Providing the Best Service,
Creating a Better World
1

2025

2030

2035

2040

2045

2050

-2%

-6%

-14.5%

-31%

-62%

-80%

List of Abbreviations
AS

Administering StateCA Port of callCompetent Authority Port of call

CB

Compliance Balance

EEA

European Economic Area

EU

European Union

GHG

Greenhouse Gas

GHGIEtarget

GHG Intensity Limit

GHGIEactual

Yearly average of the GHG intensity of the energy used on-board

GWP

Global Warming Potential

ISM CodeInternational Safety Management Code

LCV

Lower Calorific Value

LNG

Liquefied Natural Gas

MP

Monitoring Plan

MRV

Monitoring, Reporting and Verification

OPSOn-shore Power Supply

RFNBO

Renewable fuels of Non-Biological Origin

RED II

Renewable Energy Directive II

RWD

Reward factor for RFNBO, RFNBO

TEN-T

Trans European Transport Network

WtT

Well to Tank

TtW

Tank to Wake

WtW

Well to Wake

ZET

Zero Emission Technology

Providing the Best Service,
Creating a Better World

Contents
A. FuelEU Maritime ROADMAP

04

B. Initial implementation guidelines following
the introduction of FuelEU Maritime06

1. General
2. Application
3. Well to Wake
4. GHG Intensity Limit
5. GHGIE Calculation
6. RFNBO
7. OPS
C. Penalty

14

1. GHG Intensity Penalty
2. RFNBO Penalty
3. OPS Penalty
D. Flexibility Mechanism
1. Banking
2. Borrowing
3. Pooling
4. RFNBO Flexibility Mechanism

18

A.

FuelEU Maritime
ROADMAPMP Submission Reporting& Assessment period

Verification period

2024
31 Aug2026

2025| 2025 | First FuelEU monitoring year
| 2026 | First FuelEU verification year

Flexibility Mechanism
periodVerified Compliance
Balance by verifier

By 31 Mar

By 30 Apr 1 May

Penalty Period(Ensured from AS*)

1 JuneBy 30 June

FuelEU Database| Company | ~31 Jan

FuelEU MP
Submitto verifier

Monitoring
FuelEU data
for thecalendar year

Issue to company

Submit to verifier*
AS: Administering State**
Compliance Balance

Company

FuelEU ReportCompany| Verifier | ~31 Mar| Chance for pooling compliance |A

Company

B

Verification Report

Administering State shall ensure final Penalty
considered GHGIE, RFNBO, OPS, deficit for
two or more consecutive years by 1 June

Calculate and notify
to company

GHG Intensity & CB**
※ For each vessel

Pooling

Verifier

Approval of pooled **CB
before 1 May

Deficit Borrowing (or)Pooling (or)For the1st time
FuelEU Scope
voyageAssessFuelEU MP
by 202404 | FuelEU Maritime

Submit within
2 months after
first call for EU

1. GHGIE Obligation (2025~)

Paying (or)FuelEU
Penalty

DOC
Issuance

2. RFNBO Obligation (2034~)
3. OPS Obligation (2030~)

Surplus Banking (and/or)
Pooling (or)Member State (MS)All FuelEU data will be recorded in FuelEU Databaseand MS can check data anytime via FuelEU Database

FuelEU Maritime | 05

B.

Initial implementation
guidelines following
the introduction of
FuelEU Maritime

1. General

In July 2021, as part of its efforts to reduce greenhouse gases, the European
Commission announced the 'EU Fit for 55' package. This legislative package
aims to reduce GHG emissions by 55% by 2030 compared to 1990 levels.
Among the initiatives directly related to international maritime transport isFuelEU Maritime*.
FuelEU Maritime is a legislative proposal that promotes the use of renewable
and low-carbon fuels in maritime transport, applicable to all ships voyaging
at EU/EEA ports, regardless of their flag. The proposal seeks to graduallyenhanced the limits on GHG intensity of ship fuels by 2050, there by stimulating demand for alternative fuels and enhancing the use of On-shore Power
Supply (OPS) and Zero-emission Technology (ZET) within ports.
In response, the Korean Register has published technical information to assist
shipping companies in effectively complying with FuelEU Maritime. It is recommended that stakeholders refer to this information for related operations.
* FuelEU Maritime : Regulation (EU) 2023/1805 - On the use of renewable and low-carbon fuels in maritime transport, and amending Directive 2009/16/EC

