalty within the designated time, the competent
authority may remove the FuelEU document of compliance for that ship from the FuelEU
database. Because the FuelEU regulation does not explicitly describe the consequences
beyond the removal of the Document of Compliance, enforcement may be based on
existing instruments and could involve legal action or additional penalties. This could
include a so-called expulsion order, in which every member state shall refuse entry of
the ship which is subject to the expulsion order into any of its port until the company
fulfills its obligations. Because there is no precedent for this legislation, it remains
unclear at the time of writing.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 44
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

4.10 Who will enforce FuelEU Maritime?

The EU Commission will implement an electronic database to register the performance
and compliance of each ship. Verifiers are responsible to calculate penalties and issue
the documents of compliance.

Shipping companies are responsible for monitoring the type and amount of energy
used in operation and at berth. They must submit to verifiers a standardized emissions
monitoring plan for each of their vessels by August 31, 2024. Their records must contain
the WtW emissions factors for each type of fuel used at berth and at sea. At the end of
April each year, shipping companies will need to submit their data, including that
already reported for MRV regulation.

Verifiers will assess each monitoring plan and calculate the yearly average GHG
intensity of a ship’s onboard energy, use of OPS, and its reflection of yearly targets. The
verifier will issue a document of compliance, which must be kept onboard all ships
calling at an EU port until the end of that reporting period.

4.11 When will FuelEU Maritime take effect?

January 1st, 2025. The requirement of having a FuelEU Monitoring Plan will enter into
effect on the 31st August 2024. The shore power requirement for containerships and
passenger ships take into effect on the 1st of January 2030 for AFIR ports.

4.12 What happens with the revenues generated by FuelEU Maritime?

The regulation stresses that the revenues generated from FuelEU penalties are to be
used to support the rapid deployment and use of renewable and low-carbon fuels in
the maritime sector. How exactly this is done, is still uncertain.

4.13 How is GHG calculated for FuelEU when biofuels are used?
Biofuels will need to fall under the Renewable Energy Directive (RED) in order to receive
a bonus in GHG reduction calculation. In case the biofuels used on board are certified
under RED, measured GHG intensity of the Well to Tank part of that biofuel can be used.
In case the biofuels do not fall under RED and are not certified as such, they are
considered to have the same emission factors as the least favourable fossil fuel
pathway for that type of fuel. For the Tank to Wake part, measured values can also be
used if they are certified by means of laboratory testing or direct emission
measurements. When this is not the case, default values specified in RED should be
used. More information on this topic is provided in section 2.3 of the guide.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 45
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

4.14 What does RFNBO mean in the context of FuelEU Maritime?

RFNBO stands for Renewable Fuels of Non-Biological Origin. These fuels are produced
from renewable sources without using biological materials such as crops or biomass.
RFNBO fuels are typically made using renewable electricity and carbon captured from
non-biological sources. They have high sustainability potential, can significantly reduce
carbon emissions, and offer a viable alternative to fossil fuels. The RFNBOs defined as
per the FuelEU Maritime Regulation are:

RFNBOs

e-diesel e-methanol

e-DME e-H2

e-LNG e-NH3

e-LPG

4.15 What is the RFNBO subtarget for FuelEU Maritime?

Article 5(3) states the incorporations of an ‘RFNBO subtarget’, which refers to the
requirement for ships to use a certain percentage of Renewable Fuels of Non-Biological
Origin (RFNBO) in their yearly energy usage on board. The subtarget states that if the
share of RFNBO in the yearly energy used on board by ships is less than 1% for the
reporting period of 2031, a subtarget of 2% shall apply for such fuels in the yearly energy
used on board by a ship from 1 January 2034. This subtarget does not apply if the
monitoring results available before 1 January 2033 demonstrate that the share of RFNBO
is already more than 2%. If a ship has a compliance deficit for the subtarget for RFNBO
as referred to in Article 5(3), the FuelEU penalty shall be calculated in accordance with
the formula specified in Part B of Annex IV.

4.16 How will Carbon Capture and Storage affect FuelEU Maritime GHG calculation?
This is still unclear. The current regulation states that:

"In the event of technological progress concerning new GHG abatement technologies,
such as onboard carbon capture, the Commission should assess the possibility to
reflect, in the GHG intensity and compliance balance formulas set out in Annexes I and
IV respectively, the contribution of such technologies to lowering the GHG direct
emissions on board ships."

