Infrastructure Briefing — September 30, 2025
Maritime operators covered by the EU Emissions Trading System must surrender allowances for 2024 voyage emissions by the first compliance deadline, locking in carbon costs for cargo and passenger routes serving EU ports.
Executive briefing: The first EU Emissions Trading System (EU ETS) compliance deadline for maritime transport lands on September 30, 2025. Shipowners responsible for vessels of 5,000 gross tonnage or above calling at EU ports must surrender allowances covering 40 percent of verified 2024 CO2 emissions as the sector phases into the carbon market.
Key compliance checkpoints
- Verified emissions. Submit 2024 voyage-level emissions reports validated by accredited verifiers to national authorities by March 31, 2025.
- Allowance strategy. Acquire and surrender sufficient EUAs by September 30 to cover the 40 percent obligation, factoring in joint responsibility for time-charter arrangements.
- Data sharing. Maintain records linking bunker delivery notes, monitoring plans, and verifier statements to withstand audits during the first enforcement cycle.
Control alignment
- ISO 14064-1. Align greenhouse-gas inventory controls with ETS monitoring plans to tighten data quality and verification workflows.
- IMO DCS/CII. Harmonise data collection systems so ETS surrender calculations reconcile with IMO carbon intensity reporting obligations.
- IFRS S2. Update climate risk disclosures to show carbon pricing impacts, allowance hedging policies, and route optimisation investments.
Implementation priorities
- Establish EUA procurement committees that coordinate treasury, sustainability, and chartering teams on hedge timing and counterparty risk limits.
- Run scenario modelling on cargo routing, slow steaming, and fuel switching to forecast 2025–2027 allowance requirements as ETS coverage ramps from 40 percent to 100 percent.
Enablement moves
- Launch charter-party renegotiations that clarify cost pass-through for surrendered allowances and penalties for data submission failures.
- Deploy voyage emissions dashboards for operations centres so masters receive near-real-time feedback on carbon intensity and compliance exposure.
Sources
- Directive (EU) 2023/959 amending Directive 2003/87/EC for maritime transport (May 10, 2023)
- European Commission guidance: EU ETS maritime transport (accessed 2024)
Zeph Tech supports shipowners with monitoring plan optimisation, allowance procurement strategies, and governance reporting that prove readiness for the EU ETS maritime compliance cycle.