COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the Proposal for a Regulation of the European Parliament and of the Council on the use of renewable and low-carbon fuels in maritime transport
Date: 2021-07-14
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: energy resources, greenhouse gas, marine fuel, maritime transport, pollution from ships, reduction of gas emissions, renewable resources

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 14.7.2021  SWD(2021) 635 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT  Accompanying the Proposal for a Regulation of the European Parliament and of the Council on the use of renewable and low-carbon fuels in maritime transport {COM(2021) 562 final} - {SEC(2021) 562 final} - {SWD(2021) 636 final}  
 
 
Table of contents 

1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT ..................................... 6 

1.1  Overall political context .................................................................................... 6 
Interaction  between  policy  tools  to  address  maritime  CO2  emissions: 
1.2 
the ‘basket of measures’ .................................................................................... 8 
1.3  EU approach to alternative fuels in maritime transport ................................... 10 
International context ........................................................................................ 12 
1.4 
1.5  Trajectories for renewable and low carbon fuels ............................................ 13 

2.  PROBLEM DEFINITION ........................................................................................ 16 

2.1  What is the problem? ....................................................................................... 16 
2.2  What are the problem drivers? ........................................................................ 19 
2.2.1  Lack of predictability of the regulatory framework and high risk of 
investment choices (high risk of stranded assets) ..................................................... 19 

2.2.2  Low maturity of new renewable and low-carbon fuels/technologies with high 
risk for first movers ................................................................................................... 20 

2.2.3  Higher costs of alternatives compared to fossil fuels (also due to insufficient 
economies of scale) ................................................................................................... 22 

2.2.4  High interdependency with supply and distribution (chicken-and-egg 
situation) .................................................................................................................... 23 

2.2.5  Possibility of bunkering outside EU (risk of carbon leakage) ....................... 25 

2.3  How will the problem evolve? ........................................................................ 26 

3.  WHY SHOULD THE EU ACT? .............................................................................. 29 

3.1  Legal basis ....................................................................................................... 29 
3.2  Subsidiarity: Necessity of EU action ............................................................... 29 
3.3  Subsidiarity: Added value of EU action .......................................................... 30 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ..................................................... 30 

4.1  General objectives ........................................................................................... 30 
4.2  Specific objectives ........................................................................................... 31 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? .......................................... 32 

5.1  What is the baseline from which options are assessed? .................................. 32 
5.2  Description of the policy options .................................................................... 34 
5.2.1  Possible policy measures and preliminary screening of options ................... 34 

5.2.2  Identification of the general policy approach and the choice of main policy 
options ....................................................................................................................... 34 

5.2.3  Specific aspects of policy design ................................................................... 42 

5.2.4  Additional elements of policy intervention ................................................... 45 

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5.3  Options  discarded  at  an  early  stage  or  identified  as  complementary 

measures .......................................................................................................... 45 

5.3.1  Carbon pricing measures (ETS and ETD) and impact on the penetration rate 
for RLF ...................................................................................................................... 46 

5.3.2  A standard for carbon intensity of maritime operations (limit for CO2 
emissions per tonne-nautical mile) ............................................................................ 48 

5.3.3  Revision of other relevant and existing legal instruments (AFID and RED II)

49 

5.4  Feasibility of alternative pathways for the uptake of RLF .............................. 50 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ................................. 52 

6.1  Economic impacts ........................................................................................... 52 
6.1.1  Impacts on ship operators .............................................................................. 52 

6.1.2  Impacts on RLF prices, feedstock and renewable electricity needs for e-fuels

55 

6.1.3  Regulatory and administrative costs related to businesses ............................ 59 

6.1.4  Enforcement costs .......................................................................................... 62 

6.1.5  Impact on ports to provide the necessary infrastructure ................................ 63 

6.1.6  Impact on innovation ..................................................................................... 64 

6.1.7  Impact on the competitiveness of other parts of the EU maritime cluster .... 65 

6.1.8  Impact on third countries ............................................................................... 66 

6.2  Social impacts .................................................................................................. 67 
6.2.1  Impact on jobs in the different parts of the EU maritime cluster .................. 67 

6.2.2  Impact on freight rates and connectivity of remote islands and peripheral 
regions ....................................................................................................................... 68 

6.2.3  Public health .................................................................................................. 69 

6.3  Environmental impacts .................................................................................... 70 
6.3.1  Fossil fuels savings ........................................................................................ 70 

6.3.2  Impacts on GHG emissions and air quality ................................................... 70 

6.3.3  Carbon leakage .............................................................................................. 72 

7.  HOW DO THE OPTIONS COMPARE? .................................................................. 74 

7.1  Effectiveness .................................................................................................... 74 
7.2  Efficiency ........................................................................................................ 76 
7.3  Coherence ........................................................................................................ 77 
7.4  Proportionality and subsidiarity ...................................................................... 79 
7.5  Stakeholder’s views on the options ................................................................. 80 
7.6  Summary on the comparison of options .......................................................... 81 

8.  PREFERRED OPTION ............................................................................................. 82 

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9.  HOW  WILL  ACTUAL 

IMPACTS  BE  MONITORED  AND 

EVALUATED? ......................................................................................................... 83 

ANNEX 1: PROCEDURAL INFORMATION ................................................................ 85 

1.  LEAD DG, DECIDE PLANNING/CWP REFERENCES ........................................ 85 

2.  ORGANISATION AND TIMING ............................................................................ 85 

3.  CONSULTATION OF THE RSB ............................................................................. 85 

4.  EVIDENCE, SOURCES AND QUALITY ............................................................... 90 

ANNEX 2: STAKEHOLDER CONSULTATION ........................................................... 92 

1. 

INTRODUCTION ..................................................................................................... 92 

2.  FEEDBACK ON THE INCEPTION IMPACT ASSESSMENT .............................. 93 

3.  METHODOLOGY .................................................................................................... 93 

4.  ANALYSIS OF RESULTS OF THE STAKEHOLDER CONSULTATION .......... 96 

5.  CONCLUSION ....................................................................................................... 103 

ANNEX 3: WHO IS AFFECTED AND HOW? ............................................................. 104 

1.  PRACTICAL IMPLICATIONS OF THE INITIATIVE ........................................ 104 

1.1.  Outlook of the preferred option implementation ........................................... 104 
Implications on market operators and public authorities .............................. 104 
1.2. 

2.  SUMMARY OF COSTS AND BENEFITS ........................................................... 107 

ANNEX 4: ANALYTICAL METHODS ........................................................................ 109 

1.  DESCRIPTION OF THE MODELLING TOOLS USED ...................................... 109 

2.  BASELINE SCENARIO ......................................................................................... 117 

3.  METHODOLOGICAL  APPROACH  FOR  MODELLING  POLICY 

OPTIONS ................................................................................................................ 123 

4. 

IMPACT  ON  BIOMASS 
ELECTRICITY NEEDS ......................................................................................... 126 

FEEDSTOCK  AND  RENEWABLE 

5.  METHODOLOGICAL  APPROACH  FOR  REGULATORY  AND 
ADMINISTRATIVE  COSTS  RELATED  TO  BUSINESSES,  AND  FOR 
ENFORCEMENT COSTS ...................................................................................... 129 

6.  METHODOLOGICAL APPROACH FOR PORT INVESTMENTS .................... 134 

7.  METHODOLOGICAL  APPROACH  AND  RESULTS  OF  THE  RISK  OF 

CARBON LEAKAGE ANALYSIS ........................................................................ 136 

ANNEX  5:  CURRENT  MARITIME  FUEL  MIX  AND  OVERVIEW  OF 
AVAILABLE  ALTERNATIVE  FUELS  FOR  MARITIME  TRANSPORT 
AND THEIR MATURITY ..................................................................................... 171 

ANNEX 6: METHODOLOGY FOLLOWED FOR THE DEFINITION OF THE 

POLICY OPTIONS ................................................................................................. 184 

5.  FULL LIST OF IDENTIFIED POLICY MEASURESERROR! BOOKMARK NOT DEFINED. 

ANNEX  7:  OVERVIEW  OF  THE  MONITORING  AND  EVALUATION 

FRAMEWORK ....................................................................................................... 192 

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Glossary 

Term or acronym 

Meaning or definition 

AFID 

CAPEX 

CO2 

CH4 

CTP 

Drop-in fuels 

EEA 

EEDI 

EGD 

EMSA 

EPF 

ESSF 

GHG 

HFO 

IMO 

Ktoe 

LNG 

LPG 

MDO 

MGO 

MBM 

MARPOL 

Methane slip 

MOVE 

MRV 

N2O 

Nm 

Alternative Fuels Infrastructure Directive (2014/94/EU) 

Capital expenditure 

Carbon dioxide 

Methane 

Climate Target Plan, COM(2020) 562 final 

Fuel options that are functionally equivalent to the fossil fuels 
currently in use and fully compatible with the distribution 
infrastructure and the on-board machinery / engines 

European Economic Area 

Energy Efficiency Design Index 

European Green Deal 

European Maritime Safety Agency 

European Ports Forum 

European Sustainable Shipping Forum 

Greenhouse gases 

Heavy fuel oil 

International Maritime Organization 

Kilo-tonnes of oil equivalent 

Liquefied Natural Gas 

Liquefied Petroleum Gas 

Marine diesel oil 

Marine gas oil 

Market-based measure 

International Convention for the Prevention of Pollution from Ships  

Release of methane in the atmosphere while using gaseous fuels 
due, for instance, to the possible incomplete combustion of the fuel  

Directorate Directorate-General for Mobility and Transport 

Monitoring Reporting and Verification (in the meaning of 
Regulation (EU) 2015/757 as amended) 

Nitrous oxide (greenhouse gas) 

Nautical mile 

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NOx 

NMVOCs 

OPC 

OPEX 

OPS 

PM 

PO 

PSC 

RED II 

RFNBO 

RLF 

R&I 

SO 

SOx 

STCW 

Sulphur Directive 

Tank-to-wake 

TC 

TEN-T 

TRL 

Well-to-wake 

Nitrogen Oxides (air pollutant emissions to air) 

Non-methane volatile organic compounds (air pollutant emissions 
to air) 

Open public consultation 

Operating expenditure 

On-shore power supply 

Particulate matter (air pollutant emissions to air) 

Policy option 

Port State Control 

Renewable Energy Directive (Directive (EU) 2018/2001) 

Renewable fuels of non-biological origin 

Renewable and low-carbon fuels 

Research and Innovation 

Specific objective 

Sulphur Oxides (air pollutant emissions to air) 

International Convention on Standards on Training, Certification 
and Watchkeeping for Seafarers 

Codified Directive (EU) 2016/802 regulating the sulphur content in 
marine fuels (adopted in 2012 and codified in 2016) 

Method for calculating emissions that takes into account the 
greenhouse gas impact of combustion of a specific source of energy 

Targeted consultation 

Trans-European Network of Transport 

Technology readiness level 

Method for calculating emissions that takes into account the 
greenhouse gas impact of energy production, transport, distribution 
(“upstream emissions”) and use on-board, including during 
combustion 

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1.  INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

1.1  Overall political context 

This Impact Assessment accompanies a legislative proposal – hereby ‘FuelEU Maritime’ – 
aimed at increasing the demand of renewable and low-carbon fuels (RLF) in the maritime 
transport sector. These include liquid biofuels, e-liquids, decarbonised gas (including bio-
LNG and e-gas), decarbonised hydrogen, decarbonised hydrogen-derived fuels (including 
methanol, and ammonia) and electricity1.  

By contributing to around 75% of EU external trade volumes and 31% of EU internal trade 
volumes,  maritime  transport  is  an  essential  component  of  Europe’s  transport  system  and 
plays a critical role for the European economy. Every year, around 400 million passengers 
embark or disembark in EU ports, including around 14 million on cruise ships, and fulfil 
an  important  role  in  safeguarding  the  connectivity  of  islands  and  peripheral  maritime 
regions with the rest of the internal market2.  

While  maritime  transport  constitutes  arguably  the  most  energy  efficient  way  of  moving 
large  quantities  of  cargo3,  it  nevertheless  has  a  noticeable  impact  on  the  environment, 
notably in terms of air pollution4, emissions of GHG5 and marine pollution. In 2018, CO2 
emissions  from  international  shipping  in  the  EU27  were  still  around  36%  above  1990 
levels, despite their 18% reduction between 2008 and 20186. This is driven by the growth 
in  transport  activity  not  sufficiently  compensated  by  corresponding  improvements  in 
energy  efficiency,  and  exacerbated  by  slow  implementation  of  emission  reduction 
measures and heavy reliance on fossil fuels.  

The  European  Green  Deal  (EGD)  Communication7  of  December  2019  emphasised  the 
need  to  accelerate  the  transition  to  a  climate-neutral  economy  and  a  toxic-free 
environment,  also  by shifting to  sustainable and smart  mobility. The EU  is  committed to 
implement  the Paris Agreement, which  calls for  reaching  carbon neutrality  in  the second 
half of this century, and has adopted a long-term vision to become carbon neutral by 2050. 
Furthermore, the European Commission has proposed to translate the political commitment 
into  a  legal  obligation  as  part  of  the  Climate  Law8,  which  also  integrates  the  target  of 
reducing  GHG  emissions  by  at  least  55%  below  1990  levels  by  2030.  On  11  December 

1 Annex 5 provides greater information on the current maritime fuel mix and an overview of available alternative fuels 
for maritime transport and their maturity 
2 EU Transport in figures, the statistical pocketbook 2020, https://ec.europa.eu/transport/media/media-
corner/publications_en  
3 https://www.cedelft.eu/publicatie/stream_freight_transport_2016/1855, TRT 
4 In particular, emissions of sulphur oxides (SOx), nitrous oxides (NOx) and their derivative (e.g. ozone) as well as 
primary and secondary particulate matter (PM) 
5 Notably emissions of carbon dioxide (CO2). When relevant, other non-CO2 greenhouse gases will also be considered in 
this report, in particular methane (CH4) and nitrous oxide (N2O).  
6 EEA, https://www.eea.europa.eu/data-and-maps/data/data-viewers/greenhouse-gases-viewer  
7 COM(2019) 640 final 
8 COM(2020) 80 final and COM(2020) 563 final 

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2020, the European Council endorsed the binding EU target of a net domestic reduction of 
at least 55% in GHG emissions by 2030 compared to 19909.   

The 2030 Climate Target Plan (CTP)10 adopted in September 2020 sets out in more detail 
the steps towards climate-neutrality by 2050. The Commission has already indicated in the 
EGD  and  2030  CTP  that  it  will  propose  to  deploy  various  complementary  policy 
instruments  (‘basket  of  measures’)  to  ensure  that  maritime  transport  fairly  contributes  to 
the increased EU climate effort, along with the measures agreed at global level within the 
International  Maritime  Organization  (IMO).  The  interaction  between  these  policy 
instruments in described in details in Section 1.2. 

The Commission strategy for sustainable and smart mobility11 defines a framework of EU 
measures for the transport sector in line with the political ambitions of the EGD and of the 
2030  CTP,  and  in  synergy  with  zero  pollution  efforts12.  This  strategy  sets  the  course  of 
action for each mode of transport to decrease its carbon footprint in line with the objective 
of cutting GHG emissions by at least 55% by 2030 and reaching EU climate neutrality by 
2050. It also sets a number of milestones for the transport sector, drawing on the common 
analytical work underpinning the 2030 Climate Target Plan and the Sustainable and Smart 
Mobility  Strategy,  while  considering  deploying  a  broad  mix  of  policy  instruments, 
including  carbon  pricing  and  a  moderate  increase  in  the  energy  and  transport  sectoral 
regulatory policy ambition. Furthermore, the strategy acknowledges the severe effects that 
the  COVID-19  pandemic  has  had  on  the  entire  transport  sector  including  maritime.  The 
public  support  mobilized  to  help  the  economy  recover  should  create  a  leap  forward  to  a 
sustainable  and  smarter  future  by  accelerating  the  decarbonisation  and  modernisation  of 
maritime  transport,  reducing  its  negative  impact  on  the  environment  while  safeguarding 
safety and competitiveness. 

As  part  of  the  ‘Fit  for  55  package’,  the  Commission  aims  at  proposing  a  package  of 
initiatives  (e.g.  the  revision  of  the  EU  Emissions  Trading  System,  an  amendment  to  the 
Renewable Energy Directive, the revision of the Energy Tax Directive, the revision of the 
Directive  on  deployment  of  alternative  fuels  infrastructure,  etc.)  that  together  with  the 
‘ReFuelEU  Aviation’  and  ‘FuelEU  Maritime’  initiatives,  will  deliver  on  the  increased 
ambition to cut economy-wide GHG emissions by at least 55% by 2030. 

9 Source: https://www.consilium.europa.eu/media/47296/1011-12-20-euco-conclusions-en.pdf 
10 COM(2020) 562 final  
11 COM(2020) 789 final 
12 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12588-EU-Action-Plan-Towards-a-Zero-
Pollution-Ambition-for-air-water-and-soil   

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1.2 

Interaction between policy tools to address maritime CO2 emissions: the ‘basket 
of measures’ 

The interaction and expected contribution of the basket of measures to the overall carbon 
neutrality  objective  has  been  assessed  in  details  as  part  of  the  CTP  impact  assessment, 
which  involved  contributions  from  all  relevant  initiatives  to  reach  the  55%  increased 
ambition and, ultimately, the carbon neutrality target by 2050. All the policy scenarios of 
the Climate Target Plan impact assessment include a combination of a pricing mechanism 
in maritime as well as a fuel-specific measures to ensure minimum uptake and deployment 
of renewable and low carbon fuels.   

The unsatisfactory progress in the reduction of emissions from shipping can be explained 
by  insufficient  incentives  for  operators  to  cut  emissions  and  by  the  lack  of  mature, 
affordable, and globally utilisable technological alternatives to fossil fuels in the sector. A 
number  of  market  failures  –  including  negative  externalities;  interdependencies  between 
supply,  distribution  and  demand  of  fuels;  split  incentives;  lack  of  information  on  future 
regulatory requirements; long life span of assets (vessels and bunkering infrastructure); and 
insufficient access to finance – partly cause and reinforce these problems.  

A basket of measures is considered necessary to address these various and distinct market 
failures  hindering  the  deployment  of  mitigation  actions  in  the  sector.  Beside  the  FuelEU 
Maritime  initiative  that  aims  at  increasing  the  demand  of  RLF  a  proposal  to  extend  the 
European  emissions  trading  system  (ETS)13  to  maritime  and  a  proposal  to  review  the 
Energy  Taxation  Directive  (ETD)14  are  part  of  the  ‘Fit  for  55’  package.  These  two 
initiatives  should  ensure  that  the  price  of  transport  reflects  the  impact  it  has  on  the 
environment, health and energy security.  

