Introduction:

The EU Emission Trading System (EU ETS) has officially completed the first year in the maritime sector with the deadlines for the EUA surrender expired on 30th September of this year. This article revisits the ETS frame work and break down what this all means — minus the regulatory jargon.

The goal of the EU ETS is to cut overall emissions by 62% from 2005 levels by 2030. From 2024 onwards, vessels must surrender Emission Allowances (EUAs) every year for their verified CO₂emissions. The first surrender deadline was 30th September 2025, covering emissions from 2024 voyages.

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How much do you pay?

Not all emissions are taxed equally — itdepends on your voyage type:
- Voyage to the EU: 50% of emissions counted
- Voyage from the EU: 50% of emissions counted
- Voyage within the EU or at berth: 100% of emissions counted
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The taxable percentage rises each year:
- 2024: 40% of emissions
- 2025: 70%
- 2026 onward: 100%

So, 2025 voyages will see 70% of the above emissions considered under ETS.

The 6-Step EU ETS Process:

The process flow that we have used for the vessels under the TECS emission data managemnet unbrella is captrured below :

1.Estimate – Begin by estimating the ETS costs for your upcoming voyage.

2. Voyage – Ensure the estimates are communicated to all stakeholders and documented as part of the voyage costs.

3. Data Collection – Record all voyage consumptions and related evidence.

4. Processing – Prepare and evaluate the voyage data and all supporting documents for submission to Charterers/ Verifiers.

5. Verification – Submit to the verifier for additional validation where required/ Else generate EUA statements

6. EUA Acquisition & Transfer – Basis the EUA statement ,collect the EUA from charterers for addition to your MOHA account.

These individual voyages covered under the MRV scope becomes part of the company emission report at the end of the reposrtaing year basis which the final amount of EUA are submitted from the MOHA to the Administering authority.

Who’s Responsible? Owner or Manager?

By default, the registered shipowner holds ETS responsibility.

However, the owner can delegate this to the ISM Manager through a written mandate submitted toboth the verifier and the administering authority (AA).In short:-

Owner = Responsible by default

Manager = Responsible only if delegated via mandate.

Defining this responsibility in the relationship is key to ensuring that compliance is handled effectively. If the shipowner retains responsibility, the manager must provide verified emission data regularly. If the ISM manageris fully mandated, they handle everything — from monitoring to surrendering EUA allowances. Financial liabilities between both parties are covered separately, typically under the SHIPMAN EU ETS Clause 2023.

Penalties and Compliance Risks

Here’s where things get serious. Failing to surrender your required EUAs means:
- A €100 fine per tonne of CO₂ (adjusted for inflation).
- Still having to surrender the missing allowances.
- Public disclosure of non-compliant companies- potentailly imopacting futuer employemnet of vessels.
- Possible expulsion or detention from EU ports if non-compliance continues
The message is clear: staying compliant isn’t just about money — it’s about staying operational.

SettingUp Your EUA Accounts- the MOHA

You’ will need specific accounts under the Union Registry to manage emissions trading:-

MOHA Account – Mandatory for all ship operators; used for surrendering allowances.

Trading Account – Optional but useful for flexibility in buying/selling EUAs.

Buying EUAs doesn’t need to be complex.Operators can:
- Buy directly with no extra charges.
- Trade spot or futures based on need.
- Hold partial allowances for future voyages.
- Get direct transfer to your MOHA account.

Through years of domain expertise in the emisison data managemnet, in depth understanding of the fluid regulatory frame work and through stratyegic partnership, we at TECS remain capable of providing the end to end services for all your maritime ETS complliance needs.

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