22 September 2023

CLECAT FEEDBACK ON NON-EU TRANSHIPMENT PORTS IN DRAFT IR ETS MARITIME

On 18 September, CLECAT submitted its feedback to the Commission on the draft Implementing Regulation identifying neighbouring container transhipment ports. According to the recently revised ETS Directive and more specifically the inclusion of maritime emissions into the EU ETS, the Commission has been tasked to draw up a list of non-EU ports close to EU ports and mostly used for transhipments which would be excluded from the definition of port of call. These provisions have been agreed by the co-legislators to reduce the risk of carriers engaging in evasion strategies by calling at neighbouring EU ports to reduce their ETS costs, undermining the effectiveness of the measures.

CLECAT welcomes the inclusion of two ports in the Annex of the draft implementing Regulation (Tanger Med and East Port Said) but warns that more ports would fit the criteria of the ETS Directive to be included in this list over the next months. CLECAT sees here the beginning of a worrying trend of disinvestment in EU ports close to EU borders (especially in the Mediterranean Sea), undermining the connectivity of certain regions of Europe and overall, the EU competitiveness. As a consequence, this could also pose serious operational difficulties for freight forwarders, as more cargo would be transhipped, reducing the number of direct connections and potentially adding delays.

CLECAT therefore calls on the Commission to closely monitor non-EU ports close to EU borders, some of which have the infrastructure capacity to manage higher volume of transhipped containers once the EU ETS will effectively apply as of 2024. In addition, CLECAT estimates that the list should be reviewed every year, as the two-year period set out in the ETS Directive is too long.

Finally, CLECAT calls on the Commission and EU Member States to speed up negotiations at IMO in order to agree on a series of measures to decarbonise the maritime sector at global level. We consider that ambitious global measures are an important solution to effectively decarbonise the sector while avoiding evasion strategies and carbon leakage.