In  addition,  the  basket  of  measures  includes  the  review  of  several  other  directives, 
including  the  Alternative  Fuels  Infrastructure  Directive  (AFID)15  and  the  Renewable 
Energy  Directive  (RED  II)16,  part  of  the  ‘Fit  for  55’  package.  Next  to  these  revised 
legislations, the Commission will address the need for additional research and innovation 
(R&I)  activities,  in  particular  through  the  co-programmed  Zero  Emissions  Waterborne 
Transport  partnership  proposed  by  the  Waterborne  Technology  Platform  under  Horizon 
Europe17. It will also revise the Guidelines on State aid for environmental protection and 

13 Directive 2003/87/EC  
14 Council Directive 2003/96/EC  
15 Directive 2014/94/EU – the Directive is currently being evaluated with a view to a possible revision: 
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12251-Low-emission-vehicles-improving-the-
EU-s-refuelling-recharging-infrastructure  
16 Directive (EU) 2018/2001– the revision process for this Directive has already been launched: 
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12553-Revision-of-the-Renewable-Energy-
Directive-EU-2018-2001  
17 https://www.waterborne.eu/  

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energy18  in  line  with  the  policy  objectives  of  the  EGD,  which  should  allow  adequate 
funding  of  the  sector’s  green  transformation  (including  for  deployment  of  on-shore 
charging infrastructures), while avoiding any distortion of competition. 

Looking more specifically at proposed actions, there is currently no mechanism, neither at 
the  IMO  level  nor  in  the  EU,  to  correct  for  the  presence  of  negative  externalities  in  the 
sector.  This  prevents  operators  from  taking  into  account,  in  their  operational  and 
investment  choices,  the  social  cost  of  their  activity  in  terms  of  climate  change  and  air 
pollution.  The  economic  literature  indicates  pricing  mechanisms  as  the  instruments  of 
choice to ‘internalise’ external costs. The main examples would be a tax fixed at the level 
of  the  external  cost,  or  a  ‘cap  and  trade’  instrument,  such  as  the  EU  emission  trading 
system (ETS), that sets a limit to the overall emissions and lets the market determine their 
appropriate price. Both are described as ‘market-based measures’ (MBMs).  

The Commission proposes to give an increasing role to ETS because it has proven to be an 
effective tool in reducing GHG emissions. The  implementation of carbon pricing policies 
in  the  maritime  transport  sector  is  subject  to  another  comprehensive  impact  assessment 
presented in the framework of the ‘Fit for 55’ package. In general, emissions trading can 
achieve  GHG  emissions  reductions  cost‑ effectively  and  provides  a  correct  price  signal 
that influences decisions of operators, investors and consumers. 

However, carbon pricing does not address  all barriers to the deployment of low and zero 
emissions solutions. Additional policy actions are necessary to ensure that other obstacles 
to  investments  in  clean  energy  technologies  and  infrastructure  are  removed,  thereby 
reducing  abatement  costs  and  complementing  the  action  of  the  ETS.  This  is  particularly 
relevant to support mitigation measures – such as the use of RLF in the maritime transport 
sector – that have a high potential to reduce emissions in the future but which, presently, 
face high abatement costs as well as specific market barriers. 

Achieving  significant  reductions  in  CO2  emissions  of  international  maritime  transport  by 
2050,  would  require  using  both  less  energy  (increasing  energy  efficiency)  and  a  cleaner 
type  of  energy  (using  RLF).  While  a  carbon  price  is  likely  to  further  drive  energy 
efficiency improvements and narrow the price gap between conventional and low-emission 
technologies,  its  ability  to  support  the  deployment  of  RLF  technologies  in  the  maritime 
sector would strongly depend on its actual price level, which is unlikely to reach sufficient 
levels for this purpose in the short to medium term. These aspects are further examined and 
presented in greater detail in Section 5.3.1.  

Similarly, legislation dealing with fuel supply (RED II) and infrastructure (AFID) has not 
had  a  significant  impact  on  the  uptake  of  RLF  in  the  maritime  sector  and  needs  to  be 

18 Communication from the Commission (2014/C 200/01), Guidelines on State aid for environmental protection and 
energy 2014-2020; the open public consultation runs between 12/11/2020 – 07/01/2021 

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complemented by measures that are capable of creating a demand for RLF. In addition, the 
review of the RED II is not be able to address the high risk of fuel bunkering outside the 
EU  for  the  shipping  sector.  Further  considerations  on  this  issue  are  presented  in 
Section 5.3.3.  

This  impact  assessment  report  looks  specifically  at  how  to  address  the  specific  market 
barriers preventing the deployment of RLF in the maritime transport sector, in the context 
of the overall approach to maritime transport sustainability. 

Summing  up,  the  proposed  approach  is  to  deploy  various  complementary  policy 
instruments (‘basket of measures’) to address various and distinct market failures. In this 
context,  the  impact  assessment  accompanying  the  EU’s  2030  CTP  has  looked  at  the 
interaction between measures focusing on fuels obligations and carbon pricing19. 

1.3  EU approach to alternative fuels in maritime transport 

The  importance  of  developing  and  introducing  alternative  and  cleaner  fuels  in  maritime 
transport  is  present  in  several  policy  documents  adopted  by  the  Commission  in  recent 
years,  such  as  the  European  Strategy  for  Low-Emission  Mobility  of  201620;  the 
Commission Communication of 2013 on integrating maritime transport emissions in EU’s 
GHG  reduction  policies21;  and  the  2016  Implementation  report  of  the  EU  Maritime 
Transport Strategy22.  

The  June  2020  Council  Conclusions  on  “EU  Waterborne  Transport  Sector  –  Future 
outlook:  Towards  a  carbon-neutral,  zero  accidents,  automated  and  competitive  EU 
Waterborne  Transport  Sector”23  also  stress  the  need  to  support  the  development  of 
alternative fuels for use in all segments of waterborne transport. The document presents a 
vision  for  green  and  carbon-neutral  ports  and  coastal  areas  that  includes  the  use  of 
liquefied  natural  gas  (LNG)  as  a  transitional  fuel  and  the  provision  of  onshore  power 
supply and alternative fuels. The Council Conclusions also emphasize the need to ensure 
sufficient financial support through Horizon Europe. 

There  is  currently  no  regulatory  framework  in  the  EU  specifically  addressing  the  use  of 
RLF  in  maritime  transport.  However,  the  EU  acquis  already  contains  a  number  of  legal 
requirements related to this initiative, notably:  

  The  AFID  establishes  requirements  for  the  deployment  of  an  appropriate  number  of 
LNG bunkering points in the ports of the TEN-T Core Network by 31 December 2025 
and those of the TEN-T Comprehensive Network by 31 December 2030. The Directive 

19 SWD(2020) 176 final 
20 COM(2016)501 final  
21 COM(2013) 479 final 
22 SWD(2016) 326 final 
23 https://www.consilium.europa.eu/media/44311/st08648-en20.pdf  

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provides also for the installation of shore-side electricity supply as a priority in ports of 
the TEN-T Core Network, and in other ports, by 31 December 2025, unless there is no 
demand  and  the  costs  are  disproportionate  to  the  benefits,  including  environmental 
benefits.  

  The RED II establishes an obligation on fuel suppliers to ensure a minimum mandatory 
share  of  14%  of  renewable  energy  within  the  final  consumption  of  energy  in  the 
transport sector by 2030. Although this provision targets mainly the fuels used in road 
and  rail  transport,  the  renewable  fuels  supplied  to  the  maritime  sector  (except  those 
produced from food and feed crops) may also be considered for compliance, and would 
count 1.2 times their energy content.  

  The  Monitoring,  Reporting  and  Verification  Regulation  (MRV)24  establishes  the 
system  to  monitor  and  report  CO2  emissions  from  ships  above  5000  gross  tonnes 
sailing to or from ports of the EEA. It contains methods for calculating CO2 emissions 
which rely on applying CO2 emission factors to data on fuel consumption25. The MRV 
already contains  default  values for emission factors of fuels  other than the traditional 
liquid  marine fuels26  (such as  Liquefied Petroleum  Gas,  LNG, methanol  and ethanol) 
and  it  provides  that  “appropriate  emission  factors  shall  be  applied  for  biofuels, 
alternative non-fossil fuels and other fuels for which no default values are specified”.  
  The Sulphur Directive27 sets the maximum sulphur content for the fuels used by ships 
in  Europe  to  protect  the  health  of  coastal  citizens  and  their  environment  from  the 
impacts  of  SOx  emissions.  It  also  encourages  compliance  beyond  EU  legislation 
through the use of alternative fuels and on-shore power supply (OPS) for ships at berth 
as alternative emission abatement methods. Furthermore, it allows the use of mixtures 
of heavy fuel  oil (HFO) and boil-off liquefied natural  gas  to  comply with the stricter 
sulphur  requirement  at  berth  or  in  SOx-Emission  Control  Area  (SECA)  or  the  use  of 
biofuels and their mixture with HFO.  

On  8  July  2020,  the  Commission  also  adopted  a  new  dedicated  Strategy  on  hydrogen  in 
Europe28,  in  parallel  with  the  Strategy  on  energy  system  integration29.  These  strategies 
bring together different strands of action, from R&I over production and infrastructure to 
the  international  dimension.  For  waterborne  transport,  the  importance  of  hydrogen  is 
highlighted  as  a  stepping  stone  to  the  production  of  derived  fuels  such  as  methanol  or 
ammonia  and  synthetic  “drop-in”  fuels,  which  can  be  used  with  existing  technology  and 
infrastructure.  The  importance  of  biofuels  is  also  recognised  in  particular  for  “hard-to-
decarbonise” sectors, such as aviation and maritime transport.  

24 Regulation (EU) 2015/757  
25 Annex I of the Regulation expresses the  method for calculating CO2 emissions as the product of the amount of fuel 
used multiplied by the appropriate emission factor corresponding to the type of fuel used. 
26 Currently, 97% of the fuel reported under MRV is constituted of HFO, MGO or MDO.  
27 Directive (EU) 2016/802  
28 COM(2020) 301 final  
29 COM(2020) 299 final  

11 

 
 
                                                           
The  2030  CTP,  adopted  in  September  202030,  mentions  that  “Both  the  aviation  and 
maritime  sectors  will  need  to  scale  up  efforts  to  improve  the  efficiency  of  aircraft,  ships 
and their operations and to increase the use of sustainably produced renewable and low-
carbon  fuels.  This  will  be  assessed  in  greater  detail  in  the  context  of  the  ReFuelEU 
Aviation  and  FuelEU  Maritime  initiatives  that  aim  to  increase  the  production  and  the 
uptake  of  sustainable  alternative  fuels  for  these  sectors.  The  necessary  technology 
development  and  deployment  has  to  happen  already  by  2030  to  prepare  for  much  more 
rapid change thereafter.” 

1.4 

International context  

Given  the  strong  international  nature  of  maritime  transport,  the  sector  is  also  subject  to 
international rules and conventions adopted by the IMO. The IMO is the specialised United 
Nations’ agency acting as the global standard-setting authority for the safety, security and 
environmental performance of international shipping31.  

The main set of international rules on the environmental performance of ships is contained 
in the International Convention for the Prevention of Pollution from Ships (MARPOL)32. 
While  MARPOL  does  not  contain  explicit  mandatory  requirements  on  the  use  of 
alternative fuels from ships, it sets a series of rules33 regarding emissions to air, which may 
provide an incentive for the use of alternative energy sources.  

The  IMO  has  adopted  in  2011  the  Energy  Efficiency  Design  Index  (EEDI),  which  sets 
mandatory  energy  efficiency  standards  for  all  new  built  ships,  and  in  2018  the  Initial 
Strategy on the reduction of GHG emissions from ships34. Discussions are ongoing on the 
implementation  of  the  2018  IMO’s  Initial  Strategy  on  the  reduction  of  GHG  emissions 
from  ships,  starting  with  energy  efficiency  standards  to  set  minimum  improvement 
thresholds both in terms of technical and operational carbon intensity of existing ships.35 

The  strategy  recognises  that  the  “global  introduction  of  alternative  fuels  and/or  energy 
sources for international shipping will be integral to achieve the overall ambition”. Within 

30 COM(2020) 562 final 
31 http://www.imo.org/EN/Pages/Default.aspx - All EU Member States are also IMO members. 
32 The convention covers the prevention of pollution of the marine environment by ships from operational or accidental 
causes and contains a series of annexes addressing pollution from oil, noxious liquid substances in bulk, packaged 
harmful substances, sewage from ships, garbage from ships and the prevention of air pollution from ships. 
http://www.imo.org/en/About/Conventions/ListOfConventions/Pages/International-Convention-for-the-Prevention-of-
Pollution-from-Ships-(MARPOL).aspx  
33 This is the case for Regulations 13 and 14 of MARPOL Annex VI respectively on NOx, SOx and PM. 
34  The  full  text  of  the  Initial  IMO  Strategy  can  be  found  in  the  IMO  submission  to  the  Talanoa  dialogue: 
The 
https://unfccc.int/sites/default/files/resource/250_IMO%20submission_Talanoa%20Dialogue_April%202018.pdf 
IMO  initial  strategy  envisages  in  particular  to  reduce  CO2  emissions  per  transport  work,  as  an  average  across 
international shipping, by at least 40% by 2030, pursuing efforts towards 70% by 2050, compared to 2008. It also expects 
to peak GHG emissions from international shipping as soon as possible and to reduce the total annual GHG emissions by 
at least 50% by 2050 compared to 2008 whilst pursuing efforts towards phasing them out on a pathway of CO2 emissions 
reduction consistent with the Paris Agreement temperature goals. The strategy will be subject to a revision in 2023. 
35 https://www.imo.org/en/MediaCentre/PressBriefings/Pages/42-MEPC-short-term-measure.aspx 

12 

 
 
                                                           
the list of identified candidate short-term measures (meant to enter into force before 2023), 
the IMO includes the promotion of uptake of alternative low-carbon and zero-carbon fuels 
and  the  provision  of  shore-side  electricity.  It  also  calls  for  the  development  of  robust 
lifecycle  GHG/carbon  intensity  guidelines  for  all  types  of  fuels,  to  prepare  a  programme 
for effective uptake of alternative low-carbon and zero-carbon fuels. The discussion on the 
uptake of alternative fuels as well as on market-based measures (MBM) is expected to start 
at IMO in the course of 2021, also based on the EU proposal on fuel lifecycle guidelines 
based on sustainability and GHG emissions saving criteria 36.  

The International Code of Safety for Ships using Gases or other Low-flashpoint Fuels (IGF 
Code)37 also  entered into force on 1 January 2017, along with new training requirements 
for  seafarers  working  on  those  ships.  These  rules  contain  mandatory  provisions  for  the 
arrangement,  installation,  control  and  monitoring  of  machinery,  equipment  and  systems 
using low-flashpoint fuels, focusing initially on LNG.  

1.5  Trajectories for renewable and low carbon fuels  

The European Green Deal has set the key objective to deliver a 90% reduction in transport-
related greenhouse gas emissions by 2050, drawing on the in-depth analysis underpinning 
the 2050 long-term strategy38. The common scenarios underpinning the Impact Assessment 
accompanying  the  2030  Climate  Target  Plan39  and  the  Staff  Working  Document 
accompanying  the  Sustainable  and  Smart  Mobility  Strategy  confirmed  that  for  achieving 
climate  neutrality  by  2050  transport  emissions  (including  intra-EU  aviation  and  intra-EU 
maritime) would need to decrease by 95-96% by 2050 relative to 2015 (94-96% relative to 
1990).  When  considering  all  intra-EU  and  extra-EU  maritime  transport,  the  emissions 
reductions are projected at around 91-92% relative to 2015 (89-90% relative to 1990). The 
lower  emissions  reductions  in  transport  relative  to  other  sectors  like  for  example  power 
generation  is  in  recognition  of  the  fact  that  emissions  in  some  transport  modes,  in 
particular  aviation  and  maritime,  are  more  difficult  to  abate.  The  EU’s  pathway  towards 
climate neutrality, covering all sectors of the economy, is provided in Figure 1. 

36 EU submission to the 7th meeting of the Intersessional Meeting of the Working Group on Reduction of GHG emissions 
from ships from the IMO (ISWG-GHG 7/5/9), which suggests methodological elements on how to develop fuel lifecycle 
guidelines  based  on  sustainability  and  GHG  emissions  saving  criteria  to  incentivize  the  uptake  of  alternative  fuels  at 
global level. 
37 http://www.imo.org/en/OurWork/Safety/SafetyTopics/Pages/IGF-Code.aspx  
38 COM (2018) 773 
39 SWD/2020/176 final 

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Figure 1: The EU’s pathway to sustained economic prosperity and climate neutrality, 1990-2050 

Source: COM(2020) 562 final. Commission Communication “Stepping up Europe’s 2030 climate ambition Investing in a 
climate-neutral future for the benefit our people 

Among  the  transport  modes,  road  and  rail  transport  would  need  to  be  almost  fully 
decarbonised by 2050. Lower emissions reductions are projected in aviation and maritime, 
due to the more limited technological options available for these sectors. Nevertheless, air 
transport  sector  would  need  to  achieve  emissions  reductions  of  at  least  52-59%  by  2050 
relative  to  2015  (equivalent  to  14-25%  reduction  relative  to  1990)  and  international 
maritime of at least 84-86% (equivalent to 80-82% emissions reductions relative to 1990). 

The  common  economic  assessment  underpinning  the  2030  Climate  Target  Plan  and  the 
Sustainable  and  Smart  Mobility  Strategy,  looked  at  a  range  of  pathways/scenarios  to 
explore  the  delivery  of  the  increased  ambition  of  cutting  the  economy-wide  GHG 
emissions  by  at  least  55%  by  2030  and  achieving  climate  neutrality  by  2050.  These 
pathways/scenarios were constructed around a set of specific policies for all sectors of the 
economy that either focus on carbon pricing or focus on regulatory measures, or combine 
the  two  types  of  instruments.  For  the  maritime  transport,  the  same  policy  instruments 
(including ‘FuelEU Maritime’ initiative) were included in all scenario configurations.  

The  staff  working  document  accompanying  the  Sustainable  and  Smart  Mobility  Strategy 
describes the trajectories for renewable and low carbon fuels in more detail40, drawing on 
the  common  economic  analysis  underpinning  the  2030  Climate  Target  Plan  and  the 

40 Source: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52020SC0331 

14 

 
 
 
 
                                                           
Sustainable  and  Smart  Mobility  Strategy.  These  trajectories  are  derived  in  a  way  that 
enables kick starting the scale-up of renewable and low carbon fuels in the maritime sector 
from  2025  onwards  and  their  large  scale  deployment  by  2050,  while  ensuring  the 
consistency  with  the  required  overall  GHG  emissions  reductions  by  2030  and  2050, 
preserving the competitiveness of the sector, promoting innovation, and ensuring feedstock 
availability  for  renewable and low carbon fuels  in all energy  and transport sectors in  the 
transition  towards  a  climate  neutral  economy.  The  pathways/scenarios  delivering  a 
reduction  in  the  EU  GHG  emissions  by  at  least  55%  by  2030  and  climate  neutrality  by 
2050  show  that  renewable  and  low  carbon  fuels  should  represent  6  to  9%  of  the  energy 
used in the international maritime sector in 2030 and 86 to 88% by 205041,42.  

