ON-DEMAND WEBINAR

HOW WILL THE EU ETS IMPACT COMMERCIAL SHIPPING?

Questions that we did not have time to answer during the webinar:

Q&A

On your carbon calculator - how accurate is your consumption data for each vessel? Have owners provided you with s&c curves or are you modelling expected consumptions?.
The carbon estimator is built on our prediction models that are trained using a vast amount of actual reported consumption and operations data with high granularity. Additional data layers are added and used such as ship specifications, AIS track and weather data. Since we have been collection such data now fleet wide for a number of years, we have seen most ships (or sister ships) and voyages and testing shows that we are industry leading in accuracy.
Who will pay the extra cost (EUA purchases)? Is it the shipowner or the charterer? Are there any regulations in EU ETS that oversee the responsibility for EUA purchases? How are the mechanisms being built around it?
The EU ETS regulations states that it is the shipping company, meaning the ISM manager, that is to provide the required no. of EUAs to the relevant authority. The ISM manager is in most cases the technical manager of the ship and not necessarily the owner or operator of the ship. In the legislation there is stated that the ISM manager shall have the mandate to collect EUA's or be reimbursed the cost for purchase from the charterer. What is not specified in the regulation is the process to do so, nor what kind of sanctions or  penalty there would be if a charterer fails to deliver. Hence, it is left for the industry to solve this, commercially and contractually, in all commodity and chartering deals.
To tag on to the above question. Would you know if the vessel hull is fouled or not? This can have an enormous difference in estimating the theoretical fuel consumption for a voyage.
For ship with improvements beyond what is reflected in the specification variables, such as a recently performed hull cleaning, we offer owners and operators to report emission numbers which in turn will be reflected directly in any estimates provided for Siglar Carbon clients. This way we help market the impact of such investments to potential charterers.
What does mean when nothing appears in the box "EU/ETS eligible" when we are looking at information for a vessel?
The ship finder uses the ballast port, load port and discharge port to determine whether any of the sailing legs and/or port stays are included in the EU ETS. If the EU ETS eligible column displays zero it means that none of the emissions from that voyage would be included in EU ETS.
If a vessel discharges at a port in the EU and sails out to New York to load and go to China to discharge, even with this sailing, are CO2 emission from EU to New York included in EU ETS?
Yes, 50% of the CO2 emissions emitted when sailing from EU to New York would be eligible under EU ETS. Allowances must be delivered for 40 % of the eligible emissions in 2024, 70% in 2025 and 100% in 2026.
It seems that there will be an incentive for vessels to make a port call at Falmouth or Plymouth in the Uk to give a very short ballast leg out of the EU and then an non-EU ETS ballast leg from UK to US for loading the next cargo-wake?
Yes, that is currently true until either UK ETS includes international shipping, or if EU starts imposing 100% of emissions for extra-EU voyages as well. However, including an additional port call also comes with a significant cost, both with regards to port costs and additional vessel cost due to increased voyage duration.
Let's assume a vessel has done two consecutive  voyages. Voyage 1 - loaded outside EU/ discharged in EU port. Voyage 2 - loaded outside EU/ discharged outside EU. Will voyage 1 will incur 50% emissions for the laden leg and voyage 2 50% of ballast leg?
Yes, EU ETS looks at the port of calls connected to a sailing leg to establish the share of emissions eligible for EU ETS. Port of calls are only stops where cargo/passengers are loaded/unloaded. 100% of emissions in EU port of calls are included, 0% of emissions in non-EU port of calls are included, 50% of sailing legs where one port of call was in EU, and 100% of sailing legs where two port of calls were in EU.
