Newsletter EU ETS Maritime
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Outlook for the rest of 2025 |
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As of 1 April 2025, the NEa began taking enforcement measures to compel shipping companies – that have not yet done so – to submit their verified emission reports and monitoring plans. This process now has our full focus. We are communicating with the ship owners by e-mail and telephone, to make sure that they are aware of their obligations. At this stage, as a means to enforce compliance, the NEa will issue orders subject to penalty. If a shipping company still does not submit its verified emissions reports, the NEa will determine the emissions on its own (ex officio determination). For this year, the NEa will not impose administrative fines. From 2026 onwards, this will change.
On 30 September at the latest, ship owners must surrender the number of emission allowances, based on the verified emissions reports that were handed in via the EU Thetis registry. Thus, all emissions under the EU ETS have to be covered by 30 September 24:00h. Any allowances handed in on 1 October 00:01h or after, result in a fine of approximately 148 euro per ton CO2 that is not covered by allowances. Also, the names of the companies that did not comply will be published.
Important: both the fine and the naming of offenders are determined by EU law. In other words, the NEa does not have any leeway in this. |
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Do you have any questions about the Maritime ETS? Ask them! |
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The NEa is planning to record a Q&A webinar about Maritime ETS in June of this year. In the webinar we would like to answer questions that shipping companies, verifiers and others who are professionally engaged with Maritime ETS grapple with. Since we would like to tailor the webinar as much as possible to your needs, we would like to ask you the following: if you have any questions regarding compliance, allowances, reporting procedures, verification, or any other aspect of the Maritime ETS, we invite you to submit them in advance.
During the webinar, we will address the most frequently asked questions and provide clear, practical guidance to help you prepare for the upcoming obligations.
Please send your questions to info@emissieautoriteit.nl with ‘Questions Q&A webinar Maritime’ as the subject.
You can apply for the webinar itself in a later newsletter.
We look forward to your input and hope to see you at the webinar! |
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Shipping companies pay for CO₂ emissions for the first time
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Dutch and internationally operating shipping companies that are assigned to The Netherlands were recently required to report their CO₂ emissions for the year 2024 through an emissions report. Of the 378 shipping companies assigned to the Netherlands by the European Commission, approximately 60% have met the reporting requirements before the deadline. These companies submitted a verified emissions report to the Dutch Emissions Authority (NEa) by the March 31 deadline.
Since the deadline, an additional 14% of companies have submitted an emissions report. As of April 17, this brings the total compliance rate to 74%.
You can read the whole article here. |
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No MOHA? Apply for one as soon as possible |
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To comply with the 30 September deadline to surrender the number of allowances that is equal to its total and verified emissions for 2024, you must have a Maritime Operator Holding Account (MOHA) in the EU ETS registry. If you do not yet have a MOHA, or have not yet started the application process, we strongly recommend to take action as soon as possible.
Important: please be aware that obtaining a MOHA can take some time. We therefore urge you to submit your application no later than 30 May 2025. If you apply after this date, we cannot guarantee that your account will be in place before the 30 September 2025 deadline.
And please note: this requirement only applies to operators with an obligation for the 2024 emissions year. |
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Temporary measure on zero-rating of biofuels delivered by Dutch fuel suppliers
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On April 5, 2025 the Regeling handel in emissierechten was amended. The changes to it will enable the NEa to implement a temporary measure that allows for parallel claims for the use of sustainable fuel. The amendment will have retroactive effect and apply from 1 January 2024 onwards. It will be in effect until a European interim or Union Database solution is implemented.
The temporary measure applies to those situations where shipping companies have bunkered biofuels supplied by Dutch fuel suppliers and where a Proof of Sustainability (PoS) is not issued to the ship, because the fuel supplier surrenders the PoS to the NEa in order to receive Hernieuwbare Brandstof Eenheden (HBE’s).
For more information, see our previous communication on this matter on the NEa website:
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Update enforcement ETS Maritime
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First and foremost, we would like to express our sincere thanks to all parties for their efforts in meeting the initial deadline for submitting the Company Emissions Report (CER), which passed on 31 March 2025. We greatly appreciate your hard work and commitment, including those who are still finalizing their compliance obligations.
We have noticed that many parties currently have a CER status of ‘verified as satisfactory’. It is important to note that this status does not mean that full compliance has been achieved. As outlined in the e-mail sent on 9 April, there is still an action that needs to be taken: the CER must be submitted to the Administering Authority (AA) via Thetis MRV. In your case the AA is the Dutch Emissions Authority (NEa). We kindly remind all parties who are still in the process of becoming compliant to carefully review the e-mail from 9 April to ensure all steps are completed. If you have any questions regarding our communication from 9 April, please contact us at info@emissieautoriteit.nl.
Although no fines have yet been imposed, the NEa strongly urges you to submit the required CER and MPs as soon as possible via THETIS MRV to the administering authority. Failure to comply will lead to enforcement actions. We encourage all parties still in the process of becoming compliant to do so as quickly as possible.
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Where to find more information?
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