When  considering  a  pathway/scenario  that  strengthens  and  further  expands  the  carbon 
pricing  to  the  road  transport  and  buildings  sectors,  be  it  via  EU  ETS  or  other  carbon 
pricing  instruments,  in  combination  with  low  intensification  of  transport  policies  and  no 
intensification  of  energy  efficiency  and  renewables  policies,  the  analysis  shows  that 
renewable  and  low  carbon  fuels  should  represent  at  least  6%  of  the  energy  used  in  the 
international maritime sector in 2030 and 86% by 2050.  

When considering a pathway/scenario that assumes high increase of the ambition of energy 
efficiency, renewables and transport policies, while keeping the EU ETS scope unchanged, 
renewable  and  low  carbon  fuels  should  represent  close  to  9%  of  the  energy  used  in  the 
international maritime sector in 2030 and 88% by 2050. 

Finally,  the  pathway/scenario  focusing  on  a  combination  of  carbon  pricing  and  medium 
intensification of regulatory measures in all sectors of the economy shows that renewable 
and  low  carbon  fuels  should  represent  7.5%  of  the  energy  used  in  the  international 
maritime sector in 2030 and 86% by 2050.  

All the pathways described above are consistent with the increased ambition of cutting the 
economy-wide GHG emissions by at least 55% by 2030 and achieving climate neutrality 
by 2050. They all deliver a 90% reduction in transport emissions by 2050, in line with the 
European  Green  Deal  Communication  and  the  Sustainable  and  Smart  Mobility  Strategy, 
and 80-82% emissions reductions in  the international  shipping sector by  2050 relative to 
1990  (equivalent  to  88-89%  emissions  reductions  relative  to  2008)43.  In  addition,  the 
impact  assessment underpinning the 2030 Climate Target  Plan44 noted particular benefits 
in  deploying  a  broad  mix  of  policy  instruments,  including  carbon  pricing  and  increased 
energy and transport sectoral regulatory policy ambition, and clearly suggested that there is 

41  If  the  scope  of  EU  greenhouse  gas  emissions  target  would  be  additionally  extended  to  all  aviation  and  maritime 
emissions, the renewable and low carbon fuels would represent 13.5% of the energy used in the international maritime 
sector and 88% by 2050. 
42 The shares of renewable and low carbon fuels presented in this section do not account for the contribution of on-shore 
supply.  
43  The  choice  of  2008  as  a  base  year  for  the  emissions  reduction  projections  in  maritime  transport  is  made  to  allow 
consistency with the IMO objectives that are all expressed in relation to 2008. 
44 Source: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52020SC0176  

15 

 
 
                                                           
no single policy instrument being capable of achieving all the objectives considered in the 
assessment alone. 

This impact assessment takes as starting point the pathway for renewable and low carbon 
fuels that represent 7.5% of the energy used in the international maritime sector by 2030 
and 86% by 2050 in the scenario focusing on a combination of carbon pricing and medium 
intensification  of  regulatory  measures  in  all  sectors  of  the  economy,  while  additionally 
considering the contribution of the on-shore power supply. It ensures consistency with the 
2030  Climate  Target  Plan  and  with  the  other  initiatives  of  the  ‘Fit  for  55’  package  by 
delivering  the  necessary  contribution  in  terms  of  emissions  reductions  to  the  increased 
ambition  of  cutting  the  economy-wide  GHG  emissions  by  at  least  55%  by  2030  and 
achieving climate neutrality by 2050. The impact assessment focuses on the specific design 
of  the  policy  option  that  would  best  allow  to  reach  this  contribution.  A  qualitative 
assessment of the implications of lower/higher trajectory for the renewable and low carbon 
fuels is however provided in Sections 5.4 and 6.1.2.   

An  update  of  the  pathway/scenario  focusing  on  a  combination  of  carbon  pricing  and 
medium  intensification  of  regulatory  measures  in  all  sectors  of  the  economy  for  the 
purpose of the ‘Fit for 55’ package, while also reflecting the COVID-19 pandemics,  the 
National  Energy  and  Climate  Plans  and  refining  the  policy  design  of  the  initiatives, 
confirms  that  maritime  transport  effectively  contributes  to  the  EU  climate  goals  while 
considering the central trajectory for the renewable and low carbon fuels. 

2.  PROBLEM DEFINITION 

2.1  What is the problem? 

Currently,  the  fuel  mix  in  the  maritime  sector  relies  entirely  on  fossil  fuels.  The  vast 
majority of the 44 million tonnes of fuel consumed and reported by ships within MRV in 
2018  concerned  liquid  fossil  fuels.  The  use  of  LNG  was  only  3%  of  the  total  amount  of 
fuel  consumed  (mostly  by  LNG  and  gas  carriers)  and  other  alternatives,  in  particular 
renewable fuels, were negligible45. According to the fourth IMO GHG study, 98.4% of all 
engines used in the fleet in 2018 were conventional fuel oil engines and 0.52% were LNG 
engines (including dual-fuel engines)46.  

The ship traffic monitored under the MRV accounted for more than 138 million tonnes of 
CO2 emissions in 201847. This represents around 11% of all EU transport CO2 emissions 

45 European Commission, SWD(2020) 82 final, Report from the Commission 2019 Annual Report on CO2 Emissions 
from Maritime Transport https://ec.europa.eu/clima/sites/clima/files/transport/shipping/docs/swd_2020_82_en.pdf  
46 The remaining percent is constituted of  methanol engines, gas and steam turbines, sails, batteries and non-propelled 
vessels. 
47 The MRV Regulation covers CO2 emissions produced by ships above 5000 gross tonnage carrying out voyages from or 
to a port in the EEA, when transporting goods or passengers for commercial purposes. 

16 

 
 
                                                           
and  3-4%  of  total  EU  CO2  emissions48.  EU  international  shipping  CO2  emissions  are 
projected to grow by over 30% between 2015 and 2050 under current trends and policies, 
also  considering  the  impacts  of  the  COVID-19  pandemic49,50.  Since  emissions  had  fallen 
between 2008 and 2015, this implies a stabilisation of CO2 emissions by 2050 relative to 
2008 levels. This development is however not in line with the climate neutrality objective.  

Emissions occurring when the ships were at berth (anchored or navigating in EEA ports) 
amounted  to  around  6%  of  the  total  CO2  emissions  as  reported  under  the  MRV.  In 
addition, emissions of sulphur oxides (SOx), nitrogen oxides (NOx), and particulate matter 
(PM) significantly contributed to air pollution in coastal areas and port cities, where ship 
engines are still being used to produce the necessary power during the port visit51. There 
are hotspot  areas  in  Europe where the  contribution  of shipping to  air pollutant emissions 
52. While the situation 
can be up to 80% for NOx and SO2 and up to 25% for primary PM2.5
is  improving  with  the  use  of  cleaner  fuels  resulting  from  the  introduction  of  the  Sulphur 
Directive and the establishment of ECAs53 in Northern Europe, as confirmed by the 2018 
Commission report on the implementation  of the Sulphur Directive54, air quality  remains 
an important area of concern for port cities. This is also clearly recognised by the industry; 
in the past five years, air quality ranked first among the top 10 environmental priorities of 
the  port  sector  as  illustrated  in  the  environmental  report  from  the  European  Sea  Ports 
Organisation (ESPO)55. While the use of on-shore power supply (OPS) for ships at berth 
would allow removing these emissions, its uptake has so far remained negligible56.  

The  almost  exclusive  reliance  on  fossil  fuels  constitutes  an  important  risk  to  the  sector’s 
ability  to  contribute  effectively  to  the  carbon  neutrality  objectives  in  the  long  term.  As 
explained in Section 1.5, RLF should provide 6-9% of the international maritime transport 
fuel  mix  in  2030  and  86-88%  by  2050  to  contribute  to  the  EU  economy-wide  GHG 
emissions  reduction  targets57.  This,  in  combination  with  carbon  pricing  and  other 

48 By limiting the monitoring requirements to large ships, above 5000 gross tonnage, the MRV Regulation covers around 
90% of all CO2 emissions, whilst only including ca 55% of all ships calling into EEA ports. 
49  Annex  4  provides  the  assumptions  and  results  for  developments  under  current  trends  and  policies  (i.e.  the  baseline 
scenario). 
50 In comparison, emissions from international shipping at global level are expected to continue growing to around 90-
130%  of  2008  emissions  by  2050  for  a  range  of  plausible  long-term  economic  and  energy  scenarios  (IMO,  Fourth 
Greenhouse  Gas  Study,  2020).  These  projections  however  do  not  take  into  account  the  impacts  of  the  COVID-19 
pandemics.   
51 See EEA, 2017, ‘Aviation and shipping — impacts on Europe's environment’, European Environment Agency Report 
No 22/2017, in particular section 4.2.: https://www.eea.europa.eu/publications/term-report-2017  
52 EEA, 2013, The impact of international shipping on European air quality and climate forcing, Technical 
Report No 4/2013, European Environment Agency, https://www.eea.europa.eu/publications/the-impact-of-international-
shipping 
53https://www.iiasa.ac.at/web/home/research/researchPrograms/air/Shipping_emissions_reductions_main.pdf  
54 COM(2018) 188 final 
55 https://www.espo.be/media/Environmental%20Report-WEB-FINAL.pdf  
56 For more details see chapter 2.2.4 
57  Drawing  on  the  common  economic  assessment  underpinning  the  2030  Climate  Target  Plan  and  the  Sustainable  and 
Smart  Mobility  Strategy,  the  scenario  assessing  a  combination  of  carbon  pricing  and  regulatory  measures  (so-called 
MIX) projects a share of 7.5% for 2030 and 86% by 2050. 

17 

 
 
                                                           
operational and technical measures would allow the sector to reduce its CO2 emissions by 
22%  by  2030  and  88-89%  by  2050  compared  to  2008  levels  (equivalent  to  80-82% 
reduction relative to  1990)58.  In the same vein,  the  IMO  estimates that about  64% of the 
total amount of CO2 reduction in 2050 would result from the use of alternative fuels59. 

In addition, the slow uptake of RLF in the maritime sector is an issue to be addressed in the 
short term because the adoption of new fuels in the sector takes time. LNG provides a good 
illustration of the time necessary for adoption of new fuels in the sector; while LNG was 
primarily used already as fuel in Norway in 2000, it took 13 years for it to spread outside 
Norway60. Still today, LNG powered ships represent a minor fraction of the fleet, despite 
the  competitive  fuel  price  and  the  attractiveness  of  this  option  to  meet  the  existing 
requirements on SOx and NOx emissions61. 

In the open public consultation (OPC), 95% (129/136) of the respondents confirmed that it 
is  ‘very  relevant’  or  ‘relevant’  to  promote  the  uptake  of  sustainable  alternative  fuels  and 
diversify the fuel mix of maritime transport to accelerate the decarbonisation of shipping. 
Without  action  at  EU  level,  59%  (19/32)  of  the  respondents  to  the  targeted  consultation 
(TC)  think  that  by  2030,  the  use  of  RLF  will  remain  the  same  as  today  for  ships  in 
navigation. For ships at berth, the share of TC respondents is 44% (14/32).62 

The main problems that this initiative will address therefore concern:  (1) the low uptake 
of RLF by ships calling EU ports and (2) and the low uptake of zero-pollution fuels by 
ships at berth in EU ports.  

Although closely resembling, and sharing most of the problem drivers, these are assessed 
as  distinct  problems  because  of  two  important  aspects  that  differentiate  them.  The  first 
relates to the consequence of the (non)use of RLF: while the climate effect does not change 
with respect to the place of emission, the impact of air pollution is considerably higher for 
ships at berth. This might justify a different and more ambitious policy in terms of type and 
use  of  RLF  in  ports.  Indeed,  fuels  that  perform  well  in  terms  of  both  GHG  and  local 
pollutants  (NOx  or  PM),  such  as  electricity  or  hydrogen,  are  much  preferable  for  use  at 
berth than fuels that perform well on GHG but less so on local pollutants, as is the case of, 
for example, advanced biofuels and e-fuels. The second aspect relates to the availability of 
additional technologies for use in ports, where energy can be drawn from shore and use of 

58  The  choice  of  2008  as  a  base  year  for  the  emissions  reduction  projections  in  maritime  transport  is  made  to  allow 
consistency with the IMO objectives that are all expressed in relation to 2008.  
59 IMO, Fourth Greenhouse Gas Study, 2020. The study was submitted to the Marine Environment Protection Committee 
(MEPC)  in  July  2020,  as  document  MEPC  75/7/15    -  the  study  can  be  downloaded  via  the  IMODOCS  website 
(registration required). 
60 DNV GL (2019), Comparison of Alternative Marine Fuels, Study commissioned by SEA-LNG: https://sea-lng.org/wp-
content/uploads/2020/04/Alternative-Marine-Fuels-Study_final_report_25.09.19.pdf  
61 Note, however, that use of gas from fossil sources will not be sufficient to meet the EU climate objectives. 
62 For ships in navigation, while 28 % think RLF use will increase moderately. For ships at berth, that figure is 41 %. 
Looking  towards  2050,  the  majority  of  TC  respondents  expects  the  RLF  share  to  increase  either  moderately  or 
significantly both for ships in navigation (69 %) and at berth (72 %). 

18 

 
 
                                                           
fuels with low energy density is less problematic. Also this aspect might justify a different 
approach for ships at berth.  

These  two  problems  need  to  be  addressed  because  they  hamper  the  sector’s  ability  to 
effectively decarbonise in the long term, while also reducing the air pollution emissions in 
the  ports.  Ensuring  a  higher  penetration  of  RLF,  along  with  energy  efficiency 
improvements is critical to bring maritime transport in line with the European ambition of 
climate-neutrality by 2050 and reduce air pollution from ships in ports and coastal cities. 

2.2  What are the problem drivers? 

Several drivers underpin these problems and result from significant technological, market 
or  regulatory  barriers.  They  consist  in  the  lack  of  predictability  of  the  regulatory 
environment  and  the  resulting  high  risk  for  investments;  the  uncertainty  over  alternative 
technologies and the risk for first movers; the higher costs of low-carbon technologies in 
the  absence  of  significant  levels  of  production;  the  interdependency  between  demand, 
supply  and  distribution  aspects;  and  sector  specific  issues  related  to  the  possibility  of 
bunkering outside the EU. These issues are summarised in Figure 2:  

Figure 2: Problem tree 

2.2.1  Lack  of  predictability  of  the  regulatory  framework  and  high  risk  of  investment 

choices (high risk of stranded assets) 

Ships  are  costly  and  long-lived  assets;  in  accordance  with  data  from  UNCTAD,  the 
average  age  of  the  world  merchant  fleet  in  2019  was  around  21  years63,  even  though 
differences can be observed across different market segments. The age distribution of ships 
monitored in 2018 under the MRV system indicate that that the age of vessels operating in 
Europe is usually lower than the global average as ships are either relocated or sold on the 
second-hand  market.  Given  this,  it  is  important  for  ship-owners  to  anticipate  the 
framework conditions that could impact the economic value of the investment and lead to 

63 UNCTAD (2019), Review of maritime transport 2019, https://unctad.org/en/PublicationsLibrary/rmt2019_en.pdf  

19 

 
 
 
                                                           
assets  being  stranded.  This  applies  both  to  the  operating  life  of  the  vessels  and  to  their 
potential value on the second-hand market.  

Assets  would be stranded when they lose economic value well ahead of their anticipated 
useful  life64.  The  main  risk  factors  resulting  in  ships  becoming  stranded  assets  can  be 
associated  with  ship  specifications  no  longer  meeting  needs  of  demand  or  regulatory 
requirements  (e.g.  possible  introduction  of  new  standards).  In  this  context,  a  predictable 
regulatory  environment  is  very  important  for  investment  decisions.  Climate  policy  can 
reinforce the risk of stranded assets. This is mainly related to evolving standards, such as 
the increased level of energy efficiency that cannot be sustained by older equipment.  

The  importance  of  this  driver  was  also  confirmed  by  the  public  consultation.  After  the 
higher  price  of  RLF,  the  high  risk  of  investment  in  vessels  technology  and  port 
infrastructure  was  the  second  most  important  barrier  identified  by  the  respondents.  In 
addition, 61.5% (83/136) of the respondents indicated that the lack of predictability of the 
regulatory  framework  was  either  an  important  or  the  most  important  barrier  to  the 
deployment of RLF in maritime transport.  

In  the  absence  of  clear-cut  technological  choices  (see  Section  2.2.2)  and  of  a  defined 
regulatory path setting clear provisions for the decarbonisation of the future fuel mix, it is 
difficult  for operators to build a business  case  and make long-term  investment  decisions. 
Given the potential investment risks, a wait-and-see approach is likely to prevail and defer 
deployment of new technologies and hence of RLF.  

2.2.2  Low  maturity  of  new  renewable  and  low-carbon  fuels/technologies  with  high  risk 

for first movers 

The uncertainty caused by the unpredictable regulatory environment is compounded by the 
absence of a clear substitute to fossil fuels. No technological solution has yet emerged as a 
preferred choice among various alternatives. Most of the alternative technologies are at a 
low  level  of  maturity65  and  the  market  has  not  yet  started  a  process  of  deployment  and 
selection.  The  difficulty  for  the  market  to  converge  on  the  choice  of  alternative 
technologies is also due to the operating conditions of the sector, which reflect the specific 
needs  and  constraints  of  market  operators.  The  maritime  sector  is  not  uniform  and 
important differences can be observed between market segments.  

A  first  differentiation  can  be  made  between  short-sea  and  deep-sea  shipping.  In  the  EU, 
short-sea  shipping  is  defined  usually  as  maritime  transport  between  ports  situated  in 
geographical Europe, as well as on the Mediterranean and Black seas66. This type of traffic 
typically consists of relatively short routes with frequent port calls and can include fixed-

64 Smith et al. 2015, Stranded Assets and the Shipping Industry, https://www.researchgate.net/publication/321348262  
65 In terms of maturity of emission reduction options, the fourth IMO GHG study categorises all fuel options with a 
relatively low rate (evolving maturity, sometimes with some unit available).  
66 COM (1999) 317 final  

20 

 
 
                                                           
schedule  routes.  In  comparison,  deep-sea  shipping  is  mainly  characterised  by  vessels 
covering long routes, without necessarily a regular schedule (with the exception of liners). 
In practical  terms,  this  differentiation affects  the operators’ needs in  terms of quantity of 
fuel carried, energy density (energy per unit volume) and global availability of fuels.  

On  shorter  distances  and  in  ports,  lower  energy  density  is  sufficient,  already  opening 
additional decarbonisation and zero-pollution pathways (e.g. hydrogen and electrification). 
However,  currently,  these  solutions  remain  limited  to  experimental  vessels  and  very 
specific  market  segments  (e.g.  short-distance  ferries)  with  relatively  low  power 
requirements and the possibility to bunker or recharge frequently.  

An additional element concerns the compatibility of the new fuel options with the existing 
machinery (no or minor needs to retrofit the ship) and infrastructure. The performance of 
the different  fuel options in terms of air pollutant reduction can also be considered, even 
though  these  emissions  (e.g.  NOx  or  PM)  may  be  addressed  by  technical  means  such  as 
engine management and exhaust gas treatment. This is particularly relevant for the second 
problem  (low  uptake  of  zero  pollution  fuels  by  ships  at  berth),  which  as  mentioned  in 
Section 2.1 is important in these areas.  