Most likely, the EU CCS Directive or other legislation would need to be followed in order
to reduce GHG intensity. At this point in time however, this is speculation.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 46
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

4.17 What is still uncertain?

(2024 May) A lot. In the EU Parliament, a number of areas are under discussion,
including:

• The need to clearly delineate between the authorities who verify fuel composition
and the authorities in charge of levying fines.
• How responsibility will be split between owner and charterer.
• The role of LNG as a transitional fuel.
• The risks of making shore power mandatory in all situations.
• Problems of cost and competition.
• FuelEU Database has nod yet been completed.
• Calculation of GHG intensity when using Carbon Capture and Storage (CCS).

The shipping industry has raised concerns about additional cost for maritime
transportation. It remains to be seen if this price increase can be deferred to clients.
Shipowners are also concerned that FuelEU Maritime is inconsistent with EU ETS. They
have also cast doubt on the ambition level of the yearly targets.

In addition, FuelEU verifiers will need to spread over an extensive network to be able to
check intra- and extra-EU voyages. They will also need high levels of knowledge and
seniority and have their impartiality attested to by accreditors.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 47
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

5.0 APPENDIX

5.1 References

EU FuelEU Maritime Directive Regulation 2023/1805 Document 32023R1805

EU RED Directive 2023/2413 - promotion of energy from renewable sources

EU EU MRV Regulation 2015/757 - monitoring, reporting and verification

EU EU Regulation 2022/996 - rules to verify sustainability and GHG saving criteria

EU EU Regulation 2023/2449 – template for monitoring plan and emissions report

EU FuelEU legislation in progress briefing

ClassNK FuelEU FAQs

ECSA FuelEU Maritime Workship

CE Delft Impact of FuelEU on Dutch maritime sector

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 48
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

5.2 GHG Intensity terms and notations

Terms and notations for the GHG intensity formula are provided in Annex I of the FuelEU
Maritime regulation. The below is an excerpt shown as convenience.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 49
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

5.3 RED biofuels tables

The Well to Tank GHG intensity and lower caloric values (LCVs) of biofuels are
determined in the Renewable Energy Directive, Part C of Annex V, Part B of Annex VI and
Annex III. The below methodology, formulas, tables and numbers are used by
Sustainable Ships as a reference for all calculations. As default, only emissions from
extraction or cultivation, processing, transport and distribution have been taken into
account. Emissions due to annualised carbon stock changes cause by land-use
change, soil carbon accumulation via improved agricultural management, or savings
due to carbon capture and storage have not been taken into account.

Always check with your verifier all certificates of Well to Tank GHG intensity to ensure
correct values are used in the calculations of FuelEU penalties.

Figure 10. GHG intensities [gCO22eq / MJ] formula as per RED Annex V. Line items with a cross are not included
in Sustainable Ships’ default calculations. The eu factor equals the Tank to Wake aspect of emissions, i.e. the
combustion of the fuel onboard.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 50
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

Table 5. Biofuel pathways and consequent total greenhouse gas emissions due to extraction, processing,
transport and distribution of the biofuel used in Sustainable Ships calculations, taken from EU RED.

Greenhouse gas emissions Greenhouse gas emissions

Biofuel and bioliquid production pathway Fuel type
Typical value Default value

gCO2eq / MJ gCO2eq / MJ

sugar beet ethanol (no biogas from slop, natural gas as process fuel in conventional boiler) 30.7 38.2 Ethanol

sugar beet ethanol (with biogas from slop, natural gas as process fuel in conventional boiler) 21.6 25.5 Ethanol

sugar beet ethanol (no biogas from slop, natural gas as process fuel in CHP plant(*)) 25.1 30.4 Ethanol

sugar beet ethanol (with biogas from slop, natural gas as process fuel in CHP plant(*)) 19.5 22.5 Ethanol

sugar beet ethanol (no biogas from slop, lignite as processfuel in CHP plant (*)) 39.3 50.2 Ethanol

sugar beet ethanol (with biogas from slop, lignite as pro cess fuel in CHP plant(*)) 27.6 33.9 Ethanol

