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On 20 March, the European Commission published the results of two studies related to the inclusion of maritime transport into the EU ETS: the first study monitored the implementation of ETS and analyses the risk of ship evasion, and the second study focuses on the possibility to include smaller vessels (between 400 and 5000 GT) into the MRV Regulation and subsequently within the scope of the ETS Directive.

The first study analyses whether the extension of ETS to maritime transport has led to ship evasion behaviour, such as relocating transhipment activities or avoiding calls at EU ports to reduce ETS compliance costs. The analysis, which covers the period from January to September 2024 demonstrates that no concrete evidence of widespread evasive behaviours has been found. While there have been fluctuations in port activities, these changes appear to be largely driven by the geopolitical situation in the Red Sea rather than attempts to evade ETS. The report also notes that there is no significant increase in the use of smaller vessels or ship-to-ship transfers that could indicate evasive practices. However, the Commission acknowledges the limitations of the analysis, due to its short timeframe and the Red Sea crisis largely affecting global shipping trends. Future monitoring exercises should also take the implementation of FuelEU Maritime into account, as well as future trends, patterns, and emerging issues.

In addition, the report further explores the broader impacts of the ETS extension, including its effect on transport costs and essential shipping services. It estimates that the ETS will increase overall shipping costs by an average of 3.7% in 2024, with variations across different vessel categories. The Commission notes that liner operators fully pass ETS costs to their customers via the imposition surcharges, but such surcharges do not necessarily reflect the true EU ETS costs expected on a specific route, taking the example of a 30 EUR/TEU surcharge on the route Asia-North Europe, much higher than the estimated cost of 7-10 EUR/TEU on this route in 2024. While these surcharges are mostly within the range of 1-5% of container freight rates, the analysis shows that there is little transparency to what carriers can impose as surcharges to their customers, with the risk of making a profit over environmental regulations.

The second study reveals that while the direct environmental benefits of including smaller vessels in the MRV regulation are modest, the potential indirect benefits are substantial: the report underscores the administrative challenges and costs associated with expanding the MRV scope, indicating that such costs for shipping companies managing smaller vessels would be similar to or slightly higher than those for larger vessels, with a ratio between administrative costs and coverage of GHG emissions seven times higher for smaller vessels on average. However, the Commission notes that the potential for significant indirect benefits through integration with other GHG mitigation policies, such as the EU Emissions Trading System (ETS) and the FuelEU Maritime regulation, is considerable. The report emphasises the need for further assessment, particularly in the context of the 2026 review of the EU ETS Directive, to fully understand and leverage these potential benefits, while reflecting on other GHG mitigation measures, such as the possible inclusion of smaller vessels into the ETS 2.

CLECAT takes note of these reports and is looking forward to exchanging with the Commission and other stakeholders on the results of both studies at a dedicated meeting next week and discuss the next steps.