Biofuels,  biomethane  and  drop-in  e-fuels  are  compatible  with  the  existing  assets  and 
infrastructure  (liquid  or  gaseous)  and  can  therefore  be  deployed  immediately  in  existing 
oil-  or  LNG-fuelled  vessels.  However,  the  supply  of  this  type  of  fuels  to  the  maritime 
sector is very limited and their GHG reduction potential depends on whether they can be 
produced  and  used  sustainably  at  scale  (availability  of  feedstocks,  etc.).  LNG  is  a 
technologically mature solution that substantially contributes to air pollution reduction, but 
its  contribution  towards  GHG  reduction  can  be  limited,  particularly  taking  into  account 
methane  slip,  and  depends  on  the  engine  technology67.  Other  RLF  may  be  deployable 
within existing vessels as a retrofit, but these options are at an early stage of development. 
Regarding  OPS,  the  technology  can  be  considered  to  be  at  a  mature  stage.  Based  on 
information  by  the  European  Alternative  Fuels  Observatory  (EAFO)68,  ports  in  Europe 
have  started  the  first  steps  in  using  these  installations  as  of  the  1990’s,  and  an  increased 
trend  in  their  installation  is  recorded  since  2010.  Ports  now  have  experience  with  such 
installations for different vessel types. 

The  feedback  received  from  the  consultation  activities  in  preparation  of  this  initiative 
confirmed that market actors expect using a variety of fuels still in 2050 with no dominant 
source of energy. The respondents of the targeted consultation survey indicated also their 

67 LNG does not contain sulphur, which results in (almost) no SOx emissions (95% to 100% reduction compared to HFO) 
and almost no PM-emissions (90-100% compared to HFO). NOx emissions reductions depend on the type of engine used 
but vary between 40% and 80% compared to HFO. In addition, because LNG has a higher hydrogen-to-carbon ratio in 
comparison to conventional fuels, the specific CO2 emissions are lower by around 25% compared to HFO.  The overall 
GHG  impact  depend  on  methane  slip  control  but  it  can  be  reduced  to  0%  benefits  compared  to  HFO.  EMSA  (2018) 
Guidance on LNG Bunkering to Port Authorities and Administrations,  
68 https://www.eafo.eu/  

21 

 
 
                                                           
expectation on fuels most likely to be used in 2030 and 2050, both during navigation and at 
berth.  Concerning  2030,  biofuels  are  perceived  as  most  promising  for  use  in  navigation, 
followed by batteries. Looking at 2050, the expectations are different: the categories ‘other 
decarbonised  hydrogen-derived  fuels  (including  ammonia)’  and  ‘Decarbonized  hydrogen 
(including  fuel  cells)’  received  the  highest  scores.  For  emissions  at  berth,  the  alternative 
fuel option that stands out in being promising both for 2030 and 2050 is OPS69. 

The  ‘wait  and  see’  attitude  of  market  operators  can  therefore  be  explained  with  the 
uncertainty  on  both  the  right  timing  of  investments  –  also  in  connection  with  regulatory 
requirements (see also 2.2.1) – and on the choice of technologies; all in a context of long-
lived and costly assets (vessels) and different needs in different business segments. 

2.2.3  Higher  costs  of  alternatives  compared  to  fossil  fuels  (also  due  to  insufficient 

economies of scale) 

In response to the public consultation carried out in the context of this initiative 47.8% of 
the  respondents  (65/136)  indicated  the  higher  price  of  RLF  as  a  very  relevant  barrier  to 
their uptake, which made this barrier score the highest. This problem driver is particularly 
critical as the costs of fuel is the single most important item determining the voyage costs 
of a ship, accounting for 47% of the total70.  

The  cost  of  RLF  is  generally  higher  than  that  of  fossil  fuels.  Increasing  the  production 
volumes can be expected to reduce production cost due to learning effects and economies 
of  scales,  but  the  lack  of  current  profitability  and  of  significant  volumes  of  expected 
demand forms a major barrier to investment. 

While  existing  literature  confirms  the  price  gap  between  RLF  and  conventional  fuels,  it 
also shows that the production cost ranges of biofuels and e-fuels are larger than those of 
fossil fuels. To some extent, this is caused by the fact that production systems for biofuels 
and e-fuels are newer and subject of uncertainties and on-going research. For biofuels, this 
also  relates  to  the  variety  of  biomass  feedstocks  and  feedstock  prices  and  the  variety  of 
production  technologies  in  existence.  For  e-fuels  the  wide  ranges  also  relate  to  the 
uncertainty about  renewable electricity costs, which are linked to  electricity market  price 
developments  and  which  form  a  major  part  of  the  production  costs  of  e-fuels.  This  is  a 
similar challenge for the uptake of OPS. The energy price at the grid (including taxes) must 
be  comparable  to  the  bunkering  price  of  the  conventional  fuel  for  the  OPS  to  be 
economically attractive for use on a vessel. The price gap is an element that stakeholders 
like the European Sea Ports Organisation (ESPO), are considering as reducing the demand 
for OPS71. 

69 See Stakeholder consultation report 
70 Stopford (2009) – Maritime Economics, Third Edition, published by Routledge, Oxon. 
71 https://www.espo.be/media/ESPO%20Green%20Deal%20position%20paper%20Green%20Deal-FINAL_4.pdf  

22 

 
 
                                                           
These prices are expected to fall as technology matures. In this respect, the EU Hydrogen 
Strategy  already  notes  that  costs  for  renewable  hydrogen  are  going  down  quickly.  For 
instance, the costs for electrolysers, which  are necessary for the production of renewable 
hydrogen,  have  already  been  reduced  by  60%  in  the  last  ten  years,  and  are  expected  to 
halve  in  2030  compared  to  today  with  economies  of  scale.  In  regions  where  renewable 
electricity is  cheap and  available, electrolysers  may be able to  compete with  fossil-based 
hydrogen already in 2030. On the other hand, in the medium to long term the competition 
for biomass feedstocks with other energy and transport sectors in the transition towards a 
climate  neutral  economy  is  expected  to  push  the  feedstock  prices  upwards.  This  is  fully 
taken into account in the analysis and further explained in Section 5.4.    

The fragmentation of the sector and the high level of customisation of vessels represent a 
barrier to reach critical mass for the deployment of new technologies, unless a significant 
number of operators takes action. The lack of sufficient production levels contribute to the 
higher cost of RLF compared to conventional fossil fuels, which remains a barrier to their 
uptake72. MBMs, such as ETS or ETD, may help bridging the gap, but the price difference 
is  likely  to  remain  too  high  until  the  production  of  sustainable  fuels  and  technologies 
achieves  sufficient  economies  of  scale.  A  price  of  emission  allowances  of  at  least 
€200/tCO2 would be necessary to make RLF economically interesting, which is unlikely in 
the short- or medium-term.  

2.2.4  High interdependency with supply and distribution (chicken-and-egg situation) 

The introduction of new fuels does not only require the development of appropriate vessel 
technologies (see 2.2.2) or the willingness of users to adopt a new source of energy; it also 
necessitates sufficient availability of fuels in terms of production (type and quantity of fuel 
produced),  supply  and  distribution  through  an  adequate  bunkering  infrastructure.  The 
global nature of the maritime business means that many vessels need to be able to operate 
and  refuel  across  the  world.  Therefore,  an  alternative  technology  to  fossil  fuels  would 
require  the  availability  of  sufficient  production  of  the  energy  carrier,  vessels  capable  of 
using it, and an infrastructure for its distribution in ports around the world.  

Although  the  situation  differs  depending  on  the  technology,  in  all  cases  there  is  a  strong 
need  for  coordination  between  supply  and  demand.  Investments  in  production  are  not 
made, and economies of scale are not reached, without enough demand; conversely, there 
is  not  enough  demand  without  a  reasonable  priced  supply  (‘chicken-and-egg’  situation). 
This is a clear case of interdependency of business decisions by market actors on the side 
of  demand  (ship  operators  and  ship  owners)  and  supply  (fuel  production,  supply  and 
infrastructure).  At  present,  the  EU  regulatory  framework  focusses  on  the  supply, 
infrastructure and distribution of fuels, but puts no obligations on their use.  

72 The Port of Rotterdam reports that 0.5% - 2% of fuels sold were biofuels or a biofuel mixture in 2019 
(approximatley100 kilotons of fuel supplied).  

23 

 
 
                                                           
AFID establishes rules on the deployment of alternative fuels infrastructure for transport, 
including  provisions  for  equipment  of  ports  on  the  Trans-European  Transport  Network 
(TEN-T)  for  the  supply  of  LNG  and  OPS73.  While  the  Directive  was  expected  to  create 
sufficient  conditions  for  the  use  of  alternative  fuels,  the  very  low  demand  for  alternative 
fuels  or  connections  to  the  electric  grid  while  at  berth  gave  grounds  to  ports  to  delay 
investments in the relevant infrastructure. AFID is due to be reviewed74.  

Indeed, data compiled by the European Alternative Fuels Observatory (EAFO)75 show that 
the  deployment  of  OPS  has  been  slower  than  initially  expected  –  in  December  2020,  41 
maritime  and  inland  waterway  EU  ports  had  at  least  one  berth  equipped  with  OPS. 
However, depending on the location within the port and the power provided at each OPS, 
only  specific  vessels  can  be  supplied  with  power  while  at  berth.  For  example,  an  OPS 
located at a container terminal can only supply container vessels but not passenger vessels.  
Concentrating  the  regulatory  approach  solely  on  the  provision  of  infrastructure  may 
therefore not be sufficient to break the “chicken-and-egg” situation.  

The development of the LNG-fuelled fleet and the LNG bunkering infrastructure is a case 
in  point.  LNG  requires  ships  with  special  tanks,  piping  and  engines.  It  is  most  cost-
effective to supply LNG to these ships with a bunker vessel, but this requires a significant 
investment  which  can  only  be  earned  back  when  there  is  sufficient  demand.  It  has  taken 
about half a decade before the increase in the number of LNG-fuelled ships resulted in the 
deployment  of  LNG  bunker  vessels  in  ports76.  Note  that,  even  though  the  use  of  LNG 
required an upfront investment (in particular in vessels’ technologies and the development 
of  the  bunkering  infrastructure),  LNG  was  cheaper  than  HFO  per  unit  of  energy, 
throughout  the  2010-2020  period  in  all  years  except  2016  (DNVGL  (2020),  Alternative 
Fuels  Insight77)  and  significantly  cheaper  than  marine  gas  oil  (MGO)78  for  the  entire 
period. 

Besides  the  provision  of  adequate  distribution  infrastructure,  there  is  an  additional 
interdependency  with  the  production  of  fuels.  Alternative  fuels  are  not  put  in  production 

73 The Directive lists LNG and OPS as the two mature alternative fuels for waterborne transport. It foresees the provision 
of sufficient LNG bunkering capacity in all TEN-T Core ports by the end of 2025. While a similar approach in principle 
applies  to  OPS,  the  provisions  may  not  apply  if  there  is  no  demand  and  the  costs  are  disproportionate  to  the  benefits, 
including environmental benefits. 
74https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/2111-Evaluation-of-the-Alternative-Fuels-
Infrastructure-Directive  
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12251-Revision-of-Alternative-Fuels-
Infrastructure-Directive  
75 https://www.eafo.eu/  
76 This means that during this period, there were no dedicated bunkering facilities for ships and LNG bunkering was done 
via trucks, which is a rather sub-optimal solution for the maritime sector given the fuel quantities required.  
77 https://www.dnvgl.com/services/alternative-fuels-insight-128171  
78  The  use  of  MGO  is  the  principal  compliance  option  for  meeting  the  0.10%  sulphur  requirements  in  SOx  Emissions 
Control Areas (applicable as of 2015 in Europe in the Channel, the North Sea and the Baltic Sea). Next to LNG, the other 
alternative would be the use of HFO with exhaust gas cleaning system (SOx scrubbers), which also require investment in 
the ship engine.  

24 

 
 
                                                           
unless there is a demand, or at least market prospects; but without guaranteed availability 
of fuels, operators do not invest in alternative fuel vessels and do not generate demand.  

The RED II supports the supply of RLF for the land (road and rail) transport sectors and 
indirectly  for  the  aviation  and  maritime  transport  sector,  via  the  use  of  multipliers.  The 
Directive  must  be  transposed  by  the  Member  States  into  national  legislation  by  30  June 
2021.  Its  impact  on the  use of RLF in  maritime  remains still uncertain  at this stage.  The 
revision of the REDII Directive is also part of the ‘Fit for 55’ package. This should provide 
further incentives for the supply of RLF to the maritime transport sector.    

2.2.5  Possibility of bunkering outside EU (risk of carbon leakage)  

Being  an  international  sector  by  nature,  maritime  transport  is  highly  prone  to  carbon 
leakage. If rules were to apply to fuels sold in Europe without obligations for their use, it 
would be possible for many vessels active in both deep sea and short sea trades to bunker 
fuel  outside  the  EU.  Due  to  their  large  tank  capacities,  most  ships  are  able  to  undertake 
long  voyages  on  a  single  bunkering.  Estimations  made  in  the  framework  of  the  support 
study  for  this  impact  assessment  (Ecorys  /  CE  Delft,  forthcoming)  indicate  that  bulk 
carriers  can  sail  more  than  30,000  nautical  miles  (nm)  on  average  on  full  tanks, 
containerships up to 50,000 nm and tankers between 10,000 nm and 30,000 nm on average. 
To  put  this  into  perspective,  a  transatlantic  journey  from  Europe  would  cover  around 
6,000-7,000 nm and a journey to South-East Asia around 10,000 nm.  

A  number  of  important  bunkering  hubs  are  located  in  the  EU,  in  particular  the  ports  of 
Rotterdam,  Antwerp  and  Algeciras,  which  rank  among  the  world’s  ten  largest  ports  for 
bunkering (in terms of volume)79. Overall, in 2017, European countries (including the UK) 
supplied  a  little  less  than  20%  of  the  international  maritime  bunker  fuels80.  The  study 
carried out in 2011 in support for the impact assessment of a proposal to address maritime 
transport GHG emissions81, notes that the possible introduction of taxes on fuel supplied is 
likely to be circumvented by bunkering outside the scheme (either in ports outside the EU, 
or by using offshore bunkering facilities). Addressing only the EU supply of RLF would, 
in principle, not be sufficient to provide the expected results in terms of higher penetration 
of these fuels in the maritime fuel mix.  

The possibility of bunkering outside the EU also calls for requirements that do not distort 
the level playing field between fuel distributors and producers within and outside the EU.  

79 https://maritimefairtrade.org/top-ten-bunkering-ports/  
80 Eurostat and IEA data 
81 https://ec.europa.eu/clima/sites/clima/files/transport/shipping/docs/ghg_maritime_report_en.pdf  

25 

 
 
                                                           
2.3  How will the problem evolve? 

It  is  unlikely  that  the  situation  will  evolve  towards  a  significantly  greater  penetration  of 
RLF  in  shipping  without  further  policy  intervention.  The  uptake  is  likely  to  remain 
anecdotal, driven by pioneers in the sector. The baseline scenario, showing developments 
under  current  trends  and  policies82,  projects  a  limited  uptake  of  biofuels  in  international 
maritime  by  2050  (0.1%  in  2030  and  1.3%  in  2050).  Electricity  use  at  berth  is  also 
projected to remain limited at around 0.1% of the total fuel mix by 2050. No other type of 
RLF  is  foreseen  to  enter  the  international  maritime  fuel  mix  by  2050  without  further 
intervention. As a result, tank to wake CO2 emissions are projected to increase by 14% by 
2030 and by over 30% by 2050 relative to 2015. By 2050 this would imply a stabilisation 
of  CO2  emissions  to  their  2008  levels,  which  is  however  not  in  line  with  the  climate 
neutrality  objectives.  Well  to  wake  GHG  emissions  would  grow  slightly  faster  at  15% 
during 2015-2030 and over 35% for 2015-2050.83 The increase in emissions is driven by 
the sustained growth projected for transport activity (20% during 2015-2030 and 50% for 
2015-2050), even when accounting for the impact of the COVID-19 pandemic, and despite 
the projected significant  improvements in energy efficiency. More details  on the  baseline 
scenario are provided in Annex 4. 

It  is  also  worth  noting  that  the  existing  provisions  of  EU  legislation  (in  particular  the 
Sulphur  Directive  or  the  AFID),  which  could  have  encouraged  the  uptake  of  alternative 
fuels,  in  particular  LNG  and  OPS,  have  not  produced  yet  any  significant  uptake  of  new 
sources of energy in maritime transport. However, by 2050 LNG is projected to represent 
around  19%  of  the  international  maritime  fuel  mix,  mainly  as  a  result  of  more  stringent 
requirements  on  air  pollution  control  (in  particular  SOx  and  NOx  emissions)84.  Even 
though  the  GHG  benefits  of  fossil  LNG  remain  modest  (in  particular  due  to  possible 
methane slip) and insufficient to meet EU GHG reduction targets; this fuel provides a good 
solution to air pollution issues, allowing reductions in SOx and NOx emissions and, as a 
result,  it  represented  an  attractive  compliance  option  to  the  Sulphur  Directive  and 
MARPOL Annex VI. In the longer term, LNG can pave the way to the use of bio-LNG or 
e-gas, which would also offer climate-related benefits. 

The  feedback  received  in  the  context  of  the  public  consultation  confirms  that,  without 
policy  intervention,  the  uptake  of  RLF  in  maritime  transport  is  unlikely  to  happen  to  a 
significant extent before 2040.  

Figure 3 Feedback from the public consultation on the likely uptake of RLF without specific policy intervention 

82 More details on the baseline scenario are provided in Annex 4.  
83 Well to wake emissions also take into account the CH4 and N2O from methane slippage.  
84 More details on the baseline scenario are provided in Annex 4. 

26 

 
 
                                                           
Q5. How likely is it that – without specific policy intervention - a significant uptake 
of low or zero-carbon fuels will take place in the following periods? 

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Before 2030

3,0% 

5,2% 

8,1% 

Between 2030 and 2040

5,2% 

11,9% 

28,9% 

25,2% 

49,6% 

5,2% 

40,7% 

8,1% 

8,9% 

After 2040

19,3% 

18,5% 

31,1% 

14,8% 

5,9% 

10,4% 

Very likely

Likely

Neither likely nor unlikely

Unlikely

Very unlikely

Not answered / no opinion

Breaking  this  deadlock  would  require  some  external  development,  such  as  a  significant 
technological  breakthrough  on  the  side  of  research  and  development  (including  lowering 
the  cost  and  upscaling  maturing  technology  solutions),  a  strong  push  from  public 
authorities  towards  the  use  of  certain  technologies,  or  the  imposition  of  performance 
requirements that would force operators to choose low carbon technologies and kick-start a 
process of transition. Whereas a breakthrough in research providing a superior technology 
that the market would spontaneously adopt cannot be excluded, there is no certainty of this 
happening in time to reduce maritime emissions by the desired amount by 2050. To reduce 
maritime emissions in a timely fashion, additional policy intervention is required, as also 
indicated by respondents to the public consultation85.  