FuelEU
Maritime's
key objectives
Phased reduction of
the GHG intensity offuel used on board

06 | FuelEU Maritime

Promote the use ofsustainable fuels

Mandatory OPS a EU
ports (For container andpassenger ships)

2. Application

From January 1, 2025, FuelEU Maritime regulations will apply to all ships above 5,000
GT voyaging at EU/EEA ports, with specific requirements based on the jurisdiction of
a Member State as follows;■ Extra-EU Voyage (EU ↔ Non-EU): 50% of energy used is considered■ Intra-EU Voyage (EU ↔ EU): 100% of energy used is considered■ Within EU Ports: 100% of energy used is considered■ Outermost Regions Voyage (EU ↔ Outermost Regions*):
50% of energy used is considered.
The ISM company is responsible entity for the ship, according to Annex I of EC Directive 336/2006, must ensure compliance with the ISM Code under FuelEU Maritime.
Voyages between outermost regions, isolated territories to the mainland (such as
Ceuta and Melilla), and panssenger ships other than cruise passenger ships between
islands with permanent residents under 200,000 within the jurisdiction of the same
Member State are exempt until December 31, 2029.
The company may request ships classified as Ice Class IA Super, IA, IB, or IC exclusions
annually for additional energy used under ice conditions until December 31, 2034, as
specified in Annexes VI and V of EU Directive 2023/1805.

* Outermost Regions→ French Guiana, Guadeloupe, Martinique, Mayotte,Reunion Island and Saint-Martin (France)→ Azores, Madeira (Portugal)→ The Canary Islands (Spain)
https://ec.europa.eu/regional_policy/policy/themes/outermost-regions_en

Scope of voyage

50%❶

Incoming &Outcomingvoyages

Non-EU/EEA

100%

❷

EU/EEA

Intra EU/EEA
voyages

FuelEU Maritime | 07

3.
Well to Wake

FuelEU Maritime applies to GHG emissions from fuels using the "Well to Wake" approach. The "Well to Tank" phase includes emissions from the extraction or cultivation,
processing or refining, and transportation or distribution of the fuel. The "Tank to Wake"phase covers emissions from the combustion of the fuel.

Pathway
Well-to-Tank

Extraction/
Cultivation

Processing
and Refining

Tank-to-Wake

Transportationand distribution

Combustion /Fugitive & Slip

BunkeringWell-to-Wake

The greenhouse gases accounted for include not only carbon dioxide (CO2) but also methane (CH4) and nitrous oxide (N2O). Methane and nitrous oxide are converted to CO2 equivalents using the Global Warming Potential (GWP100*) values, with factors of 28 and 265
respectively.
* Regulation (EU) 2020/1044 : Supplementing Regulation (EU) 2018/1999 of the European
Parliament and of the Council with regard to values for global warming potentials and the inventory guidelines and with regard to the Union inventory system and repealing Commission
Delegated Regulation (EU) No 666/2014

4.
GHG Intensity
Limit

The European Commission set a reference value of 91.16 gCO2eq/MJ for GHG intensity using the 2020 MRV data. Based on this reference value, they have set targets toprogressively reduce the GHG Intensity Limit of the energy used in ships at five-year
intervals until 2050.
GHG intensity(gCO2eq/MJ)

2020

2025

2030

2035

2040

2045

2050

100
90

91.16

89.34

80

-2%

-6%
85.69

70

-14.5%
77.94

-31%
62.90

60

-62%

50
40

34.64

30

-80%
18.23

20
10

Year

2020

2025

2030

2035

2040

2045

2050

Reduction

-

-2%

-6%

-14.5%

-31%

-62%

-80%

GHG
intensity

91.16

89.34

85.69

77.94

62.90

34.64

18.23

(gCO2eq/MJ)

08 | FuelEU Maritime

5.
GHGIEactual
Calculation

The GHG Intensity for energy used in ships is expressed as the Well to Wake (WtW)
GHG emissions per unit of energy (gCO2eq/MJ) and is calculated as follows in Equation(1). Additionally, the results from Equations (2) and (3) for Well to Tank (WtT) and Tank
to Wake (TtW), respectively, are summed and then multiplied by the wind compensation factor fwind. The result of this calculation is used as the GHGIEactual value in Section
C's Penalty calculation.

