Compliance pooling under the EU’s FuelEU Maritime regulation is proving more complex and potentially more costly than many shipowners initially expected, according to a new whitepaper from Berlin-based digital platform ZERO44.
Since January 2025, vessels trading in European waters have been required to report their fuel consumption and greenhouse gas intensity. Any vessel exceeding the permitted thresholds faces potential penalties of several hundred thousand euros annually. Pooling was introduced as a flexible compliance option that enables operators of less efficient ships to offset their deficits against the surpluses of lower-emission vessels.
The ZERO44 study, FuelEU Maritime: Beyond the Pooling Hype, highlights that surpluses are not created automatically but through costly measures such as biofuel use, onshore power or investments in wind propulsion. These costs are passed through to pooling arrangements, which may make them less attractive compared with alternative compliance pathways.
The regulation sets penalties at €2,400 per tonne of VLSFO equivalent, which equates to around €640/tCO₂eq. This figure acts as a ceiling: paying more than this for surplus credits would be uneconomical. In one example, a vessel with a deficit of 600 tCO₂eq would pay €150,000 if purchasing surplus at €250/tCO₂eq, compared with €384,000 if paying the penalty. However, switching to a biofuel blend (based on an assumed cost of US$850/tonne) could deliver compliance at about €170/tCO₂eq, two-thirds of the cost of pooling. The analysis suggests that while pooling may provide short-term relief, alternative fuel strategies often deliver better value.
ZERO44 also points to challenges in determining value and reliability in the pooling market. Companies must consider governance and regulatory compliance, exposure to volatile prices, and counterparty risk. A vessel may only join one pool per compliance period, pools must demonstrate a net surplus, and participants must trust their counterparties to deliver. Providers that can offer regulatory assurance, price transparency, access to market liquidity and risk management tools are therefore critical.
Beyond external pooling, companies can also explore internal pooling across their own fleets, banking surpluses for future years or borrowing compliance from subsequent years. These options, along with direct investment in alternative fuels, can reduce exposure to price swings and offer greater control over long-term performance. ZERO44 notes that these strategies will become increasingly competitive from 2027, once the EU ETS phase-in is complete and the cost of fossil fuels rises further.
Friederike Hesse, Co-Founder and Managing Director of ZERO44, said: ‘Pooling is no cure-all. Anyone using it should be clear about the price and the partners they engage with. In the long term, strategic fuel decisions often lead to lower costs and greater control.’
Founded in 2022, ZERO44 offers software tools that integrate compliance with FuelEU Maritime, the EU Emissions Trading System and the IMO’s Carbon Intensity Indicator. Its latest analysis underscores that FuelEU compliance decisions now require a clear understanding of abatement costs across all available strategies, positioning pooling as a tactical measure rather than a long-term strategy.