As explained in Sections 1.5 and 2.1, maritime transport should reduce its CO2 emissions 
by at least 22% by 2030 and 88-89% by 2050 compared to 2008, to be in line with the EU 
climate  objectives.  Existing  literature  suggests  that  with  current  technologies,  at  best,  a 
vessel  can  improve  the  energy  efficiency  of  its  operations  by  roughly  further  20  to  30% 
compared to current levels86.  Moreover, individual energy savings are likely to be partially 
offset  by  an  increase  in  the  volume  of  maritime  activity.  As  a  result,  a  large  part  of  the 
emission savings would need to  also be achieved via use of RLF already within the next 
couple of decades. It is therefore clear that a specific approach dedicated to the uptake of 
RLF is essential for the sector to effectively contribute to the post-2030 climate targets. As 
explained in Section 1.5, RLF should provide 6-9% of the international maritime transport 
fuel  mix  in  2030  and  86-88%  by  2050.  The  scenario  assessing  a  combination  of  carbon 

85 More than 87% of the respondents in the OPC focusing on the demand-side. When asked about possible intervention, 
76% of the respondents consider it very relevant or relevant to set a clear regulatory pathway for decarbonising the 
current marine fuel mix  
86  Further  improvements  in  energy  efficiency  depend  on  the  different  types  and  combinations  of  energy  saving 
technologies available for the different ship types and their use in operation. For example, shipyards estimate on average 
further  EEDI  improvements  at  0-5%,  wind  assisted  propulsion  at  5-10%  (albeit  it  is  voyage  dependent  and  is  suitable 
primarily  for  bulk  carriers  and  tankers),  air  lubrication  at  ca 5%  (but  not  suitable  for larger  tankers  and bulk  carriers). 
Fouling  control  and  speed  reduction  can  bring  additional  savings,  as  well  as  waste  heat  recovery  which  has  however 
limited performance at reduced speeds and is only suitable for certain ships with sufficient electrical load to absorb the 
power generated. These are estimates for individual ships,  but considering a fleet level perspective  – these percentages 
need to be adjusted to account for the fact that not all ships are compatible with these interventions. Source: ABS et al 
(forthcoming),  “Decarbonisation  of  Shipping:  Technical  Study  on  the  future  of  the  Ship  Energy  Efficiency  Design 
Index”. 

27 

 
 
 
                                                           
pricing  and  medium  intensification  of  regulatory  measures  underpinning  the  impact 
assessment accompanying the 2030 Climate Target  Plan and the staff working document 
accompanying  the  Sustainable  and  Smart  Mobility  Strategy  projects  a  share  of  7.5%  for 
2030 and 86% by 2050. 

Achieving  2050  emission  reduction  targets  in  maritime  transport  is  highly  unlikely,  as 
shown  by  the  Baseline  scenario  projections,  if  the  production  of  sustainable  fuels,  the 
testing and certification for maritime use, the deployment of the necessary infrastructure in 
ports, and the renewal of the fleet do not start as soon as possible, particularly in the case 
of  technologies  that  require  dedicated  infrastructure,  retrofit  solutions  as  well  as  new 
vessels and engine design. RLF that can be blended with the fossil fuels currently in use 
(drop-in fuels) can be deployed much more rapidly, but even in their case production needs 
to be scaled up and production costs reduced.  

These considerations suggest that a scenario in which a new dominant technology replaces 
rapidly  the  current  one  is  not  very  likely87.  The  most  probable  scenario  is  that  various 
technologies,  possibly  used  in  different  segments  of  the  market,  will  coexist  for  a 
prolonged period of time. This tends to indicate that the process of decarbonisation of the 
energy  used  in  the  sector  must  start  promptly  and  develop  in  parallel  with  the 
improvements in energy efficiency.  

In  addition,  it  is  important  to  stress  that  increasing  the  penetration  of  alternative  fuels  in 
maritime  transport  is  a  long  and  complicated  process,  requiring  cooperation  and 
coordination  among  different  market  actors.  Availability  of  technology  (including  the 
technical  means  to  use  it),  sufficient  supply  of  fuels  (in  terms  of  production  and 
bunkering/charging infrastructure) as well as sufficient conditions to sustain the use of the 
technology  by  market  operators  is  critical.  Without  a  regulatory  framework  providing  a 
clearly identified pathway  for decarbonising  the  maritime fuel  mix and for the necessary 
technology  developments,  the  uptake  of  new  fuels  is  likely  to  remain  marginal  and  the 
costs for their introduction will solely  fall upon first  movers  (even though  these may not 
receive any competitive advantage as a result88).  

The  review  of  the  Renewable  Energy  Directive  is  expected  to  drive  scaling  up  the 
production of renewable and low carbon fuels in the EU. However, as explained in section 
2.2.4, and given the possibility of ships to bunker internationally and carry long journeys 
on  a  single  bunkering,  any  requirements  relying  solely  on  supply  may  be  easily 
circumvented in the context of maritime and would not ensure their uptake in the sector. 

87 The maritime sector has already gone in the past through two transitions: from wind to steam, and from steam to oil. 
Even if in those cases the ‘next’ technologies were clearly identified, both transitions took around 50 years to complete.  
88 This is also due to the fact that the use of alternative fuels is likely to be seen as an additional cost item as opposed to 
the introduction of fuel saving / efficiency technologies, where first movers would in principle be able to lower their fuel-
related  voyage  costs.  This  would,  in  turn,  allow  them  to  either  increase  profit  margins  or  be  able  to  offer  more 
competitive prices as a clear first mover advantage.  

28 

 
 
                                                           
On the other hand, the current initiative complements the review of the Renewable Energy 
Directive  by  securing  the  demand  for  these  fuels  in  the  maritime  sector  and  thus 
reinforcing the delivery of renewable energy in the transport sector. In this regard, it should 
be  highlighted  that  this  initiative  intends  to  fully  match  the  definitions  and  sustainability 
criteria  of  the  Renewable  Energy  Directive.  In  fact,  in  the  absence  of  RLF  supply  in  the 
EU, maritime would rely exclusively on imports or bunkering such fuels in third countries. 
Further  insights  in  related  policy  instruments  governing  the  supply  and  infrastructure  of 
RLF are provided in Section 5.3.1. 

The revision of the Energy Taxation Directive revisits the tax exemptions for conventional 
fossil fuels used in shipping. This will however not be able to address problem drivers 1, 2, 
4 and 5 of the present initiative. Finally, as explained above, for the EU ETS to make RLF 
economically interesting for the maritime sector, a price of CO2 emission allowances of at 
least €200 would be necessary. By comparison, the impact assessment89 accompanying the 
2030  Climate  Target  Plan  projected  carbon  prices  for  the  ETS  sector  (including  the 
maritime sector) in the range of 32 to 65 €/tCO2, to cut the economy-wide GHG emissions 
by at least 55% by 2030. The EU ETS is therefore unlikely, by itself, to drive RLF uptake 
in the medium-term. More details are provided in Section 5.3.3. 

3.  WHY SHOULD THE EU ACT? 

3.1  Legal basis 

The  legal  basis  giving  the  EU  the  right  to  act  is  Article  100(2)  of  the  Treaty  on  the 
Functioning of the European Union. In accordance with Article 4(2) of the Treaty, shared 
competence between the EU and the Member applies in the area of transport. 

3.2  Subsidiarity: Necessity of EU action 

Maritime transport is  an international sector by  nature.  In Europe, approximately 75% of 
the voyages reported under the MRV are within the EEA (and could therefore be a proxy 
for intra-EU traffic) and only around 9% of the traffic is estimated to be domestic voyages 
(between ports within the same Member State). The cross-border dimension of the sector is 
therefore essential and calls for coordinated action at European level.  

Without  action  at  EU  level,  the  risk  is  the  establishment  of  a  patchwork  of  regional  or 
national  requirements  across  Members  States,  which  would  trigger  the  development  of 
technical  solutions  that  may  not  necessarily  be  compatible  with  each  other.  Several 
Member  States  are  already  developing  national  maritime  strategies  that  include  specific 
approaches  to  ship  emissions  and  in  particular  the  uptake  of  alternative  fuels90.  As  the 

89 SWD(2020) 176 final. 
90 This includes national plans being developed by the Netherlands, Sweden and Italy (in the form of their ‘Guidelines for 
Energy and Environmental Planning Documents of the Port System Authorities (DEASP)’. Non-EU Member States like 

29 

 
 
                                                           
 
problem  drivers  identified  in  Section  2.2  do  not  fundamentally  differ  from  one  Member 
State  to  another,  and  given  the  cross-border  dimension  of  sector’s  activities,  these  issues 
can  be  best  addressed  at  EU  level.  EU  action  can  also  inspire  and  pave  the  way  for  the 
development  of  future  measures  to  accelerate  the  uptake  of  alternative  fuels  at  global 
level91.  

Previous EU action on GHG issues has already stimulated a corresponding response from 
the  IMO,  notably  by  the  adoption  of  the  EU  Regulation  on  Monitoring,  Reporting  and 
Verification of GHG emissions from ships that led shortly afterwards to  IMO adopting a 
similar  mandatory  global  GHG  Data  Collection  System.  A  coordinated  approach  by  EU 
Member  States  to  developments  in  GHG  emission  reduction  at  IMO  has  more  recently 
ensured that mandatory operational energy efficiency measures are included within IMO’s 
short  term  actions  to  reduce  GHG.  Projecting  a  common  viewpoint  from  a  considerable 
group of IMO member states within the IMO fora means that the EU can have a significant 
impact on the direction and outcome of IMO discussions. 

3.3  Subsidiarity: Added value of EU action 

The  implementation  of  this  initiative  at  European  level  is  necessary  to  achieve  the 
economies of scale in the uptake of RLF in maritime transport as well as avoiding carbon 
leakage,  and  ensuring  level  playing  field  between  operators  calling  in  EU  ports  and 
between the EU ports themselves. To give an example, obligations established at national 
level  on  the  use  of  RLF  could  divert  traffic  to  competing  ports  of  other  MSs  and  distort 
competition. Accordingly, harmonisation at EU level is necessary to ensure a level playing 
field for all actors of the maritime cluster (in particular, operators, ports and fuel suppliers).  

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1  General objectives 

This initiative aims at increasing the uptake of RLF in EU maritime transport with a view 
to  reducing  emissions  from  the  sector,  both  in  navigation  and  at  berth  and  thereby 
contribute to  achieving  EU and international  climate objectives. Ensuring a more diverse 
fuel mix and higher penetration of RLF is critical to ensure the sector’s contribution to the 
European  ambition  of  climate-neutrality  by  2050.  At  the  same  time,  a  differentiated 
approach to the use of RLF in navigation and in ports is important to account for different 
implications on air pollution (more relevant for ships in ports) and different availability of 
technologies (more options for ships in ports). 

the  UK  and  Norway  have  also  established  their  own  plans.  It  is  important  to  mention  them  in  this  respect  as  their 
objectives may affect short-sea shipping traffic to and from the EU.  
91 Currently listed in the Initial IMO Strategy on reduction of GHG emissions from ships among candidate mid-term 
measures, i.e. measures to be agreed by the IMO between 2023 and 2030. 

30 

 
 
                                                                                                                                                                                
The initiative aims at setting a harmonised regulatory framework in the EU with a view to 
increase  the  share  of  RLF  in  the  fuel  mix  of  international  maritime  transport,  including: 
liquid  biofuels,  e-liquids,  decarbonised  gas  (including  bio-LNG  and  e-gas),  decarbonised 
hydrogen,  decarbonised  hydrogen-derived  fuels  (including  methanol,  and  ammonia)  and 
electricity. The present intervention is focused on demand-side aspects (the use of fuels, in 
this  case  RLF)  and  will  complement  the  existing  EU  regulatory  framework  related  to 
supply and infrastructure. It will also provide synergies with pollution reduction initiatives.  

4.2  Specific objectives 

This  initiative  is  designed  to  effectively  address  the  existing  barriers  that  hamper  the 
further deployment of RLF.  

The  specific  objectives  (SOs)  and  their  correspondence  with  the  problem  drivers  are 
presented in Figure 4:  

Figure 4 Correspondence between the specific objectives and the problem drivers 

The initiative will contribute to the achievement  of the general objective by pursuing the 
following SOs: 

  Enhance  predictability  through  the  setting  of  a  clear  regulatory  environment 
concerning  the  use  of  RLF  in  maritime  transport.  The  establishment  of  clear  and 
mandatory  targets  for  decarbonising  the  marine  fuel  mix  to  be  used  on-board  will 
provide  certainty  on  future  obligations,  facilitate  planning  of  investments,  and 
counteract  a  ‘wait-and-see’  attitude  of  operators.  Setting  a  clear  pathway  for 
decarbonising  the  marine  fuel  mix,  with  progressively  more  stringent  requirements, 
will also help understanding which technologies are more ‘future proof’ than others. 
  Stimulate technology development. Establishing minimum levels of demand for RLF 
in  the  maritime  sector  is  expected  to  stimulate  the  process  of  their  selection  and 
deployment,  as  well  as  of  gradual  technological  improvement  of  yet  immature 
solutions.  It  is  expected  to  speed-up  the  deployment  of  more  performant  propulsion 
systems  (energy  converters)  that  can  be  used  with  specific  fuels  (e.g.  fuel  cells  to  be 
used  with  hydrogen  and  hydrogen-based  fuels).  It  would  also  ensure  that  the 
development  and  deployment  costs  are  spread  more  evenly  across  the  sector  and  not 
only on first movers, who may not gain any competitive advantage in return. It is also 

31 

 
 
 
important that the chosen intervention, while encouraging a more rapid deployment of 
the  more  mature  options  (e.g.  drop-in  fuels)  in  the  medium-term,  does  not  prevent 
additional progress on the most environmentally sound, but yet immature, technologies 
that are needed in the longer term.  

  Stimulate  production  on  a  larger  scale  of  RLF  with  sufficient  high  technology 
readiness  level  (TRLs)  and  reduce  the  price  gap  with  current  fuels  and 
technologies.  By  triggering  demand  of  RLF  by  maritime  operators,  this  initiative 
would  create  the  conditions  for  higher  volumes  of  production  and  attainment  of 
economies of scale. This could contribute towards reducing the existing price gap with 
respect to conventional fuels. 

  Create demand from ship operators to bunker RLF or connect to the electric grid 
while at berth. At the moment, the EU legislative framework is solely focussed on fuel 
supply  and  provision  of  infrastructure.  However,  in  the  absence  of  sufficient  and 
predictable  levels  of  demand,  investments  in  production  and  infrastructure  remain 
unprofitable and extremely limited in practice (as explained in Section 2.2.4). In order 
to address this interdependency issue, this initiative should complement measures taken 
on the supply and distribution side with a corresponding demand-side intervention (i.e. 
the use of fuels). 

  Avoid  carbon  leakage.  This  initiative  should  help  avoiding  the  carbon  leakage  that 
would derive from bunkering fuels outside the EU. This would be achieved by setting 
specific  performance  requirements  on  the  fuel  used  by  ships,  regardless  of  where  the 
fuel  is  acquired.  The  intervention  should  also  be  designed  with  a  view  to  avoid  any 
possible  distortion  of  competition  and  regulatory  advantage  derived  from  ships 
belonging to different jurisdictions. 

These  objectives  are  consistent  with  the  objectives  of  other  Commission  initiatives 
currently  being  pursued  as  part  of  the  overall  basket  of  measures  to  address  GHG 
emissions from maritime transport, in line with the renewed EU climate ambition.  

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

5.1  What is the baseline from which options are assessed? 

The baseline scenario reflects  developments  under current  trends  and adopted policies as 
described in Section 2, and without further EU-level intervention. It builds on the baseline 
scenario underpinning the impact assessment accompanying the 2030 Climate Target Plan 
and  the  staff  working  document  accompanying  the  Sustainable  and  Smart  Mobility 
Strategy92,  but  it  additionally  considers  the  impacts  of  the  COVID-19  pandemic  and  the 
National  Energy  and  Climate  Plans.  In  this  scenario,  the  penetration  of  RLF  would 
continue  to  remain  extremely  limited  (1.4%  of  the  fuel  mix  by  2050,  of  which  1.3% 

92 SWD(2020) 331 final. 

32 

 
 
                                                           
biofuels and 0.1% electricity use at berth).  No other type of RLF is foreseen to enter the 
international  maritime  fuel  mix  by  2050  without  further  intervention.  A  series  of 
independent, and potentially diverging, company-based approaches would characterise the 
development  and  deployment  of  alternative  fuel  solutions.  While  ship  operators  are 
currently  making  different  assumptions  on  the  type  of  energy  to  be  used  in  their  market 
segment in the future, the uptake of RLF in the baseline scenario is expected to principally 
concentrate  on  the  most  mature  and  currently  available  option  for  maritime  transport, 
which is biofuels. In this scenario, LNG uptake will continue growing, as the result of the 
application of more stringent requirements on air pollution control in the maritime sector 
(in particular SOx and NOx emissions). LNG is projected to represent 19% of the fuel mix 
by 2050 without further EU-level intervention.  

This  is  explained  by  the  maturity  of  the  technology,  the  gradual  availability  of 
infrastructure  and  considerations  on  fuel  supply  (bearing  also  in  mind  the  limited 
competition for feedstock for LNG compared to other potential fuel options). The lack of 
sector-wide  coordination  and  harmonised  approach  at  EU  level  regarding  the  type  and 
emission  footprint  of  fuels,  the  limited  geographical  scope  of  application  as  well  as  the 
timeframe  for  their  deployment  is  likely  to  lead  to  sub-optimal  results  and  overall 
insufficient penetration on RLF to meet the EU climate objectives set out in the EGD and 
the 2030 CTP.  

Tank to wake CO2 emissions from international shipping are projected to increase by 14% 
by  2030  and  by  over  30%  by  2050  relative  to  2015.  By  2050  this  would  imply  a 
stabilisation of CO2 emissions to their 2008 levels, which is however not in line with the 
climate neutrality objectives. Well to wake GHG emissions would grow slightly faster at 
15% during 2015-2030 and over 35% for 2015-2050.93 The increase in emissions is driven 
by  the  sustained  growth  projected  for  transport  activity,  even  when  accounting  for  the 
impact of the COVID-19 pandemic, and despite the projected significant improvements in 
energy efficiency. More details on the baseline scenario are provided in Annex 4. 

The  baseline  scenario  does  not  include  the  other  ‘Fit  for  55’  initiatives.  This  ensures  a 
consistent  approach  with  the  impact  assessments  accompanying  the  other  ‘Fit  for  55’ 
initiatives. However, a qualitative assessment of their possible impact on how the problem 
will evolve is provided in Section 2.3.  