Compliance Balance (RFNBO)
Calculation(1)fwind is the wind-assisted propulsion reward factor, calculated as PWind/PProp. The PWind value can be represented by the verified EEDI or EEXI value according to MEPC.1/Circ.896*,
multiplied by feff×Peff**. PProp, representing the ship's propulsion power, corresponds to thePME value as defined in MEPC.364(79) and MEPC.333(76)***. If a shaft motor is installed,
PProp can be represented as PME+P(PTI(i), shaft).

*
MEPC.1/Circ.896: 2021 GUIDANCE ON TREATMENT OF INNOVATIVE ENERGY EFFICIENCYTECHNOLOGIES FOR CALCULATION AND VERIFICATION OF THE ATTAINED EEDI AND EEXI**
f_eff: Availability factor P_eff: Power reduction factor***
MEPC.364(79): 2022 GUIDELINES ON THE METHOD OF CALCULATION OF THE ATTAINEDENERGY EFFICIENCY DESIGN INDEX (EEDI) FOR NEW SHIPS
MEPC.333(76): 2021 GUIDELINES ON THE METHOD OF CALCULATION OF THE ATTAINEDENERGY EFFICIENCY EXISTING SHIP INDEX (EEXI)FuelEU Maritime | 09Calculation(2)Calculation(3)In this formula, i represents the fuel types, j represents the fuel consumer units on board
the ship, k represents OPS connection points, n is the total number of fuel types, c is thetotal number of OPS connection points, m is the total number of fuel consumer units,
M is the Mass of fuel i consumed by fuel consumer unit j (gFuel), Ek is the Electriciy delivered to the ship per OPS connection point k (MJ), CO2eqWtT,i is the WtT GHG emission
factor of fuel i (gCO2eq/MJ), CO2eq, electricity, k is the WtT GHG emission factor associatedwith the electricity delivered to the ship at berth per OPS connection point k (gCO2eq/
MJ), LCV is the lower calorific value of fuel i (MJ/gFuel), Cslip is Non-combusted fuelcoefficient as a percentage of the mass of the fuel i consumed by fuel consumer unit
j. Cslip includes fugitive and slipped emissions (%), CO2eq,TtW is the TtW CO2 equivalentemissions of combusted fuel i in fuel consumer unit j (gCO2eq/gFuel), and CO2eq, TtW, slip isthe TtW GHG emission factors by slipped fuel i towards fuel consumer unit j (gCO2eq/
gFuel). RWD is the reward factor for ships using where the fuel is of non-biologicalorigin, a reward factor of 2 from 1 January 2025 to 31 December 2033can be applied.
Otherwise RWDi = 1.
The WtT GHG emission factors for fossil fuels should use default values. However, alternative fuels like biofuels and RFNBO can use actual values recognized by certification systems under Article 10 of FuelEU Maritime. TtW GHG emission factors can also
use actual values if experimental data are available, but fossil fuel CO2 emission factors
must use default values.

| Applicable Actual Emission Factors | Tank to Wake
TtW
Combustion Emission Factors

10 | FuelEU Maritime

Slippage

CO2

CH4

N 2O

FOSSIL

N

Y

Y

Y

BIO

Y

Y

Y

Y

RFNBO

Y

Y

Y

Y

The WtT GHG emission factor (gCO2eq/MJ) for biofuels can be derived using Equation(4).

Calculation(4)For liquid biofuels, the default values shall be calculated by using the values of E
established in accordance with the methodologies laid down in RED II (Directive (EU)2018/2001), Part C of Annex V to that Directive for all liquid biofuels except bio-LNG
and Part B of Annex VI to that Directive for bio-LNG CfCO2 uses the TtW CO2 emission
factor default value for biofuels, and LCV is determined according to the values specified in Annex III of RED II. As shown in Equation (4), the reason for subtracting the valueof CfCO2 divided by LCV from the value E is because E represents the WtW value, but
in FuelEU Maritime, WtT and TtW are calculated separately to avoid double countingof emissions.

