The FuelEU Maritime (FEUM) regulation introduces new complexity to emissions management by shifting reporting responsibility from shipowners to ship managers holding the Document of Compliance (DoC). Unlike the EU Emissions Trading System (EU ETS), FEUM directly impacts contractual and financial relationships between owners, charterers, and independent ship managers.
Since FEUM took effect on January 1, 2025, the DoC holder now carries legal responsibility for emissions reporting and compliance across the full calendar year. This creates challenges where charter periods do not align with compliance cycles, increasing the need for precise cost allocation mechanisms.
Independent ship managers face heightened financial exposure despite having limited control over fuel choice or trading patterns. As a result, charter parties must be carefully amended to ensure liabilities follow the “polluter pays” principle.
Industry bodies such as BIMCO have introduced FuelEU Maritime clauses to help address these issues, though many commercial details still require bespoke negotiation. Clear contractual language is essential to define who bears emissions costs during charter delivery, redelivery, and hypothetical scenarios.
The monetization of emissions is also changing industry dynamics by encouraging closer collaboration between commercial partners. With fuel and emissions penalties potentially doubling fuel costs, transparency and cooperation have become critical.
Trusted emissions data platforms, such as DNV’s Emissions Connect, are emerging as essential tools to support fair cost allocation and informed negotiations. A single, reliable source of emissions data helps align stakeholders and reduce disputes in an increasingly regulated operating environment.
