Newsletter EU ETS Maritime

December 2024

Dear contact person,

Through this newsletter EU ETS Maritime, we aim to keep you informed about the (policy) developments and obligations that are relevant to you.

The topics of this newsletter are:

Year-end closing: compliance with obligations concerning emissions over 2024
Starting 2025: MRV obligations for offshore ships and smaller general cargo ships
FuelEU - are you prepared?

Year-end closing: compliance with obligations concerning emissions over 2024

For shipping companies with MRV/ETS obligations, it is important to be aware of the deadlines to comply with your obligations. In the course of 2025 the NEa, the administering authority for The Netherlands, will provide compliance assistance by informing you about the steps you need to take in this process. On our website you will also find other supporting information, such as links to guidances, webinars and tutorials by the EMSA or the European Commission.

For the 16th of January 2025, a webinar is announced on the (new) emissions report functionality in THETIS-MRV and the EU ETS registry. Shipping companies with MRV and ETS obligations should have received an invite per email from the EMSA directly. The webinar will be recorded and published on their website afterwards. For questions related to on-line registration please contact the EMSA Events Team (events@emsa.europa.eu).

Important obligations and deadlines in 2025 are:

Obligation	Deadline	System
Submit a satisfactorily verified emissions report for each ship	March 31st, 2025	THETIS MRV
Submit a satisfactorily verified aggregated emissions report per company	March 31st, 2025	THETIS MRV
Enter the verified emissions figures	March 31st, 2025	EU ETS registry
Have the emissions figures in the registry confirmed by your verifier	March 31st, 2025	EU ETS registry
Surrender the equivalent number of allowances	September 30th, 2025	EU ETS registry

Do you have a Maritime Operator Holding Account?
Shipping companies with MRV/ETS obligations that are attributed to the Netherlands, should have already applied for a Maritime Operator Holding Account (MOHA) in the Dutch part of the EU ETS registry. If you haven’t applied for a MOHA already, please do so as soon as possible, as it will take some time to gather all documents and to process your request.

Are your registrations up to date?
Please note that it is very important to update company information and contact details in both systems: THETIS MRV and EU ETS registry. Especially if there is a change in the mandate of the shipowner to the ISM company, make sure the current responsible entity is represented correctly in both systems.

Non-compliance
In case of non-compliance with the surrender obligation, an EU sanction regime applies. Shipping companies that fail to surrender allowances are liable to an excess emissions penalty of EUR 100 (corrected for inflation) per tonne of CO2 equivalent and are still liable for the surrender of the required allowances. More information on our enforcement policy can be found on our website.

Starting 2025: MRV obligations for offshore ships and smaller general cargo ships

Offshore ships from 400 gross tonnage and above and general cargo ships from 400 to 5.000 gross tonnage are obliged to monitor and report their greenhouse gas emissions as per January 1st, 2025.

This includes the greenhouse gas emissions released during their voyages for transporting for commercial purposes cargo or passengers starting or ending in an EEA port or between EEA ports.
An important obligation is that the companies need to draw up and submit a monitoring plan via THETIS MRV to the verifier for all of these ships, without undue delay and no later than two months after each ship’s first port call in a EEA port.

After positive verification, companies have to submit the monitoring plan to the administering authority without undue delay and no later than three months after each ship’s first port call in an EEA port. The administering authority only receives the monitoring plan but has no role in this process. The administering authority will therefore not assess and approve your monitoring plan regarding these ships.

For further questions please contact the European Commission’s dedicated helpdesk via: fitfor55@emsa.europa.eu

More information can be found on the European Commission website.

FuelEU - are you prepared?

FuelEU aims to drastically reduce onboard greenhouse gas emissions by 2050 and forms a substantive part of the EU’s Fit For 55 package to reduce greenhouse gas emissions from shipping. The FuelEU Maritime Regulation applies from January 1st, 2025, except for the submission of the monitoring plan, which was applicable from August 31st, 2024. The regulation is a complementary obligation to the EU ETS.

For your FuelEU Maritime obligations and deadlines, we refer to the website of the European Commission and the EMSA website. Compliance with the FuelEU Maritime Regulation relies heavily on private supervision by verifiers and the national accreditation bodies.

The Dutch Emissions Authority (NEa) is the competent authority for the following three tasks:

The NEa can perform additional checks on the monitoring plan, the FuelEU report and the verifier's compliance calculations (Article 17)
The NEa collects the FuelEU penalty (where appropriate, the NEa modifies the FuelEU penalty if inaccuracies are found) and then registers the FuelEU compliance document in the FuelEU database (Article 22 and 23)
The NEa decides on a review application when a company disagrees with a decision of the verifier (Article 26)

Where to find more information?

More information on the definition of a shipping company, the obligations and practical information can be found on the NEa website.

For answers to specific questions, please check the FAQ pages of the European Commission and EMSA.

In case your question remains unanswered, you can send an email to our helpdesk.

For questions regarding THETIS MRV, please contact the EMSA via maritimesupportservices@emsa.europa.eu

Kind regards,

The Dutch Emissions Authority