FuelEU Maritime | 11

To comply with the FuelEU Maritime regulation, transitioning from fossil fuels to

6. RFNBO

sustainable alternative fuels is essential. RFNBO (Renewable Fuels of Non-BiologicalOrigin), also known as e-Fuel, is synthesized electrically using hydrogen (H2). FuelEU
Maritime may provide for a combination of measures to ensure the support for the
uptake of sustainable RFNBO, including the possibility to use a ‘multiplier’ until the endof 2033, allowing the energy from RFNBO to count twice. In addition, a 2% RFNBO
subtarget should apply as of 2034 if, further to monitoring of the market, the Commission reports that the share of RFNBO in the maritime bunker fuels used by ships fallingunder the scope of this Regulation is less than 1 % by 2031.

RFNBO (e-fuel)
RFNBO Requirements

GHG savings - at least 70% GHG savings
N2
when
value
2
CO2 compared to a fossil reference

H

CO2

CO2

N2

N2

CO2

N2

H2

H2

H2

+

N2

CO2
N2 N2

CO2 CO2

e-fuels

e-fuels+
Electrolysis

12 | FuelEU Maritime

DAC

e-fuels(Direct Air Capture)

Point
SourceH2 e-fuels

H2 H2e-fuels

e-fuels
e-fuels

7. OPS

Container and passenger ships since those are the ship categories that produce thehighest amount of emissions per ship while moored at the quayside, according to thedata collected within the framework of Regulation (EU) 2015/757 in 2018. Considering
the positive effects of the use of OPS on local air pollution and the need to incentivise the uptake of that technology in the short term, the carbon intensity of the production of the electricity supplied at berth should be counted as zero. Therefore, forcontainer and passenger ships moored at EU/EEA ports for more than two hours, theuse of Onshore Power Supply (OPS) or Zero Emission Technology (ZET) is mandated.
If these requirements are not complied with, it is referred to as a 'Non-Compliant portof call', which is verified by a verifier and reported to the EU. The OPS mandate aims
to reduce air pollution emissions in densely populated areas near ports, with penalties
for non-compliance starting in 2030 for ports included in the TEN-T(Trans-European
Transport Network)*. Furthermore, from 2035, penalties will also be applied to ports
not included in TEN-T but equipped with OPS facilities.
* TEN-T : Trans-European Transport Network (TEN-T) is a key instrument for the development of efficient and high-quality transport infrastructure across EU. The terms ‘TEN-T
core maritime port or TEN-T comprehensive maritime port’ means a maritime port of
the TEN-T core network or TEN-T comprehensive network, as listed and categorised in
Annex II to Regulation (EU) No 1315/2013.

Obligation by using OPS (Passenger ship, Container ship only)| PORTS: GATEWAYS OF THE TEN-T || Exemptions (EU 2023/1805 Article 6(5)) |▶ Moored less than 2 hours

2030~
For TEN-T Maritime Port

▶ Use zero-emission technologies▶ Unscheduled port call
▶ Unable to connect to OPS

2035~
For none TEN-T Maritime Port
(If OPS connection exists)▶ Unavailability of OPS connection

points in a port

▶ Onboard energy generation formaintanance tests or functional tests

FuelEU Maritime | 13

C.

Penalty1.
GHG Intensity
Penalty

Starting in 2025, ships under the regulation whose annual ship energy consumption GHG intensity is below the GHG Intensity Limit will generate a surplus in their Compliance Balance (CB), while those exceeding the limit will
incur a deficit. Ships with a deficit must pay a penalty proportional to theirdeficit. The CB can be expressed as the difference between the GHG Intensity Limit and the annual GHG Intensity value, multiplied by the energy
consumption. Energy consumption is calculated using the mass of the fuel,its Lower Calorific Value (LCV), and the amount of power supplied to the ship.
Additionally, ships that have sustained a deficit for a consecutive period of N
years (two years or more) must pay an additional penalty of (N-1) X 10%.