corn (maize) ethanol (natural gas as process fuel in con ventional boiler) 48.5 56.8 Ethanol

corn (maize) ethanol, (natural gas as process fuel in CHP plant(*)) 42.5 48.5 Ethanol

corn (maize) ethanol (lignite as process fuel in CHP plant(*)) 56.3 67.8 Ethanol

corn (maize) ethanol (forest residues as process fuel in CHP plant(*)) 29.5 30.3 Ethanol

other cereals excluding maize ethanol (natural gas as pro cess fuel in conventional boiler) 50.2 58.5 Ethanol

other cereals excluding maize ethanol (natural gas as pro cess fuel in CHP plant(*)) 44.3 50.3 Ethanol

other cereals excluding maize ethanol (lignite as process fuel in CHP plant(*)) 59.5 71.7 Ethanol

other cereals excluding maize ethanol (forest residues as process fuel in CHP plant(*)) 30.7 314 Ethanol

sugar cane ethanol 28.1 286 Ethanol

rape seed biodiesel 45.5 50.1 Bio-diesel

sunflower biodiesel 40 44.7 Bio-diesel

soybean biodiesel 42.2 47 Bio-diesel

palm oil biodiesel (open effluent pond) 63.5 75.7 Bio-diesel

palm oil biodiesel (process with methane capture at oil mill) 46.3 51.6 Bio-diesel

waste cooking oil biodiesel 11.2 14.9 Bio-diesel

animal fats from rendering biodiesel (**) 15.3 20.8 Bio-diesel

hydrotreated vegetable oil from rape seed 45.8 50.1 HVO

hydrotreated vegetable oil from sunflower 39.4 43.6 HVO

hydrotreated vegetable oil from soybean 42.2 46.5 HVO

hydrotreated vegetable oil from palm oil (open effluent pond) 62.2 73.3 HVO

hydrotreated vegetable oil from palm oil (process with methane capture at oil mill) 44.1 48 HVO

hydrotreated oil from waste cooking oil 11.9 16 HVO

hydrotreated oil from animal fats from rendering (**) 16 21.8 HVO

pure vegetable oil from rape seed 38.5 40 Other

pure vegetable oil from sunflower 32.7 34.3 Other

pure vegetable oil from soybean 35.2 36.9 Other

pure vegetable oil from palm oil (open effluent pond) 56.3 65.4 Other

pure vegetable oil from palm oil (process with methane capture at oil mill) 38.4 57.2 Other

pure oil from waste cooking oil 2 2.2 Other

wheat straw ethanol (2016+) 13.7 15.7 Ethanol

waste wood Fischer-Tropsch diesel in free-standing plant (2016+) 13.7 13.7 Bio-diesel

farmed wood Fischer-Tropsch diesel in free-standing plant (2016+) 16.7 16.7 Bio-diesel

waste wood Fischer-Tropsch petrol in free-standing plant (2016+) 13.7 13.7 Other

farmed wood Fischer-Tropsch petrol in free-standing plant (2016+) 16.7 16.7 Other

waste wood dimethylether (DME) in free-standing plant (2016+) 13.5 13.5 Other

farmed wood dimethylether (DME) in free-standing plant (2016+) 16.2 16.2 Other

waste wood methanol in free-standing plant (2016+) 13.5 13.5 Bio-Methanol

farmed wood methanol in free-standing plant (2016+) 16.2 16.2 Bio-Methanol

Fischer-Tropsch diesel from black-liquor gasification inte grated with pulp mill (2016+) 10.2 10.2 Bio-diesel

Fischer-Tropsch petrol from black-liquor gasification inte grated with pulp mill (2016+) 10.4 10.4 Bio-diesel

dimethylether (DME) from black-liquor gasification inte grated with pulp mill (2016+) 10.2 10.2 Other

Methanol from black-liquor gasification integrated with pulp mill (2016+) 10.4 10.4 Bio-Methanol

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 51
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

Table 6. Biofuel lower calorific values (LCVs) used in Sustainable Ships calculations, taken from EU RED.