What is the EEOI target indicator on the Ship Finder? Is this comparing it to the overall ship type's baseline EEOI or something else?
The EEOI target is taken from Sea Cargo Charter trajectories which are based on IMO Fourth Green House Gas Study. The trajectory is dependent on ship-type and capacity (DWT for bulk and tankers, and CBM for gas carriers).
Are only load/discharge operations considered for port calls? What if a vessel bunkers at Fuj/Suez while coming from Singapore. Will the 50% apply for Singapore to EU or Suez to Singapore?
Yes, only stops where cargo/passengers are loaded or discharged are considered as port calls. The 50% will apply from Singapore to EU.
A ship loads in the USG, it discharges at STS Southwold that is outside port limits.  It then loads in Rotterdam.  Where does that 'ballast' leg to be calculated start if an STS outside port limits does not count as a port call?
In the example, 50% of the emissions from completed loading in USG until arriving in Rotterdam would be eligible for EU ETS. This is unfortunately where the EU ETS does not align with more industry standard definitions of a voyage (empty to empty). It can makes sense when following the vessel, but makes it harder when breaking it up into voyages.
Let's say we are in 2024 and my voyage completed today. I know the total of eligible emissions for my voyage. What would be the price of allowances? forward or spot
The price for EUAs have been very volatile. The ISM manager will be asked to deliver the corresponding allowances for this voyage eventually in 2025. The cost for either purchasing or receiving these allowances from charterers is a matter left to the commercial agreements between the parties involved in the voyage, i.e the ISM manager with the ship operator if not the same company and the spot charterer.
Can the ETS exposure be reduced by using liquid biofuels?
The EU ETS is currently following Tank-To-Wake principle regarding emission factors, and the following was written in the latest proposal: “The emission factor for biomass that complies with the sustainability criteria and greenhouse gas emission saving criteria for the use of biomass established by Directive (EU) 2018/2001, with any necessary adjustments for application under this Directive, as set out in the implementing acts referred to in Article 14, shall be zero.” The FuelEU Maritime regulation is focusing on the Well-To-Wake principle, where the emission intensity for biofuel will not be zero as the well-to-tank emissions are not zero.
EU ETS is required to result in a 62% reduction in emissions by 2030. What do emissions mean here (Co2 or GHG or Co2+Methane+N20)?
Emissions from the maritime industry will be included in two steps: carbon dioxide will be included in the ETS from 2024 whereas methane and nitrous oxide will be included from 2026. According to the European Commission, EU ETS covers the following sectors and gases, focusing on emissions that can be measured, reported and verified with a high level of accuracy: - carbon dioxide (CO2) from electricity and heat generation, energy-intensive industry sectors, including oil refineries, steel works, and production of iron, aluminium, metals, cement, lime, glass, ceramics, pulp, paper, cardboard, acids and bulk organic chemicals, aviation within the European Economic Area and departing flights to Switzerland and the United Kingdom; maritime transport - nitrous oxide (N2O) from production of nitric, adipic and glyoxylic acids and glyoxal; - perfluorocarbons (PFCs) from the production of aluminium.
Fit for 55 reduction target in 2030 is still 55% as per my understanding – but I heard the target was revised to 57% (related to LULUCF emissions reduction new target); is it already finalised?
The revised regulation on the land use, land use change and forestry sector (LULUCF) was formally adopted by the Council in March 2023. It increased the EU carbon sinks target for the land use and forestry sector, which increases the EU’s 2030 greenhouse gas reduction target to 57%.

