CASE STUDIES / EU ETS · ANALYSIS · MARCH2026
What ETS compliance really costs per voyage.
Four routes into Rotterdam, four engine types, one formula. Which driver actually moves the bill.
€49K–196K
ONE LADEN VOYAGE INTO GATE · AT €85 PER EUA
One rule, phased in.
01 · THE REGULATION
Since 2024 the EU ETS covers maritime shipping across the EU27 plus Norway, Iceland and Liechtenstein. Every tonne of reported greenhouse gas must be offset with an allowance bought on the market, so the cost of carbon is set by a live index, not a tariff table.
SHARE OF EMISSIONS TO SURRENDER · ALL SCENARIOS HERE USE THE 2026 RULE
Inside the EU and EEA
100%
Both ports in scope, Norway and Iceland included. The whole journey counts.
Into or out of the EU
50%
One port outside the scheme: half the journey emissions are surrendered.
Outside the EU entirely
0%
Non-EU to non-EU voyages stay outside the system.
SHARE OF A JOURNEY THE ETS COUNTS · NON-COMPLIANCE FINE €100/tCO₂e VS. INDEX ~€85
One formula writes the bill.
02 · THE MECHANIC
Fuel consumption
Tonnes of LNG burned on board: engine, speed and distance set the volume.
Emissions factor
LNG emits 2.8 to 3.5 tCO₂e per tonne of fuel, depending on the engine.
EUA price
One allowance offsets one tonne of CO₂e. The index trades between €80 and €90.
Exposure
The share of the journey the ETS counts: 100%, 50% or nothing.
Four voyages into Gate.
03 · THE ROUTES
Same ship on every run: a 174,000 m³ Neopanamax carrying about 3.8 million MMBtu, sailing 16 knots, benchmarked at €85 per EUA. Only the loading port changes.
Snøhvit
€50–80K
ONE-WAY · €90–150K ROUND TRIP
100% EXPOSURE · INTRA EU/EEA
Nigeria LNG
€80–130K
ONE-WAY · €150–250K ROUND TRIP
50% EXPOSURE · NON-EU LEG
Sabine Pass
€90–150K
ONE-WAY · €170–280K ROUND TRIP
50% EXPOSURE · NON-EU LEG
Qatargas
€120–200K
ONE-WAY · €230–370K ROUND TRIP
50% EXPOSURE · VIA SUEZ
Same voyage, four different bills.
04 · THE ENGINE
The engine room decides up to 60% of the bill.
Fuel efficiency and methane slip separate four common engine generations far more than most desks expect. On the Qatar run the spread between the cleanest and the thirstiest engine is €76K, every single voyage.
Diesel DF slow speed · cleanest bill
Otto DF slow speed
LBSI
Otto DF medium speed · highest bill
EFFICIENT VESSELS INCUR LESS COST AND GAIN VALUE ON THE CHARTER MARKET
Two dials the desk watches.
05 · SENSITIVITIES
DIAL 1 · THE EUA INDEX
The cost line is straight: every euro on the allowance flows through the formula unchanged. Sabine Pass to Gate, four engines.
EUA SUPPLY SHRINKS 19% UNTIL 2030 · PRICES LIKELY TO RISE
DIAL 2 · SPEED
From 16 to 19 knots the bill rises about 20%, roughly €20K to €30K per voyage. The dip at 13 knots is the value of arriving sooner.
SABINE PASS → GATE · JOURNEY EMISSIONS ONLY
Per unit traded, distance rules.
06 · THE TRADED UNIT
Broken down to the cargo, carbon rides on distance.
Per traded MMBtu the cost rises almost in proportion to journey length. Snøhvit pays 100% exposure yet lands the cheapest unit cost of all four routes: proximity to Gate beats the exposure rule.
ONE-WAY, AT €85/EUA · ROUND TRIP ROUGHLY DOUBLES THE UNIT COST
07 · THE VERDICT
Tangible, every voyage. But it does not break the bank.
COMPLIANCE COST RELATIVE TO TRADED CARGO VALUE, PER ROUTE
Tighter every year from here.
08 · OUTLOOK
THE CAP
Allowances shrink each year
The emissions cap tightens by 4.3% annually until 2027 and 4.4% from 2028 to 2030, so scarcity is designed into the system.
FUELEU MARITIME
Intensity rules since 2025
A second regime now targets the greenhouse gas intensity of the fuel itself, with penalties and incentives on top of the ETS.
IMO NET ZERO
A global framework is forming
The IMO framework would extend carbon pricing beyond Europe. Its implementation date is still uncertain.
THIS ANALYSIS RAN ON X-LNG
Carbon priced inside the same optimisation that plans your fleet.
X-LNG estimates the compliance cost of journeys and whole portfolios in seconds, so ETS sits in every netback, diversion and charter call rather than in a reconciliation weeks later.