Compliance Balance(GHG intensity limit on energy used on board by a ship for the reporting period(gCO2eq/MJ)– Yearly average of the GHG intensity of the energy used on-board a ship calculated for the relevant reporting period(gCO2eq/MJ))
X (Each fuel consumption(gFuel) X Each fuel's low calorific value(MJ/gFuel) + OPS energy used(MJ))

Penalty| Compliance Balance(gCO2eq) |(Yearly average of the GHG intensity of the energy used on-board a ship
calculated for the relevant reporting period(gCO2eq/MJ) X 41000MJ/tonne)

14 | FuelEU Maritime

X 2400Euro(EUR/tonne)

2.
RFNBO Penalty

Despite incentives for the use of RFNBO (Renewable Fuels of Non-BiologicalOrigin) until 2033, if the proportion of RFNBO used in the total annual energy
consumption of is less than 1% of the reported total fuel energy in 2031, a new
subtarget may be provided. The subtarget may be applied from 2034, requiring
at least 2% of a ship's annual energy consumption to be from RFNBO. This subtarget may lead to additional penalties for shipping company, calculated basedon the value of the compliance balance for RFNBO the 2% target and considering the Price difference between RFNBO and fossil fuel compatible with ship
installation.

Compliance Balance (RFNBO)(0.02 X (Each fuel consumption(gFuel) X Each fuel's low calorific value(MJ/gFuel))- (RFNBO consumption(gFuel) X RFNBO low calorific value(MJ/gFuel))

Penalty (RFNBO)

Compliance Balance(RFNBO)(MJ)
41000MJ/tonne

X Price difference between RFNBO and fossil fuel compatible with ship installation

FuelEU Maritime | 15

3.
OPS Penalty

Starting from 2030, container and passenger ships will be subject to penalties
if they fail to comply with the Onshore Power Supply (OPS) requirements at any
EU/EEA port of call. For all applicable ships that are not exempt, an additional
OPS penalty will be paid, calculated by resulting from the multiplication of EUR
1.5 by the established total electrical power demand of the ship at berth and by
the total number of hours rounded up to the nearest whole hour, spent at berthby the ship in non-compliance with the requirements.

OPS Penalty
Total Electrical Power Demand of ship at berth × Total Number of hours(round up to nearest hour) × 1.5 EUR(The highest value, expressed in kilowatts, of the total demand for electricity of a ship at berth,including hotel and cargo handling workloads X The total number of hours rounded up to the nearest whole hour(h) X 1.5 Euro16 | FuelEU Maritime

| GHGIE Penalty | 2025~
GHGIE Target

GHGIE Actual

Annual average GHG intensity reduction
compared to the average in 2020-2%

-6% -14.5%

-31%

-62%

-80%

fwind

(

WtT

Reward factor forwind-assited propulsion

2025 2030 2035

2040

2045

+

Fuel
production)

TtW
Fuel combustion &fugitive, slipped

2050

Compliance Balance

Pooling
Pooled Compliance Balance > 0

Energy(GHGIEtarget - GHGIEactual) × Total
Used
gCO2eq/MJ

Compliance Balance > 0

LNG, Biofuels, RFNBOs

2025 2026 2027 2028 2029 2030 2031 2032 2033
The multiplier '2' can be applied to the use of RFNBO

No

+

MJ

| RFNBO Penalty | When fail to meet the 2% subtarget

Compliance Balance < 0= FuelEU

Penalty

Fossil Fuels| OPS Penalty |2030~ Passengership, Container ship only
Zero Emission / Zero Penalty
General requirements for zero-meission technologies(EU 2023/1805 ANNEX III)

RFNBO ENERGY X 2
Energy used by RFNBO
less than 1% in 2031

2% RFNBO subtarget
will be applied (2034~)

1%
Maritime
bunker fuels
used by ships

Fuel Cells

On-board
electrical energy
storageOn-board power
generation fromwind and solar
energy2% 2%Energy Demand at port (Demand * hour(s) * 1.5EUR)

FuelEU Maritime | 17

D.

Flexibility
Mechanism

1.
Banking

On the basis of GHGIEactual calculations where the ship has, for the reporting
period, a compliance surplus on its GHG intensity, the company may bank itto the same ship’s compliance balance for the following reporting period. The
company shall record the banking of the compliance surplus to the following
reporting period in the FuelEU database subject to approval by its verifier. The
company may no longer bank the compliance surplus once the FuelEU document of compliance has been issued.