Questions that we did not have time to answer during the webinar:

FAQ

To tag on to the above question. Would you know if the vessel hull is fouled or not? This can have an enormous difference in estimating the theoretical fuel consumption for a voyage.
For ship with improvements beyond what is reflected in the specification variables, such as a recently performed hull cleaning, we offer owners and operators to report emission numbers which in turn will be reflected directly in any estimates provided for Siglar Carbon clients. This way we help market the impact of such investments to potential charterers.
Who will pay the extra cost (EUA purchases)? Is it the shipowner or the charterer? Are there any regulations in EU ETS that oversee the responsibility for EUA purchases? How are the mechanisms being built around it?
The EU ETS regulations states that it is the shipping company, meaning the ISM manager, that is to provide the required no. of EUAs to the relevant authority. The ISM manager is in most cases the technical manager of the ship and not necessarily the owner or operator of the ship. In the legislation there is stated that the ISM manager shall have the mandate to collect EUA's or be reimbursed the cost for purchase from the charterer. What is not specified in the regulation is the process to do so, nor what kind of sanctions or  penalty there would be if a charterer fails to deliver. Hence, it is left for the industry to solve this, commercially and contractually, in all commodity and chartering deals.
Fit for 55 reduction target in 2030 is still 55% as per my understanding – but I heard the target was revised to 57% (related to LULUCF emissions reduction new target); is it already finalised?
The revised regulation on the land use, land use change and forestry sector (LULUCF) was formally adopted by the Council in March 2023. It increased the EU carbon sinks target for the land use and forestry sector, which increases the EU’s 2030 greenhouse gas reduction target to 57%.
EU ETS is required to result in a 62% reduction in emissions by 2030. What do emissions mean here (Co2 or GHG or Co2+Methane+N20)?
Emissions from the maritime industry will be included in two steps: carbon dioxide will be included in the ETS from 2024 whereas methane and nitrous oxide will be included from 2026. According to the European Commission, EU ETS covers the following sectors and gases, focusing on emissions that can be measured, reported and verified with a high level of accuracy: - carbon dioxide (CO2) from electricity and heat generation, energy-intensive industry sectors, including oil refineries, steel works, and production of iron, aluminium, metals, cement, lime, glass, ceramics, pulp, paper, cardboard, acids and bulk organic chemicals, aviation within the European Economic Area and departing flights to Switzerland and the United Kingdom; maritime transport - nitrous oxide (N2O) from production of nitric, adipic and glyoxylic acids and glyoxal; - perfluorocarbons (PFCs) from the production of aluminium.
Can the ETS exposure be reduced by using liquid biofuels?
The EU ETS is currently following Tank-To-Wake principle regarding emission factors, and the following was written in the latest proposal: “The emission factor for biomass that complies with the sustainability criteria and greenhouse gas emission saving criteria for the use of biomass established by Directive (EU) 2018/2001, with any necessary adjustments for application under this Directive, as set out in the implementing acts referred to in Article 14, shall be zero.” The FuelEU Maritime regulation is focusing on the Well-To-Wake principle, where the emission intensity for biofuel will not be zero as the well-to-tank emissions are not zero.
Let's say we are in 2024 and my voyage completed today. I know the total of eligible emissions for my voyage. What would be the price of allowances? forward or spot
The price for EUAs have been very volatile. The ISM manager will be asked to deliver the corresponding allowances for this voyage eventually in 2025. The cost for either purchasing or receiving these allowances from charterers is a matter left to the commercial agreements between the parties involved in the voyage, i.e the ISM manager with the ship operator if not the same company and the spot charterer.
On your carbon calculator - how accurate is your consumption data for each vessel? Have owners provided you with s&c curves or are you modelling expected consumptions?.
The carbon estimator is built on our prediction models that are trained using a vast amount of actual reported consumption and operations data with high granularity. Additional data layers are added and used such as ship specifications, AIS track and weather data. Since we have been collection such data now fleet wide for a number of years, we have seen most ships (or sister ships) and voyages and testing shows that we are industry leading in accuracy.
What does mean when nothing appears in the box "EU/ETS eligible" when we are looking at information for a vessel?
The ship finder uses the ballast port, load port and discharge port to determine whether any of the sailing legs and/or port stays are included in the EU ETS. If the EU ETS eligible column displays zero it means that none of the emissions from that voyage would be included in EU ETS.
If a vessel discharges at a port in the EU and sails out to New York to load and go to China to discharge, even with this sailing, are CO2 emission from EU to New York included in EU ETS?
Yes, 50% of the CO2 emissions emitted when sailing from EU to New York would be eligible under EU ETS. Allowances must be delivered for 40 % of the eligible emissions in 2024, 70% in 2025 and 100% in 2026.
It seems that there will be an incentive for vessels to make a port call at Falmouth or Plymouth in the Uk to give a very short ballast leg out of the EU and then an non-EU ETS ballast leg from UK to US for loading the next cargo-wake?
Yes, that is currently true until either UK ETS includes international shipping, or if EU starts imposing 100% of emissions for extra-EU voyages as well. However, including an additional port call also comes with a significant cost, both with regards to port costs and additional vessel cost due to increased voyage duration.
Let's assume a vessel has done two consecutive  voyages. Voyage 1 - loaded outside EU/ discharged in EU port. Voyage 2 - loaded outside EU/ discharged outside EU. Will voyage 1 will incur 50% emissions for the laden leg and voyage 2 50% of ballast leg?
Yes, EU ETS looks at the port of calls connected to a sailing leg to establish the share of emissions eligible for EU ETS. Port of calls are only stops where cargo/passengers are loaded/unloaded. 100% of emissions in EU port of calls are included, 0% of emissions in non-EU port of calls are included, 50% of sailing legs where one port of call was in EU, and 100% of sailing legs where two port of calls were in EU.
What is the EEOI target indicator on the Ship Finder? Is this comparing it to the overall ship type's baseline EEOI or something else?
The EEOI target is taken from Sea Cargo Charter trajectories which are based on IMO Fourth Green House Gas Study. The trajectory is dependent on ship-type and capacity (DWT for bulk and tankers, and CBM for gas carriers).
Are only load/discharge operations considered for port calls? What if a vessel bunkers at Fuj/Suez while coming from Singapore. Will the 50% apply for Singapore to EU or Suez to Singapore?
Yes, only stops where cargo/passengers are loaded or discharged are considered as port calls. The 50% will apply from Singapore to EU.
A ship loads in the USG, it discharges at STS Southwold that is outside port limits.  It then loads in Rotterdam.  Where does that 'ballast' leg to be calculated start if an STS outside port limits does not count as a port call?
In the example, 50% of the emissions from completed loading in USG until arriving in Rotterdam would be eligible for EU ETS. This is unfortunately where the EU ETS does not align with more industry standard definitions of a voyage (empty to empty). It can makes sense when following the vessel, but makes it harder when breaking it up into voyages.
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