Energy content by weight Energy content by weight

Biofuel and bioliquid production pathway Fuel type
(lower calorific value, MJ/kg) (lower calorific value, MJ/l)

[MJ / g] [MJ / l]

Bio-Propane 0.046 0.024 Other

0.037
Pure vegetable oil (oil produced from oil plants throughpressing, extraction or comparable procedures, crude or re-fined 0.034
but chemically unmodified) Other

Biodiesel - fatty acid methyl ester (methyl-ester producedfrom oil of biomass origin) 0.037 0.033 Bio-diesel

Biodiesel - fatty acid ethyl ester (ethyl-ester produced fromoil of biomass origin) 0.038 0.034 Bio-diesel

Biogas that can be purified to natural gas quality 0.050 - Bio-LNG

Hydrotreated (thermochemically treated with hydrogen) oil of biomass origin, to be used for replacement of diesel
0.044 0.034 HVO

Hydrotreated (thermochemically treated with hydrogen) oil of biomass origin, to be used for replacement of petrol
0.045 0.030 Other

Hydrotreated (thermochemically treated with hydrogen) oil of biomass origin, to be used for replacement of jet fuel
0.044 0.034 Other

Hydrotreated oil (thermochemically treated with hydrogen) of biomass origin, to be used for replacement of liquefied
0.046 petroleum gas 0.024 Other

Co-processed oil (processed in a refinery simultaneouslywith fossil fuel) of biomass or pyrolysed biomass origin0.043
tobe used for replacement of diesel
0.036 Bio-Diesel

Co-processed oil (processed in a refinery simultaneouslywith fossil fuel) of biomass or pyrolysed biomass origin,0.044
tobe used to replace petrol 0.032 Other

Co-processed oil (processed in a refinery simultaneouslywith fossil fuel) of biomass or pyrolysed biomass origin,0.043
tobe used to replace jet fuel 0.033 Other

Co-processed oil (processed in a refinery simultaneouslywith fossil fuel) of biomass or pyrolysed biomass origin,0.046
tobe used to replace liquefied 0.023
petroleum gas Other

Methanol from renewable sources 0.020 0.016 Bio-methanol

Ethanol from renewable sources 0.027 0.021 Ethanol

Propanol from renewable sources 0.031 0.025 Other

Butanol from renewable sources 0.033 0.027 Other

Fischer-Tropsch diesel (a synthetic hydrocarbon or mixtureof synthetic hydrocarbons to be used for replacement
0.044
of diesel) 0.034 Bio-Diesel

Fischer-Tropsch petrol (a synthetic hydrocarbon or mixtureof synthetic produced from biomass, to be hydrocarbons
0.044
used for replacement of petrol)
0.033 Other

0.044
Fischer-Tropsch jet fuel (a synthetic hydrocarbon or mix-ture of synthetic hydrocarbons produced from biomass, 0.033
tobe used for replacement of jet fuel) Other

0.046
Fischer-Tropsch liquefied petroleum gas (a synthetic hydro-carbon or mixture synthetic hydrocarbons, to be used of for replacement of liquefied0.024
petroleum gas Other

DME (dimethylether) 0.028 0.019 Other

Hydrogen from renewable sources 0.120 - Bio-H2

ETBE (ethyl-tertio-butyl-ether produced on the basis of ethanol) 36 (of which 37 % from re-newable
27 (of
sources) Other
which 37 % from re-newable sources)

MTBE (methyl-tertio-butyl-ether produced on the basis of methanol) 35 (of which 22 % from re-newable
26 (of
sources) Other
which 22 % from re-newable sources)

TAEE (tertiary-amyl-ethyl-ether produced on the basis of ethanol) 38 (of which 29 % from re-newable
29 (of
sources) Other
which 29 % from re-newable sources)

TAME (tertiary-amyl-methyl-ether produced on the basisof methanol) 36 (of which 18 % from re-newable
28 (of
sources) Other
which 18 % from re-newable sources)

THxEE (tertiary-hexyl-ethyl-ether produced on the basis of ethanol) 38 (of which 25 % from re-newable
30 (of
sources) Other
which 25 % from re-newable sources)

THxME (tertiary-hexyl-methyl-ether produced on the basisof methanol) 38 of which 14 % from re-newable

30 sources) Other
(of which 14 % from re-newable sources)

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 52
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

5.4 GHG Intensity penalty terms and notations

More information on the formulas and calculation on FuelEU penalties can be found in
Annex IV of the FuelEU regulation.