2.
Borrowing

On the basis of GHGIEactual calculations where the ship has, for the reporting
period, a compliance deficit, the company may borrow an advance compliancesurplus of the corresponding amount from the following reporting period. The
advance compliance surplus shall be added to the ship’s compliance balance inthe reporting period and the advance compliance surplus multiplied by 1.1 shallbe subtracted from the same ship’s compliance balance in the following reporting
period. The advance compliance surplus may not be borrowed:■ For an amount exceeding by more than GHGIEtarget by 2%■ For two consecutive reporting periods

18 | FuelEU Maritime

3.
Pooling

The compliance balances for GHG intensity referred to GHGIEtarget of two or more
ships, as calculated in accordance with GHGIEactual calculations, may be pooled
for the purposes of complying with the requirements. By April 30th, the definitive
composition of the pool and allocation of the total pool compliance balance to eachindividual ship after pooling compliance by verifier. Ships with a surplus in their CB
relative to the GHGIEtarget can be used as flexiblity mechanism to assist ships witha CB deficit. The requirements for pooling are as follows:■ A ship’s compliance balance may not be included in more than one pool in thesame reporting period.
■ Where the ships participating in the pool are controlled by two or more companies, the pool details is validated same verifier.
■ A pool is valid only if the total pooled compliance is positive.

4.
RFNBO
Flexibility
Mechanism

If the proportion of RFNBO used in the total annual energy consumption of isless than 1% of the reported total fuel energy in 2031, the subtarget may be
applied from 2034, requiring at least 2% of a ship's annual energy consumption
to be from RFNBO. Similarly to the GHGIE flexible mechanism, there is also an
opportunity for pooling under the RFNBO subtarget. Two separate pools may
be used for GHGIEtarget and for the subtarget for RFNBO, and the pooling requirements for banking/borrowing remain the same.

FuelEU Maritime | 19

Member State can check
all process via FuelEU Database

Every year from 2026

by 31 Mar| 1 | EU 2023/1805 Article 15▶

Member StateRoles

by 30 Apr

Surplus

Use OPS connection or application of any exemptions▶

Each Fuel consumption at berth and at sea▶

Electricity delivered to the ship through OPS▶

All GHG emission factor for each type of fuel▶

All amount of energy for each substitute source▶

Ice class relevant documents

AS shall ensure FuelEU Penalty

by 1 June

Banking◀ 89.34

GHGIEtarget
Surplus※ No morebanking afterissuanceof DoCIf the pooled CB results in asurplus, it can be banked tothe surplus ship's CB for thefollowing period

CB◀ 7.09 / e-fuelFor following
periodPooling
CB

CB

Requirement for Pooling◀ VLSFO

92.59

DeficitPooling| 1 | FuelEU ReportCompany

VerifierCB| 2 | CB

Borrowing
From Next year’s CB
as multiplied by 1.1
shall be subtracted| 2 | EU 2023/1805 Article 16(4)▶

Yearly average GHG intensity▶

Compliance Balance(CB)▶

The number of non-compliant port calls▶

Yearly Energy used excluding from OPS▶

Yearly Energy used from the RFNBO

20 | FuelEU Maritime

by 30 June

Deficit

Date and time for Departure/Arrival EU port
and time spent at sea▶

→ Administering State (AS)→ Competent Authority (CA) Port of call
→ Flag state (EU only)

PayingVessel can choose
Banking/Borrowing or Pooling

DOC
Issuance

1. A ship can be included inonly one pool per year
2. Different companies
available, but must be
verified by same verifier
3. Must be positive
compliance after pooling

Not allowed for Borrowing
1. Amount more than 2%of GHGIEtarget
2. For two consecurive
reporting periods

FuelEU Penalty※ Compliance withpaying penalty!

CAUTION!

If a ship fails to comply with the FuelEU obligation
two or more consecutive reporting periods, MS gives an expulsion order

FuelEU Maritime | 21

KOREAN REGISTER(46762) 36, Myeongji ocean city 9-ro, Gangseogu, Busan, Republic of Korea
Tel: +82 70 8799 8772 | Fax: +82 70 8799 8774
Email: eumrv@krs.co.kr
www.krs.co.kr