In  addition,  as  explained  in  Section  1.5,  the  trajectory  of  the  RLF  uptake  from  2025  to 
2050 in the policy options is based on the common economic assessment underpinning the 
2030  Climate  Target  Plan  and  the  Sustainable  and  Smart  Mobility  Strategy,  while 
considering  a  combination  of  carbon  pricing  and  medium  intensification  of  regulatory 
measures in all sectors of the economy. This ensures a consistent approach for delivering 
the EU climate ambition by 2030 and 2050, while at the same time identifying the impacts 

93 Well to wake emissions also take into account the CH4 and N2O from methane slippage.  

33 

 
 
                                                           
of  the  design  of  the  policy  option  that  would  best  allow  to  reach  this  contribution.  A 
qualitative assessment of the implications of lower/higher trajectory for the renewable and 
low carbon fuels is however provided in Section 5.4.   

5.2  Description of the policy options 

5.2.1  Possible policy measures and preliminary screening of options 

As  a  first  step,  a  comprehensive  list  of  possible  policy  measures  was  established  after 
extensive  consultations  with  stakeholders,  expert  meetings,  independent  research  and  the 
Commission’s  own  analysis.  This  initial  list  is  presented  in  Annex  6.  This  list  was 
subsequently screened based on the likely effectiveness, efficiency and proportionality of 
the proposed measures in relation  to  the  given objectives, as well  as their legal,  political 
and technical feasibility.  

As a result of this analysis, several measures were not retained in the main policy options, 
although, in some cases, their important  role as complementary measures,  supporting the 
climate  objective  for  the  maritime  transport  sector,  is  fully  recognised.  The  non-retained 
options are discussed in greater detail in Section 5.3. 

5.2.2 

Identification of the general policy approach and the choice of main policy options 

The  screening  of  the  initial  list  of  possible  policy  measures  was  accompanied  by  a 
reflection  on  what  type  of  approaches  would  be  needed  to  address  each  of  the  SOs 
identified  in  Section  4.  The  list  of  suitable  approaches  related  to  each  of  the  SOs  is 
presented in Figure 5:  

Figure 5 General policy approaches to address the problem drivers  

Following  this  analysis,  it  appears  that  all  policy  approaches  potentially  capable  of 
fulfilling the given objectives would need to share two principal characteristics:  

  They  should  provide  certainty  on  the  future  short  to  long-term  policy  targets  for  the 
carbon  intensity  of  the  energy  used  by  ships.  Such  targets  should  preferably  be 
mandatory and enforceable, thus providing legal certainty. 

34 

 
 
 
 
  They  should  address  the  demand  side  component,  by  incentivising  or  prescribing 
minimum  performance  requirements  of  the  marine  energy  mix.  This  is  necessary  for 
complementing  existing  supply-side  measures  and  solving  the  interdependency  issue, 
as well as for avoiding carbon leakage.  

Policy approaches could, however, differ on the way that the required level of performance 
is achieved. This could either be done by prescribing the use of certain technologies/fuels 
or by setting certain goals that operators could meet with technologies/fuels of their choice. 
As  a  result,  this  aspect  was  considered  to  be  the  main  factor  differentiating  the  suitable 
policy options (POs) to be analysed for this initiative.  

In the next step, the retained policy measures were classified according to their approach 
and  characteristics  in  relation  to  three  areas  of  policy  intervention:  i)  improve  the 
penetration rate of RLF, ii) stimulate the introduction of zero-emissions energy solutions, 
and iii) certification, reporting and enforcement.  

The correspondence between the SOs and the areas of policy intervention are illustrated in 
Figure 6: 

Figure 6 Correspondence between the specific objectives and the identified areas of policy interventions 

As  explained  in  Section  5.2.1,  the  full  list  of  identified  policy  measures  is  presented  in 
Table  69  in  Annex  6.  It  clearly  indicates  if  these  measures  have  been  retained  or  are 
considered as flanking measures or complementary measures. Only retained measures have 
been included in policy options and were subject to a thorough analysis.  

The  correspondence  between  the  specific  policy  objectives,  the  retained  policy  measures 
grouped in accordance with the three areas of policy intervention and links to the different 
POs is shown in Table 1. 

Table 1 Overview of specific policy objectives, measures and links to policy options 

Retained policy measure 

Driver / 
Specific 
objective 

Policy options 

PO1  PO2  PO3 

35 

 
 
 
Field of policy intervention 1: Improve the penetration rate of RLF 

1 

2 

Establish minimum share (in volume terms) of selected RLF for 
ships in navigation calling EU ports (blending mandate) 

Set maximum targets on the GHG intensity (meaning the GHG 
emissions per unit of energy) of the energy used by vessels (the 
fuel / energy emissions per MJ). 

3  Mandate the use of OPS (or equally performant alternatives e.g. 

batteries, zero-pollution energy sources like hydrogen) for the 
most polluting ships in ports 

SO1, SO2, 
SO3, SO4, 
SO5 
SO1, SO2, 
SO3, SO4, 
SO5 

SO1, SO2, 
SO3, SO4  

 

- 

- 

- 

 

 

 

 

 

4 

Provide guidance to facilitate uptake of technology, including 
on the deployment of the necessary supply infrastucture 

SO2, SO3, 
SO4 

 

 

 

Field of policy intervention 2: Stimulate the introduction of zero-emissions energy solutions 

5  Adopt additional incentives to stimulate the introduction of 

zero-emission energy solutions, avoid fuel technology lock-in 
and reward over-achievers  

6 

Increase awareness raising, exchange of experience, 
encouragement and promotion of industry-led programmes in 
support of the uptake of alternative fuels 

SO2, SO3, 
SO4 

SO2, SO3, 
SO4 

Field of policy intervention 3: Certification, reporting and enforcement 
Establish an EU-wide methodology to certify the well-to-wake 
7 
performance of fuels, reflecting all relevant GHG emissions and 
define the related documents to certify compliance 

SO1, SO2, 
SO5 

8 

9 

Establish requirements for certification and acceptance of 
bunkering supplied in third countries 

Establish a set of rules to follow for monitoring, reporting and 
verification of consumption of alternative fuels in the context of 
the EU MRV 

10  Establish Port State Control procedures for the use of RLF 
(including upskilling and training of PSC officers) 

SO5 

SO1, SO5 

SO1, SO5 

- 

- 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

The three policy options can be summarised as follows: 

 

 

In PO1, demand obligations would be identified by the regulator and defined in terms 
of share of RLF in the total maritime fuel mix to be used from 2025 onwards; 
In  PO2,  maritime  operators  would  be  required  to  achieve  a  certain  goal  in  terms  of 
carbon intensity of the energy used from 2025 onwards, but would retain freedom on 
the choice of fuels (and technologies); 

  PO3,  represents  a  mixed  approach  whereby  obligations  would  remain  ‘goal-based’ 
from  2025  onwards,  but  a  system  of  incentives  would  be  put  in  place  to  favour 
adoption of certain technologies identified by the regulator. 

These differences would apply only to ships in navigation, while the three options  would 
share the same approach for ships at berth. The reasoning for selecting a single approach 
for the ships at berth is based on a number of considerations. 

36 

 
 
 
First  of  all,  there  is  a  strong  case  for  advocating,  in  ports,  the  use  of  fuels  that  have 
minimal  emissions  of  both  GHG  and  local  pollutants  (zero  emission  fuels).  Use  of  zero 
emission  fuels  generates  considerably  higher  health  benefits  for  ships  at  berth  than  for 
ships at sea. 

This  ‘double  dividend’  on  climate  and  health  justifies  not  only  a  preference  for  zero 
emission fuels, but also a higher level of ambition in terms of emission abatement for ships 
at  berth.  Indeed,  other  things  equal,  the  same  reduction  in  the  use  of  fossil  fuels  will 
produce  greater benefits  when occurring in  ports  than  in  navigation.  For this reason, and 
considering that the cost of abating emission is not higher in ports, it makes sense to set a 
target of zero emissions for ships at berth. 

In  addition,  there  is  a  strong  convergence  on  the  promotion  and  use  of  OPS  for  ships  at 
berth. OPS is a technology that allows for zero emissions of both GHG and air pollutants. 
It  is  a  tried  and  tested  solution,  in  application  for  more  than  two  decades,  mandated  in 
certain parts of the world (e.g. the state of California) and increasingly deployed in other 
(e.g.  China).  In  the  EU,  the  Sulphur  Directive  encourages  the  use  of  OPS  and  the  AFID 
requires deployment of OPS when demand conditions justify it.           

In view of these considerations, the proposed intervention at  berth focussed primarily on 
the  use  of  OPS,  but  it  does  not  exclude  other  zero  GHG  and  air  pollutants  technologies, 
like batteries or hydrogen, which can be available in the medium to long term. As a result, 
maritime  operators  keep  the  possibility  to  use  alternative  zero-emission  solution  and  the 
policy  approach  remains  technology  neutral.  With  regard  to  possible  variations  of  the 
option in terms of timing or scope, it should be noted that: 

a)  Timing:  the  use  of  OPS  is  highly  dependent  on  the  deployment  of  the  required 
infrastructure  (currently  still  immature),  the  proposed  intervention  at  berth  would 
start from 2030 onwards and first focus on the most polluting ships in ports.  

b)  Scope:  The  most  polluting  ship  categories  have  been  identified  on  the  basis  of 
MRV  data  from  2018,  and  consists  of  containerships,  passenger  ships  and  ro-pax 
ships. These three ship categories represent roughly 40% of the emissions at berth, 
have among the highest levels of emissions per ship in port and belong to the first 
movers  in  the  use  of  OPS.  It  also  ensures  alignment  with  the  decisions  regarding 
vessels in navigation. 

In conclusion, with respect to use of fuels at berth, the proposed approach of requiring use 
of  OPS,  or  equivalent  solution,  by  the  main  emitters,  did  not  apper  to  have  a  credible 
alternative  which  would  retain  the  same  level  of  ambition  while  remaining  technically 
possible. Each of the policy options is presented in more details below.  

Policy Option 1 : Prescriptive approach on the choice of technologies 

Improve the penetration rate of RLF 

In PO1, improvement of the penetration rate is expected to be delivered by requiring shares 

37 

 
 
of specific RLF to be used in navigation (x% of the fuel used by ships during the journeys 
in scope). The type of fuels and the corresponding shares would be established ex-ante in 
line  with  technology  maturity  and  GHG  saving  potential.  The  minimum  share  would 
increase over time. The types of fuels included in this option would be regularly extended 
once more advanced options become mature.  

The indicative trajectory is provided in the table below. As explained in Section 1.5, this 
trajectory  has  been derived in  a way  that  enables kick starting the scale-up of renewable 
and  low  carbon  fuels  in  the  maritime  sector  from  2025  onwards  and  their  large  scale 
deployment  by  2050,  while  ensuring  the  consistency  with  the  required  overall  GHG 
emissions  reductions  by  2030  and  2050,  preserving  the  competitiveness  of  the  sector, 
promoting  innovation,  and  ensuring  feedstock  availability  for  renewable  and  low  carbon 
fuels  in  all  energy  and  transport  sectors  in  the  transition  towards  a  climate  neutral 
economy. 

Shares in the fuel mix (%) 

2025 

2030 

2035 

2040 

2045 

2050 

Total RLF shares 

Biofuels and bio-LNG 
Renewable fuels of non-biological origin 
Electricity 

2.9% 
2.9% 
0.0% 
0.0% 

7.4% 
7.2% 
0.2% 
0.1% 

15.6% 
12.5% 
2.8% 
0.2% 

30.0% 
22.8% 
6.8% 
0.4% 

68.8% 
46.4% 
21.7% 
0.7% 

85.9% 
53.3% 
31.5% 
1.1% 

The category renewable fuels of non-biological origin, in the meaning of Article 2(63) of 
the  Renewable  Energy  Directive,  covers  here  e-liquids,  e-gas,  hydrogen  and  other 
hydrogen-derived fuels like ammonia and methanol. 

At berth, the use of OPS will be mandated from 2030 onwards for the most polluting ships 
in  ports,  which  have  been  identified  on  the  basis  of  MRV  data  from  2018,  i.e. 
containerships, passenger ships and ro-pax ships,94 unless they can prove the use of equally 
performant alternative (e.g. batteries). The shares of electricity use at berth due to the OPS 
requirements  comes  in  addition  to  the  trajectory  illustrated  above  and  is  a  result  of  the 
assessment presented in Section 6.1.1. A phased-in implementation could gradually extend 
the requirements to the entire fleet (subject to a review clause and an impact assessment in 
the future).  

The  Commission,  assisted  by  EMSA,  will  continue  to  support  Member  States  in 
exchanging  best  practices  in  line  with  international  developments  and  the  latest 
technological / scientific knowledge, and to facilitate the uptake of technology, including  
the  deployment  of  the  necessary  supply  infrastucture.  These  could  take  place  in  the 
framework  of  the  expert  groups  from  the  Commission  such  as  the  European  Sustainable 
Shipping  Forum  (ESSF)  or  the  European  Ports  Forum  (EPF).  In  the  past,  EMSA  has 
already  delivered  LNG  bunkering  guidance95  and  is  currently  working  on  developping 
OPS  guidelines  to  facilitate  the  deployment  of  on-shore  power  connection  in  European 

94  These  three  ship  categories  represent  roughly  40%  of  the  emissions  at  berth,  have  among  the  highest  levels  of 
emissions per ship in port and belong to the first movers in the use of OPS. 
95 EMSA (2018) Guidance on LNG Bunkering to Port Authorities and Administrations 

38 

 
 
                                                           
Ports.  The  main  purpose  here  is  to  facilitate  planning  and  /  or  the  development  of  local 
rules for the safe use / handling of fuels. 

Stimulate the introduction of zero-emissions energy solutions 

As  specific  technological  choices  are  prescribed  under  this  option  and  considering 
technological progress over time, there is a risk that the choice made in year x may not be 
an optimal solution in year z. For this reason, the list of selected fuels would be updated on 
a regular basis and reflect the technology developments. The Commission will continue to 
foster  awareness  raising,  exchange  of  experience,  innovation,  encouragement  and 
promotion of industry-led programmes in support of the uptake of RLF. 

Certification, reporting and enforcement 

In  order  to  document  compliance  with  the  regulatory  obligations,  an  EU-wide 
methodology  to  establish  the  GHG  emissions  performance  /  sustainability  of  fuels  for 
maritime transport would be based on the RED II Directive and EU MRV Regulation, both 
of  which  would  be  cross-referenced  in  this  initiative.  As  regards  the  latter,  it  is  also 
proposed  to    include  the  non-CO2  emissions  and  alternative  sources  of  power96. 
Requirements  for  the  certification  of  fuel  suppliers  (including  in  third  countries)  and 
documentation  to  report  performance  would  be  necessary  and  as  above  it  would  be  also 
based on RED II requirements97. In this PO, the performance of fuel is established ex-ante 
and  demonstrating  sufficient  blending  levels  would  be  necessary  to  prove  compliance. 
Compliance  needs  to  be  documented  on  annual  basis  for  the  total  energy  generated  on-
board.  Additional  rules  should  be  established  for  this  purpose,  including  for  monitoring, 
reporting  and  verification  of  consumption  of  alternative  fuels  in  the  context  of  the  EU 
MRV and to harmonise Port State Control (PSC) procedures.  

Policy Option 2 : Goal-based approach on technologies 

Improve the penetration rate of RLF 

In PO2, improvement of the penetration rate of RLF is expected to be delivered by a goal-
based  approach  requiring  fuels  used  in  navigation  and  at  berth  to  meet  maximum  GHG 
intensity  targets.  A  maximum  limit  on  the  GHG  content  of  energy  used  by  ships  in 
navigation (e.g. CO2eq/MJ) is identified to deliver comparable GHG emissions reductions 
on  the  well  to  wake  basis  as  in  PO1.  This  target  will  be  made  more  stringent  over  time, 

96 Theoretically, a new governance could be designed for the purpose of this initiative only, with reporting requirements 
different  or  separate  from  the  existing  EU  MRV  Regulation.  This  option  has  been  discarded  at  an  early  stage  of  the 
analysis as disproportionate and unnecessary, also in view of the  fact that one of the  main objectives of the EU MRV 
Regulation  is  to  provide  a  framework  for  the  implementation  of  EU  climate  policies.  Similarly  for  REDII,  where  any 
divergence from the definition and certification of RLF may create inconsistencies between EU regulatory provisions – at 
the moment or in the future. This applies to all PO. 
97  The  European  Commission  recognises  a  number  of  voluntary  schemes  that  demonstrate  compliance  with  the 
sustainability  criteria  for  biofuels  (at  the  moment).  Schemes  may  adopt  their  verification  procedures  but  must  notify 
changes  that  might  be  relevant  to  the  Commission,  such  as  changes  in  auditing  procedures.  Examples  of  approved 
https://ec.europa.eu/energy/topics/renewable-
under  RED 
certification 
energy/biofuels/voluntary-schemes_en#approved-voluntary-schemes 

schemes 

found 

can 

at: 

be 

II 

39 

 
 
 
                                                           
which would require operators to shift to increase the overall share of RLF in their fuel mix 
(including thorugh the inclusion of more innovative solutions such as hydroen-based fuels 
of electricity). The reduction in the well to wake GHG intensity relative to the base period 
(2015)98 is provided in the table below. 

 Well to wake GHG intensity 
reduction (in %) 

2025 

2030 

2035 

2040 

2045 

2050 

Resulting from the use of RLF 
-2% 
-26% 
Concerning emissions at berth, the approach is the same as for PO1.  

-14% 

-7% 

-59% 

-74% 

Stimulate the introduction of zero-emissions energy solutions 

As no technology  choice is made in this PO, the risk of technology lock-in is reduced as 
the  market  operators  are  likely  to  maximise  the  use  of  existing  and  developing 
infrastructure and on-board equipment to meet the targets. They also may decide to comply 
with  more performant  and advanced technology (i.e. battery, fuel  cell), in terms  of GHG 
reductions, than fuel blends. The target could also be set in a way that reflects the uptake of 
energy  sources  such  as  wind  propulsion.  Also,  since  all  fuels  consumed  onboard  are 
accounted to meet the same target, ship operators may decide to comply by averaging very 
performant  technology  for  ancillary  power  (e.g.  renewable  hydrogen)  with  more 
conventional fuels used for propulsion. The Commission will continue to foster awareness 
raising, exchange of experience, innovation, encouragement and promotion of industry-led 
programmes in support of the uptake of alternative fuel, similarly to what is described for 
PO1. 

Certification, reporting and enforcement 

In  order  to  document  compliance  with  the  regulatory  obligations,  an  EU-wide 
methodology to establish the performance / sustainability of fuels for maritime transport be 
based on the RED II Directive and EU MRV Regulation, both of which would be cross-
referenced in this initiative. As regards the latter, it is also proposed to   include the non-
CO2 emissions and alternative sources of power. Requirements for the certification of fuel 
suppliers  (incl.  in  third  countries)  and  documentation  to  report  performance  would  be 
necessary  and  as  above  it  would  be  also  based  on  RED  II  requirements.  In  PO2,  the 
performance  of  the  fuel  is  not  established  on-board  but  needs  to  be  document  on  annual 
basis for the total energy generated on-board. Similarly to PO1, additional rules should be 
established  for  this  purpose,  including  for  monitoring,  reporting  and  verification  of 
consumption  of  alternative  fuels  in  the  context  of  the  EU  MRV  and  to  harmonise  PSC 
procedures.  