Figure 11. Formulas to calculate compliance balance and penalties for FuelEU, taken from Annex IV of the
regulation.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 53
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

5.5 Fuel change compliance years

The below table shows the year in which it is expected the specific fuel will cause a
penalty, i.e. will results in a GHG intensity actual that is higher than the GHG intensity
target. For biofuels and RFNBOs, it is important to ensure the Well to Tank emissions and
lower calorific values (LCVs) are correctly stated, otherwise no valid claims can be
made. It should be noted that the GHG intensities are for a single fuel only and will
deviate when multiple fuels are used. Biofuels E values are based on the averages of all
pathways if known, or the average of all biofuels if unknown. RFNBOs include a reward
factor of 2. Use the FuelEU Quickscan for more customization options.

Figure 12. This figure shows the provisional GHG intensity of fuel types identified by the FuelEU Maritime
regulation calculating using the assumptions as taken from Table 2.

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 54
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.
 FuelEU Maritime Guide v. 2024-08-07 Contact Helpdesk

Table 7. Fuel types and pathways including WtT, TtW and WtW values which lead to a ‘compliance year’, an
indication of until when usage of the fuel would result in a GHG intensity actual that is lower than the GHG
intensity target. Especially with regards to the different biofuels and RFNBO pathway options, WtT values can
change significantly. Always check your pathway with verifier to ensure correct numbers are used.

Pathway name Fuel Class CO2eq WtT incl. RWD CO2eq TtW incl. slip CO2eq WtW Compliance year

- - gCO2eq / MJ gCO2eq / MJ gCO2eq / MJ Estimate!

HFO Fossil 13.50 78.10 91.60 2025

LFO Fossil 13.20 78.05 91.25 2025

MDO Fossil 14.40 76.23 90.63 2025

MGO Fossil 14.40 76.23 90.63 2025

LNG Otto - Medium Speed

Fossil 18.50 72.53 91.03 2025

LNG Otto - Slow Speed Fossil 18.50 65.33 83.83 2035

LNG Diesel - Slow SpeedFossil 18.50 57.63 76.13 2040

LNG - LBSI Fossil 18.50 69.96 88.46 2030

LPG Fossil 7.80 66.28 74.08 2040

H2 Fossil 132.00 0.40 132.40 2025

NH3 Fossil 121.00 2.56 123.56 2025

Methanol Fossil 31.30 71.49 102.79 2025

Ethanol Biofuels 35.44 72.67 37.26 2045

Bio-diesel Biofuels 27.25 77.92 28.58 2050

HVO Biofuels 37.37 71.91 38.49 2045

Bio-LNG Otto - Medium Speed

Biofuels 29.98 71.22 46.20 2045

Bio-LNG Otto - Slow Speed

Biofuels 29.98 64.16 39.14 2045

Bio-LNG Diesel - Slow Speed

Biofuels 29.98 56.59 31.57 2050

Bio-LNG - LBSI Biofuels 29.98 68.70 43.68 2045

Bio-methanol Biofuels 13.37 71.14 15.76 2050+

Other Biofuels 24.85 77.17 26.05 2050

Bio-H2 Biofuels 29.98 0.40 30.38 2050

e-diesel RFNBO 13.625 38.12 51.74 2045

e-methanol RFNBO 6.685 35.78 42.47 2045

e-LNG Otto - Medium Speed

RFNBO 14.99 36.26 51.25 2045

e-LNG Otto - Slow SpeedRFNBO 14.99 32.67 47.66 2045

e-LNG Diesel - Slow Speed

RFNBO 14.99 28.81 43.80 2045

e-LNG - LBSI RFNBO 14.99 34.98 49.97 2045

e-H2 RFNBO 14.99 0.20 15.19 2050+

e-NH3 RFNBO 14.99 1.28 16.27 2050+

e-LPG RFNBO 14.99 33.14 48.13 2045

e-DME RFNBO 14.99 3.40 18.39 2045

Liability Disclaimer - Sustainable Ships will not be held responsible for any damages that could arise from using information provided in this report, on its platform or 55
by any of its crew. All numbers are indicative and subject to change, no rights can be derived from this study. View all terms and conditions here.