Technological neutrality for emerging renewable energy pathways.

The lifecycle framework in FuelEU Maritime sets performance standards for GHG intensity without mandating specific fuels or disqualifying candidate decarbonization pathways. This technology neutral approach captures the GHG reduction potential across all stages of renewable energy transition pathways.

Mandating fuel sub-quotas would insert pathway-specific discriminatory elements that muddie the waters. Instead, dedicated and temporary performance multipliers would help incentivize first mover investments in all viable pathways and accelerate the transition to renewably derived fuels.

Faster progress through synergies.

FuelEU Maritime compliance requires combined efforts by

1. The operator and vessel charter working to efficiently provide transport services using onboard technologies and vessel designs, and

2. The shipowner who determines the onboard technology available and defines the range of fuels and fuel quality allowed.

Freedom of contract, including over the allocation of responsibility for penalties, is essential to so that the parties achieve the best technological and operational outcomes needed to meet GHG-intensity reduction mandates. 

The Commissions FuelEU Maritime definition of the responsible entity recognises well that ship owners and ship operators share responsibility for the implementation of shipping decarbonisation measures and gives all parties an incentive to work for GHG intensity reduction. It is also consistent with the international nature of fleet operation, ownership, and control, supporting EU priorities for IMO agreements and measures to reduce GHGs in shipping.

Pooling accelerates technology transfer.

FuelEU Maritime includes measures such as pooling that promote innovation, broaden fleet uptake to GHG reducing strategies, and can accelerate global GHG reductions.

Pooling within the EU policy context can improve global GHG performance through expected fleet rotation across global service routes and with resale of ships with low-GHG performance and replacement of lower-performing ships. Pooling will accelerate technology transfer, support lead mover initiatives, and promote progress for decarbonization across fleets.

Shared efforts to achieve maritime on-shore Power Supply.

Liner shipping is committed to being ready by 2030 to plug into OPS where available and compatible with international connectivity or to using zero emissions technology at berth. The Fuel EU Regulation must ensure that the obligation for carriers to use OPS continues to respect the important lead time needed to retrofit ships meeting FuelEU requirements.

In parallel, the Alternative Fuels Infrastructure Regulation must provide certainty that ports will build out the infrastructure required. Otherwise, vessel OPS capabilities will be stranded. Developing alternative fuel infrastructure and building out port electrification for OPS requires shared leadership, responsibility and co-investment by private ports, public port authorities and port administrations.

Promote competition, avoid GHG leakage, enable IMO agreements.

All EU Green Deal goals for the European economy and for GHG reduction targets can be achieved without applying extra-territorial compliance requirements in EU ETS and FuelEU Maritime.

A regional policy design, based on intra-EU voyages, reduces the risk of GHG leakage and maintains the global competitiveness of EU ports. Intra-EU regional policy better positions Europe to successfully negotiate strong international agreement at IMO.

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