Policy Option 3 : Goal-based approach on technology and reward mechanisms for 
overachievers 

98  For  2015  the  average  GHG  intensity  of  marine  fuels  on  well  to  wake  basis  is  estimated  at  87  gCO2eq/MJ.  The 
emissions factors used are provided in Annex 4. 

40 

 
 
 
                                                           
Improve the penetration rate of RLF 

In PO3, improvement of the penetration rate of RLF is expected to be delivered by a goal-
based  approach  requiring  fuels  used  in  navigation  and  at  berth  to  meet  maximum  GHG 
intensity  targets.  A  maximum  limit  on  the  GHG  content  of  energy  used  by  ships  (e.g. 
CO2eq/MJ)  is  identified  in  the  same  manner  as  for  PO2  to  deliver  GHG  emissions 
reductions that are comparable on a well-to-wake basis across all three policy options.  

The  reduction  in  the  well  to  wake  GHG  intensity  relative  to  the  base  period  (2015)99  is 
provided  in  the  table  below.  This  table  does  not  account  for  the  “multipliers  for  zero-
emission options”, explained below, in order to show the true reduction in the well to wake 
GHG intensity of fuels.  

 Well to wake GHG intensity 
reduction (in %) 
Resulting from the use of RLF 
-60% 
Concerning emissions at berth, the approach is the same as for PO1 and PO2.  

-26% 

-14% 

2040 

2030 

2035 

2025 

2045 

-2% 

-7% 

2050 

-75% 

Stimulate the introduction of zero-emissions energy solutions 

The  requirements  in  this  option  are  similar  to  PO2  as  they  are  based  on  a  goal-based 
approach.  However,  this  PO  also  integrates  specific  additional  measures  to  foster  over-
achievement  and  encourage 
the  development  of  more  advanced,  zero-emissions 
technologies.  Two  aspects  will  be  assessed  as  part  of  the  mechanism  to  foster  over-
achivements.  These  concern  specifically  higher  weight  attributed  to  zero-emission 
solutions  when  establishing  the  ship’s  performance  in  achieving  the  yearly  target 
(“multipliers  for  zero-emission  options”)  as  well  as  the  possibility  to  not  only  average 
compliance  on  a  yearly  basis  (as  in  PO2)  but  also  pool  compliance  with  other  ships  / 
operators  via  a  mechanism  for  voluntary  transfer  and  compensation  of  balances.  This 
mechanism  does  not  represent  an  additional  regulatory  obligation,  but  it  offers  operators 
more  flexibility  and  an  additional  means  of  compliance  with  the  requirements,  allowing 
them to optimise the investments at the ship level. In practice, it will allow operators using 
more performant technologies to exchange “excess compliance points” with less perfomant 
ships / operators, provided that the minimum targets are met on average. A specific module 
will be added to the existing MRV system to track compliance and, where necessary trace 
the transfer of balance. Balances would be generated automatically and there would be no 
need for a system of auctioning or attribution. Also, as the mechanism remains voluntary, 
the  transfer  of  balance  will  not  be  subject  to  specific  conditions  but  be  governed  by 
private-law agreements between the concerned operators. In practice, most of the transfers 
are likely to take place within the same firm or group (representing de facto a solution to 
pool  compliance  at  company  level),  but  will  not  be  limited  to  it  and  would  offert  the 
possibiltiy to also provide transfers between different companies. Alternatively, a possible 
link with upcoming revision of the ETS to reward overachievers could  be also envisaged 

99  For  2015  the  average  GHG  intensity  of  marine  fuels  on  well  to  wake  basis  is  estimated  at  87  gCO2eq/MJ.  The 
emissions factors used are provided in Annex 4. 

41 

 
 
                                                           
(e.g.  through  the  provision  of  additional  free  allowances)  but  it  is  not  expected  to 
signifcantly affect the likely impacts of the instrument. The Commission will continue to 
foster  awareness  raising,  exchange  of  experience,  innovation,  encouragement  and 
promotion  of  industry-led  programmes  in  support  of  the  uptake  of  alternative  fuels, 
similarly to what is described for PO1 and PO2. 

Certification, reporting and enforcement 

In  order  to  document  compliance  with  the  regulatory  obligations,  an  EU-wide 
methodology to establish the performance / sustainability of fuels for maritime transport be 
based on the RED II Directive and EU MRV Regulation, both of which would be cross-
referenced in this initiative. As regards the latter, it is also proposed to   include the non-
CO2 emissions and alternative sources of power. Requirements for the certification of fuel 
suppliers  (incl.  in  third  countries)  and  documentation  to  report  performance  would  be 
necessary  and  as  above  it  would  be  also  based  on  RED  II  requirements.  In  PO3,  the 
performance of the fuel is not established on-board but needs to be documented on annual 
basis for the total energy generated on-board. A specific mechanism to account for possible 
pooled  compliance  and  transfer  of  balances  needs  to  be  established.  Additional  rules 
should be established for this purpose, including for monitoring, reporting and verification 
of consumption of alternative fuels in the context of the EU MRV and to harmonise PSC 
procedures.  

5.2.3  Specific aspects of policy design 

Concerning  the  more  specific  characteristics  of  the  proposed  policy  intervention,  the 
following aspects have also been considered and assessed in the same way for all POs.  

Targets  (volumes  or  GHG  intensity)  are  set  and  gradually  increase  over  time  to  deliver 
higher RLF penetration rates (and the related emissions reductions until 2050). All POs are 
designed to deliver similar GHG emission reductions pathways. Targets are specified up to 
2050  to  provide  operators  and  investors  with  sufficient  clarity  and  predictability.  The 
analysis  made  in  support  of  this  impact  assessment  also  include  increased  shares  of 
electricity covering the growing uptake of OPS by ships at berth; this was not available at 
the time of the work on the common economic assessment underpinning the 2030 Climate 
Target Plan and the Sustainable and Smart Mobility Strategy.  

The GHG performance of fuels is assessed on a well-to-wake basis, taking into account the 
impacts  of  production,  transport,  distribution  and  use  on  board.  This  is  to  incentivise 
technologies and production pathways that provide real benefits compared to the existing 
conventional fuels. This approach is also supported by the open public consultation (OPC) 

42 

 
 
 
results.100  The  emission  factors  reflect  the  characteristics  of  the  different  fuels  and  are 
provided in Annex 4. 

With regards to the type of emissions, the proposed intervention is not limited to CO2, but 
also  include  other  GHG  emissions  such  as  CH4  and  N2O  emissions.  Even  though  the 
volume  of  these  emissions  is  lower  than  CO2  only,  their  global  warming  potential  is 
stronger, in particular in the short term.  Including these emissions is particularly relevant 
as they may be fuel-dependent, which is for instance the case of CH4 which can be released 
as a slippage when using gaseous fuel. This option provides hence a more comprehensive 
approach to GHG emissions. 81% of the OPC respondents were in favour of at least this 
scope101.  Limiting  the  approach  to  CO2,  would  overlook  significant  GHG  emissions  that 
can be generated by fuels with CO2 savings potential, thereby creating a distortion between 
different technologies and potentially reducing overall GHG savings.   

In terms of addressees, the regulated entity should be a company with obligations put on 
each ship arriving and departing from EU ports. As for the MRV Regulation, the scope is 
limited to vessels beyond 5,000 gross tonnes. Even though these ships represents only ca 
55% of all ships calling EEA ports, in accordance with MRV data, they are responsible for 
90%  of  the  CO2  emissions  from  the  maritime  sector.  As  it  is  also  the  case  for  the  MRV 
Regulation,  small  emitters  (ships  below  5,000  gross  tonnes)  have  been  excluded  for 
proportionality reasons, because although they represent about 45 % of the fleet, they only 
account  for  10%  of  the  total  emissions.  According  to  estimates  provided  by  EMSA,  this 
picture  is  very  similar  when  considering  air  pollution.  Vessels  above  5,000  gross  tonnes 
account  for  94.5%  of  the  maritime  SOx  emissions  produced  by  ships  calling  EEA  ports, 
89.5% of the NO2 emissions and 57.9% of the PM2.5 emissions. The approach followed by 
this initiative focusses therefore on the highest emitters in order to strike the best balance 
between  the  environmental  objectives  while  limiting  the  potential  regulatory  and 
administrative  burden  to  the  smallest  operators.  As  in  the  scope  of  EU  MRV,  warships, 
fishing  vessels,  ships  not  propelled  by  mechanical  means,  and  inland  vessels  are  not 
covered  by  the  proposed  intervention.  The  scope  of  MRV  was  decided  on  the  basis  of  a 
proportionality analysis, which concluded that the measures would be disproportionate for 
these  ship  types102.  Regarding  warships,  there  is  no  legal  basis  for  the  Union  to  regulate 
them  under  the  TFEU.  Indeed,  this  initiative  concerns  sea  transport  as  explained  in  the 
legal basis in Section 3.1, which leaves out fishing vessels and inland vessels. 

The ships that have been excluded from the scope of this initiative may still benefit from 
supply-side  intervention  through  the  RED  as  revised  and  from  a  higher  availability  of 

100  In  the  open  public  consultation,  56%  of  the  respondents  (76/136)  were  in  favour  of  measuring  environmental 
performance on a well-to-wake basis. 
101 55% (75/136) of the OPC respondents indicated that the measurement should take into account both GHG (including 
CH4 and N2O) and air quality emissions. 26% (35/136) indicated that it should take into account just GHG. 12% (16/136) 
thought it should only focus on CO2. 
102 See the 2013 IA for the EU MRV proposal (SWD(2013) 236) and the 2019 IA for the revised MRV proposal 
(SWD(2019) 11). 

43 

 
 
                                                           
renewable and low-carbon fuels in ports following the revision of AFID. Small ships such 
as  tug  boats  and  dredger  vessels  might  not  engage  in  extra-EU  voyages  and  thus  be  less 
prone to carbon leakage. 

Some  possible  variants  allowing  pooled  compliance,  through  voluntary  transfer  and 
compensation of balances, have been tested as part of the assessment of PO3 as they could 
offer  additional  flexibility  to  the  industry.  For  the  retained  design  of  PO3,  the  pooled 
compliance is organised among different ships rather than companies, which proved to be 
the only solution that does not penalise small and medium size companies with a limited 
number  of  ships.  The  respondents  to  the  targeted  consultation  did  not  express  a  clear 
preference for an entity that should be regulated by the policy measure103.   

Concerning the geographical scope, the options have been assessed on a similar scope to 
MRV, which covers voyages from the last port of call to an EU port of call and from an 
EU  port  to  their  next  port  of  call104.  This  approach  is  expected  to  avoid  distortion  of 
competition among market actors, maximise the impacts and reap the full potential of the 
reporting  requirements  put  in  place  by  the  EU  MRV  Regulation.  A  similar  geographical 
scope has  been used for this measure in  the common economic assessment underpinning 
the  2030  Climate  Target  Plan  and  the  Sustainable  and  Smart  Mobility  Strategy.  On  the 
other hand, a more limited geographical  scope could  be easier to  accept  by third-country 
operators, but would have considerably lower impact. The OPC respondents did not clearly 
express a preference with regard to a particular geographical scope105.   

The monitoring, reporting and verification requirements of this initiative are based on the 
EU MRV Regulation, under which all ships calling at EEA ports, irrespective of their flag 
(i.e.  all  flags),  are  obliged  to  report  their  fuel  consumption  to  the  Commission  (via 
THETIS-MRV database) and to the EU flag States. It applies in a non-discriminatory way 
to all ships and requires third party verification in order to ensure the accuracy of the data 
submitted.  It  uses  a  specific  verification  system  similar  (though  simplified)  to  the  one 
applied in the EU Emissions Trading System (ETS), based on internationally agreed ISO 
standards and EU specific verification rules. As  Commission Communication of 2013 on 
integrating maritime transport emissions in EU’s GHG reduction policies106, the EU MRV 
Regulation was put in place to provide (among others) for robust and reliable data on GHG 
emissions  from  shipping  activities  as  a  prerequisite  for  any  further  policy  action  and  the 

103  The  targeted  consultation  shows  that  24%  of  the  respondents  chose  the  option  ‘each  individual  ship’  (8/32),  while 
‘company  fleet’  received  support  by  18%  of  the  respondents  (6/32).  In  addition,  50%  did not  indicate  a  preference  by 
choosing the option ‘no answer’ (16/32).   
104 Alternative approaches are discussed in Annex 6.  
105  The  open  public  consultation  indicates  that  there  is  no  agreement  among  the  respondents  concerning  the  right 
geographical scope. The  option ‘ships calling at ports of the EU’ received 30% of the responses (41/136), whilst 24% 
would prefer a scope taking into account ‘ships sailing in the territorial waters and Exclusive Economic Zones of the EU 
Member States’ (33/136). Only the proposal “ships bunkering in EU ports” received a very low rate of support, with 2% 
of responses (3/136). 
106 COM(2013) 479 final 

44 

 
 
                                                           
development  and  implementation  of  effective  EU  measures.  Additional  elements  that 
would need to be included in the EU MRV system are assessed in this impact assessment. 

In  addition  to  EU  MRV  monitoring,  reporting  and  verification  obligations,  this  initiative 
will  include  more  rigorous  compliance  and  enforcement  provisions.  Recognizing  that 
compliance  will  impose  additional  fuel  costs  on  ship  operators,  effective  enforcement  is 
important  to  avoid  distortion  of  competition  and  regulatory  loopholes.  It  is  therefore 
necessary  to  add  specific  provisions  for  demonstrating  compliance  with  this  initiative, 
while  building  on  existing  processes  to  minimize  administrative  burden.  Shipping 
companies will need to document to their third party verifier that they have been compliant 
with  the  RLF  requirements  coming  from  this  initiative.  Upon  fulfilment  of  the  reporting 
obligations, the third party verifier will then issue a Document of Compliance to the ship 
that can be checked in subsequent PSC inspections. Appropriate and proportional sanctions 
that  reflect  fuel  cost-savings  of  non-compliance  are  important  for  maintaining  the  level 
playing field in the sector.  

5.2.4  Additional elements of policy intervention 

In  addition  to  the  measures  resulting  directly  from  the  proposed  policy  intervention  and 
those included in the ‘basket of measures’ to address ship emissions, a number of ‘flanking 
measures’  would  also  help  addressing  the  problems  identified.  The  intensification  of  the 
work  at  international  level  (IMO)  on  the  development  of  lifecycle  GHG/carbon  intensity 
guidelines  for  all  types  of  fuels  paves  the  way  for  future  measures.  Steering  financial 
support towards the development and deployment of RLF is also relevant. This applies in 
particular  to  R&I,  where  the  preparation  of  the  co-programmed  ‘Zero  Emissions 
Waterborne Transport’ partnership under Horizon Europe is expected to play an important 
role of support. Public funding from Member States and the EU budget could also support 
the  uptake  of  RLF  through  deployment  of  the  necessary  infrastructure,  support  to 
investments, etc.  

5.3  Options discarded at an early stage or identified as complementary measures  

As already mentioned, the process of selection of policy options started with the analysis 
of the wider set of possible policy measures that is listed in Annex 6.  

In the following sections, further details are provided on those, non-retained, measures that 
deserve more attention, either because they are part of the ‘basket of measures’ for GHG 
emissions reduction and are subject of another impact assessment (ETS, ETD, RED II and 
AFID) or because they have been specifically proposed by stakeholders in the context of 
the consultations activities (energy  efficiency  standards).  In the former  case, the analysis 
also explores interaction and complementarities between different instruments.   

45 

 
 
5.3.1  Carbon  pricing  measures  (ETS  and  ETD)  and  impact  on  the  penetration  rate  for 

RLF 

As part of the ‘Fit for 55’ package, the Commission proposes the extension of the ETS to 
the  maritime  sector107,  therefore  introducing  carbon  pricing  also  for  maritime  operators. 
While  ETS  can  also  be  described  as  a  demand  side  measure,  its  scope  is  wider  than  the 
proposed  intervention  under  this  initiative,  as  it  addresses  overall  emissions  and  is  not 
targeted specifically at fuels. 

For any given level of activity, there are two categories of possible intervention to reduce 
ship  emissions:  either  measures  that  increase  energy  efficiency  (resulting  from  either 
design  /  technical  options  or  operational  choices)  or  greater  uptake  of  cleaner  fuels  and 
alternative sources of energy108. The ETS is designed to reduce emissions in the most cost-
effective  way,  triggering  first  the  cheapest  abatement  measures  and  only  later  the  more 
expensive options. There is ample scientific literature109 demonstrating that in most cases, 
options  like  voyage  execution,  routing,  speed  reduction,  reduction  in  auxiliary  power, 
optimised propellers have all lower marginal abatement costs than the switch to alternative 
fuels or the use of on-shore power supply while at berth. The ETS is therefore expected to 
affect  initially  energy  demand,  without  necessarily  influencing  also  the  type  of  energy 
used. 

The analysis carried out in the fourth IMO Greenhouse Gas Study confirms that the use of 
alternatives  fuels  in  maritime  have  a  comparatively  higher  abatement  costs  than  other 
options110. Out of the 16 technology groups identified by the study, the use of alternative 
fuels  ranks  as  the  second  or  third  most  expensive  technology  depending  on  whether  the 
focus is on the alternative fuels containing carbon (above 250 USD/t-CO2) or zero-carbon 
fuels  (above  410  USD/t-CO2).  The  difference  is  explained  in  this  case  by  the  expected 
higher fuel price resulting from synthesis process. Based on the fuel price projections used 
in  the  context  of  this  impact  assessment,  consistent  with  those  used  in  the  common 
economic assessment underpinning the 2030 Climate Target Plan and the Sustainable and 
Smart  Mobility  Strategy,  for  the  EU  ETS  to  make  RLF  economically  interesting  for  the 
maritime sector, a price of CO2 emission allowances of at least €200 would be necessary. 

107 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12660-Updating-the-EU-Emissions-Trading-
System  
108 This is well documented in existing literature, such as Bouman et.al.(2017), which assesses the potential of different 
options, gathered in six main groups: hull design, power and propulsion, economies of scale, speed, weather routing and 
scheduling, fuels and alternative energy sources. - Bouman et.al.(2017), State-of-the-art technologies, measures, and 
potential for reducing greenhouse gas emissions from shipping –a review, Transportation Research Part D 52, 408-421 
109 Relevant studies which have modelled a series of technical and operational measures in Marginal Abatement Costs 
Curves (MACC) for each vessel category: 
 CE DELFT 2011, Analysis of GHG Marginal Abatement Cost Curves, 
https://www.cedelft.eu/publicatie/analysis_of_ghg_marginal_abatement_cost_curves/1155  
DNV 2010, Pathway to low carbon shipping, abatement potential towards 2030 
TNO 2015, “GHG emission reduction potential of EU-related maritime transport and on its impacts”, study funded by 
DG CLIMA and available at: 
https://ec.europa.eu/clima/sites/clima/files/transport/shipping/docs/report_ghg_reduction_potential_en.pdf  
110 IMO (2020), Fourth IMO GHG Study 

46 

 
 
                                                           
By  comparison,  the  impact  assessment111  accompanying  the  2030  Climate  Target  Plan 
projects carbon prices for the ETS sector (including the maritime sector) in the range of 32 
to 65 €/tCO2, to cut the economy-wide GHG emissions by at least 55% by 2030. The EU 
ETS is therefore unlikely, by itself, to drive RLF uptake in the medium-term. 

As  a  result,  while  carbon  pricing  would  promote  a  reduction  of  CO2  emissions  in  all 
sectors  where  it  applies,  it  is  likely  that  interventions  in  the  maritime  sector  would 
concentrate  initially  only  on  energy  efficiency  improvements,  without  determining  any 
significant modification of the fuel mix. This is a problem because, in addition to the cost 
elements, the introduction of the new fuels is also hampered by the complexities and the 
long  lead  times  required  by  the  extra  coordination  of  fuel  supply  and  distribution 
(including  the  deployment  of  the  specific  infrastructure  when  necessary).  Whereas  most 
energy efficiency measures can be implemented by individual operators  – via operational 
measures, retrofitting or technical specifications of new vessels – the uptake of alternative 
fuels is more complex and typically outside the control of the single operator. 

The simplest case is the use of drop-in low and zero-carbon sustainable fuels, as these can 
virtually  be  used  in  current  machinery  on-board  and  taking  advantage  of  the  existing 
infrastructure.  However,  this  requires  sufficient  levels  of  production  and  availability  in 
ports  that  would  have  to  be  triggered  by  predictable  demand.  Other  technologies  like 
hydrogen or ammonia are even more complex, as they would in principle require dedicated 
infrastructure for distribution, safety certification, and new bunkering protocols, in addition 
to technical adaptation of vessels and sufficient production from renewable sources.  

Accordingly, the marginal abatement cost curve in the maritime sector is not likely to be 
smooth and allow a gradual uptake of abatement options in line with the evolution of the 
carbon price. On the contrary, the risk is that once the energy efficiency options have been 
exploited, the uptake of fuel technologies would require considerable time, before reaching 
sufficient levels, had it not been prepared in advance. For this reason, while ETS has other 
advantages  such  as  facilitating  emission  reductions  in  a  cost-effective  manner  across 
sectors, it has been identified as a desirable complementary measure, but not one sufficient 
to address all the problems identified in this impact assessment, focused on the insufficient 
penetration of RLF in the maritime fuel mix. A dedicated policy intervention, such as the 
one proposed under FuelEU Maritime is expected to establish the necessary conditions for 
lead markets to start emerging as rapidly as possible and to support the deployment of  new 
fuel technologies to deliver on the post-2030 climate objectives. 

On  the  other  hand,  the  present  initiative  does  not  weaken  the  case  for  the  inclusion  of 
maritime transport in the ETS. Carbon pricing will render profitable certain measures and 
investments  in  energy  efficiency  which  are  not  targeted  by  fuel  mandates  and  will  also 
contribute to reducing the price gap between fossil fuels and RLF. More importantly, the 

111 SWD(2020) 176 final. 

47 

 
 
                                                           
ETS ensures that all the sectors comprised in the system respect, as a whole, the total cap 
on  emissions.  This  means  that  any  departure  of  individual  sectors  from  the  intended 
sectoral emission abatement target – which could result from a variety of factors, including 
unrealised  expectations  on  the  level  of  economic  activity  or  the  effectiveness  of  policy 
measures – will find automatic compensation via adjustments of the carbon price. In other 
words, independently on the level of emission reductions that can be attributed to the ETS 
or  to  other  interventions,  ETS  has  an  important  role  in  ensuring  overall  consistency  and 
climate integrity of the policy framework. Last but not least, ETS revenues could also be 
used  in  support  of  a  higher  penetration  of  RLF  by  using  available  budget  from  the 
Innovation Fund to  bring to  the market  innovative industrial solutions  to decarbonise the 
EU and support its transition to climate neutrality.   

Besides  ETS,  energy  taxation  can  also  have  an  impact  on  the  relative  price  of  RLF  and 
influence the demand for fuels. The review of the ETD will result in an increased cost  of 
conventional  fuels,  but  as  in  the  case  of  ETS,  the  price  increase  would  have  to  be 
substantial in order to render profitable the use of RLF. To give an example, a tax rate of at 
least  550  EUR/1000  litres  for  diesel,  coupled  with  a  tax  exemption  for  RLF,  would  be 
needed to make the latter fuels competitive. The ETD has also the additional problem that 
ships can easily circumvent its provisions by bunkering outside the EU, especially if high 
tax rates are put in place to bridge the price gap. In any event, the ETD remains a taxation 
instrument whose primary goal is revenue collection; while it can have incentive effects for 
RLF,  it  cannot  be  fine-tuned  to  the  exclusive  needs  of  RLF  promotion  in  the  maritime 
sector. 

5.3.2  A  standard  for  carbon  intensity  of  maritime  operations  (limit  for  CO2  emissions 

per tonne-nautical mile)  

In response to the public consultation, some stakeholders have argued in favour of setting a 
standard for the carbon intensity of maritime operations. 

In line with  the MRV Regulation, the CO2 emissions of the ships  (and hence the  carbon 
intensity of operations if this figure is made relative to distance / tonnes of cargo carried) is 
the product of the amount of fuel consumed multiplied by the emission factor of the given 
fuel. The first term of this equation relates to the amount of energy used while the second 
focuses on the carbon intensity of the energy.  

In  other  words,  maritime  operators  would  have  to  reduce  their  emissions  per  unit  of 
‘transport  work’  (e.g.  expressed  in  CO2  per  tonne-nautical-mile)  and  could  do  so  by 
improving their energy efficiency (first term), by using energy with lower carbon content 
(second term), or via a combination of the two (both terms). 

Similarly  to  the  case  of  carbon  pricing,  this  approach  is  expected  to  have  only  a  very 
limited  impact  on  the  uptake  of  RLF  in  the  short  term  as  the  market  actors  would  first 
favour  solutions  with  lower  marginal  abatement  costs  and  less  complexities  in  terms  of 
introduction (no coordination of actors, etc.). As in the case of carbon pricing (e.g. ETS), 

48 

 
 
this  instrument  could  be  considered  as  a  solution  to  other  market  failures,  but  not  to  the 
problems highlighted in this impact assessment, in terms of the insufficient penetration of 
RLF in the maritime fuel mix and the need to prepare their uptake in advance. 

Building on this policy option, a possible alternative would be to establish sub-targets for 
each term of the equation. In this case, establishing a carbon intensity limit for the energy 
used  is  actually  comparable  to  the  PO2  and  PO3  described  in  Section  5.2.1.  While 
improving  energy  efficiency  of  maritime  transport  will  be  an  essential  instrument  to 
decarbonise the sector, their impact on RLF uptake is expected to be more modest. For this 
reason, the introduction of additional targets on energy efficiency have not been assessed 
in greater details in the context of this initiative. 

5.3.3  Revision of other relevant legal instruments (AFID and RED II)  

One aspect that has been also considered is whether the problem drivers identified in this 
report could be addressed via the revision of AFID and the RED II (cf. Section 1.2). 

Both  are  directives  addressed  at  Members  States,  to  promote,  in  the  case  of  AFID,  the 
provision of infrastructure for use of alternative fuels, and, in the case of RED II (for the 
part related to the transport sector), to set obligations on fuel suppliers to ensure a certain 
share  of  renewable  energy  in  final  consumption.  By  not  addressing  demand,  these  tools 
would  not  solve  the  carbon  leakage  issue.  For  example,  even  if  obligations  on  suppliers 
resulted in RLF (or otherwise-defined complaint fuels) being the only fuels available in EU 
ports, vessels would retain the possibility to bunker conventional fuels outside the EU. In 
addition,  RED  II  and  AFID  do  not  guarantee  a  level  of  demand  that  would  justify 
investments in supply and distribution. This is also the reason why they did not succeed so 
far in promoting RLF in maritime.  

One possibility would have been to modify the current approach in RED II and AFID and 
include  an  aspect  of  ‘maritime  demand’  into  those  instruments.  However,  addressing 
vessels  operators  in  RED  II  and  AFID  would  have  been  quite  complex  from  a  legal 
drafting  perspective  because  of  the  different  addressees  and  the  need  to  include  a  lot  of 
specific  provisions  for  maritime  transport  in  horizontal  instruments  that  cover  the  entire 
transport  sector  (and  beyond  for  RED  II).  In  both  cases,  the  inclusion  of  provisions 
addressed to maritime operators would not have been in line with the general approach of 
these instruments, would have create unnecessary complexity, and would have run against 
the  Commission’s  better  regulation  principles.  Moreover,  the  two  directives  could  be 
implemented differently by the various Member States, which could be problematic for  a 
sector with a strong international connotation as maritime. 

The conclusion that the revision of RED II and AFID is capable, on its own, to address all 
the  problems  identified  in  this  report  should  not  overshadow  the  important  role  of  these 
instruments  in  ensuring  the  overall  goal  of  promoting  use  of  RLF,  also  in  the  maritime 
sector. Very important complementarities exist between demand, supply and distribution of 
RLF, and if one of these three components is not adequately developed, the overall goal of 

49 

 
 
promoting use of RLF would be compromised. Indeed, the lack of sufficient demand can 
be held responsible for the extremely limited impact that RED II and AFID have had in the 
maritime sector until now. A proposal that targets demand can make the difference, since it 
is  more  likely  that  market  players  on  the  supply-side  accommodate  developments  in 
demand,  rather  than  demand  be  created  by  the  supply  of  (more  expensive)  RLF. 
Nevertheless, the revised RED II and AFID is necessary to correct any market failures that 
exist on the side of RLF supply and distribution. 

5.4  Feasibility of alternative pathways for the uptake of RLF 

As explained in Section 1.5, the trajectory for the uptake of RLF in PO1 has been based on 
the  common  economic  assessment  underpinning  the  2030  Climate  Target  Plan  and  the 
Sustainable  and  Smart  Mobility  Strategy  while  considering  a  combination  of  carbon 
pricing and medium intensification of regulatory measures in all sectors of the economy. It 
has been derived in a way that enables kick starting the scale-up of RLF in the international 
maritime  sector  from  2025  onwards  and  their  large  scale  deployment  by  2050,  while 
ensuring the consistency with the required overall GHG emissions reductions by 2030 and 
2050,  preserving  the  competitiveness  of  the  sector,  promoting  innovation,  and  ensuring 
feedstock  availability  for  renewable  and  low  carbon  fuels  in  all  energy  and  transport 
sectors  in  the  transition  towards  a  climate  neutral  economy.  An  update  of  the 
pathway/scenario focusing on a combination of carbon pricing and medium intensification 
of  regulatory  measures  in  all  sectors  of  the  economy  for  the  purpose  of  the  ‘Fit  for  55’ 
package, while also reflecting the COVID-19 pandemics, the National Energy and Climate 
Plans and refining the policy design of the initiatives, confirms that international maritime 
sector effectively contributes to the EU climate goals while considering the RLF trajectory 
in PO1. As further explained in Section 5.2.1, PO2 and PO3 have defined in such way to 
ensure  comparable  well  to  wake  GHG  emissions  reductions  as  PO1.  This  approach 
preserves the consistency with the EU climate objectives for 2030 and 2050 in all policy 
options.  

As  regards  the  possible  impact  of  fuel  mandates  on  the  ETS  system,  the  analysis  above 
suggests that abating emissions via use of clean energy comes at a higher cost than the ETS 
carbon price. The implication is that in the presence of fuel mandates the maritime sector 
would reduce its emissions – and thus its demand for ETS allowances – to a greater extent 
than otherwise. As  explained in  Section 1.5, the economic assessment taken as reference 
for the definition of the policy options in this report simulates the joint operation of a fuel 
mandate and ETS. If the fuel mandate is removed (or set at a lower level of ambition), the 
result in  the short and medium term  would be an upward shift  in  the overall demand for 
allowances,  a  correspondingly  higher  carbon  price,  and  a  shift  in  emission  cuts  from  the 
maritime  sector  to  other  ETS  sectors.  In  the  longer  term,  the  postponement  in  the 
deployment and adoption of RLF technologies would lead to higher abatement costs and a 
higher carbon price imposed on the economy. This is explained in more detail below.  

50 

 
 
A somewhat lower RLF uptake by 2030 would be possible, but the lower RLF uptake is 
expected to push the price of the EU ETS allowances upwards. In this case, the impacts on 
emissions  reductions  in  the  maritime  sector  by  2030  would  be  more  limited,  while 
somewhat higher emissions reductions would take place in other sectors. At the same time, 
with a lower RLF uptake by 2030, the build-up of RLF capacities could be delayed, due to 
path dependency effects, diverting them (i.e. advanced biofuels, e-fuels) towards the road 
transport  sector,  where  more  promising  options  (like  for  example 
large  scale 
electrification)  are  available.  Post-2030,  a  steeper  trajectory  for  the  reduction  in  the 
maritime  transport  emissions  would  be  needed  to  contribute  towards  EU  climate  neutral 
economy  by  2050.  This  would  require  a  steep  build-up  of  RLF  production  capacities, 
starting from  a low base and under a limited time horizon, which may not be feasible.  It 
may  require substantially higher effort when approaching 2050. The latter could result in 
steep reductions in maritime transport activity, with negative consequences on jobs in the 
sector, connectivity, as well as growth of businesses and regions. 

A somewhat higher RLF uptake by 2030 would also be possible. The higher RLF uptake is 
expected  to  push  to  some  extent  the  price  of  the  EU  ETS  allowances  downwards  and  to 
require less emissions reduction efforts in other sectors. Yet, a higher RLF by 2030 would 
lead to a higher increase in the freight rates than in the central trajectory, with impacts on 
growth  of  businesses  and  regions,  while  more  options  for  emissions  reduction  would  be 
available in other sectors at lower costs. At the same time, some advanced biofuels would 
still be required in the road transport sector by 2030 considering that the electrification of 
the sector takes time due to the gradual replacement of the vehicle fleet. The higher RLF 
uptake  may  intensify  the  competition  for  biomass  feedstock  with  other  transport  and 
energy sectors, pushing the feedstock prices further up. Post-2030, continuing the central 
RLF  uptake  trajectory  would  ensure  the  required  contribution  towards  the  climate 
neutrality by 2050.  

Overall,  as  explained  in  Section  1.5,  a  range  of  6  to  9%  for  the  share  of  RLF  in  the 
international  maritime  fuel  mix  is  feasible  by  2030,  while  keeping  in  mind  the 
considerations above. The possibilities of lower or higher RLF uptake post-2030 are more 
limited while ensuring the consistency with the required overall GHG emissions reductions 
by 2050, preserving the competitiveness of the sector, promoting innovation, and ensuring 
feedstock  availability  for  renewable  and  low  carbon  fuels  in  all  energy  and  transport 
sectors  in  the  transition  towards  a  climate  neutral  economy.  This  assessment  takes  into 
account  the  current  knowledge  related  to  the  possible  evolution  of  technology  costs  and 
feedstock  costs.  If  higher  decrease  in  these  costs  would  materialise  in  the  future,  higher 
RLF could be possible post-2030. On the other hand, lower uptake post-2030 may require 
substantially  higher  effort  when  approaching  2050,  with  the  associated  risks  explained 
above.   

51 

 
 
6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

This section summarizes the main expected economic, social and environmental impacts of 
each  PO.112  This  analysis  does  not  only  focus  on  the  impacts  expected  for  the  ship 
operators  but  also  consider  them  for  the  maritime  cluster  at  large,  including  ports 
(particularly  given  the  need  for  potential  specific  infrastructure  deployment),  technology 
providers and shipbuilders as well as fuel suppliers. 

In terms of time horizon, the assessment has been undertaken for the 2025-2050 period (in 
five-year  steps).  The  measures  that  are  part  of  the  POs  are  assumed  to  be  implemented 
from 2025 onwards. This long term perspective is particularly important as the penetration 
of RLF requires a long period for building RLF production and distribution capacity.  

The  analysis  presented  in  this  section  covers  the  EU27  scope.  Costs  and  benefits  are 
expressed  as  present  value  using  a  4%  discount  rate.  While  the  results  presented  in  this 
section  concern  the  impacts  of  the  POs  over  the  2025-2050  period,  it  is  important  to 
remind  that  the  costs  and  benefits  will  be  spread  out  over  time  due  to  the  gradual 
strengthening of the regulatory targets. More details on the modelling  exercise, including 
the possible limitations and uncertainties, are provided in Annex 4.  

6.1  Economic impacts 

Different  aspects  have  been  analysed  to  determine  the  economic  impacts  of  each  of  the 
POs. These concern: the impacts on ship operators, the impacts on RLF prices, feedstocks 
and renewable electricity needs, the regulatory costs for economic actors, the costs related 
to enforcement, the impacts on ports to provide the necessary infrastructure, the impact on 
the EU maritime cluster and the impact on third countries.  

6.1.1 

Impacts on ship operators 

Impacts on the fuel mix used by ship operators: The direct impact of the assessed POs 
will be the increased share of RLF in the overall maritime energy mix. Table 2 presents the 
evolution  of  this  share  for  each  of  the  PO  and  the  baseline  for  two  specific  target  years: 
2030 and 2050. It also presents a breakdown by type of RLF uptake corresponding to each 
PO.  

Table 2 Share of renewable and low carbon fuels in maritime energy use in navigation and at berth  

Share of renewable and low 
carbon fuels in maritime energy 
use (in %) 

Baseline 

PO1 

PO2 

PO3 

2030 

2050 

2030 

2050 

2030 

2050 

2030 

2050 

Total 

0.3% 

1.4% 

8.6% 

86.9% 

8.6% 

89.5% 

8.6% 

88.8% 

112 The analysis in this section is based on modelling performed by E3Modelling with the PRIMES-TREMOVE transport 
model and by TRT with the TRUST model, on the Ecorys et al (forthcoming) Assessment of impacts from accelerating 
the uptake of sustainable alternative fuels in maritime transport, and on the analysis of stakeholders' feedback. References 
to the sources of specific information and explanations  of assumptions underlying various cost and benefits results are 
further presented in Annex 4. 

52 

 
 
                                                           
Share of renewable and low 
carbon fuels in maritime energy 
use (in %) 

biofuels 
bio-LNG 
e-liquids 
e-gas 
hydrogen 
ammonia 
methanol 
electricity 

of which at berth 

Baseline 

PO1 

PO2 

PO3 

2030 

2050 

2030 

2050 

2030 

2050 

2030 

2050 

0.1% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.1% 
0.1% 

1.3% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
0.1% 
0.1% 

6.0% 
1.2% 
0.2% 
0.0% 
0.0% 
0.0% 
0.0% 
1.3% 
1.2% 

39.0% 
14.2% 
16.3% 
6.5% 
7.9% 
0.5% 
0.3% 
2.1% 
1.0% 

6.2% 
1.2% 
0.0% 
0.0% 
0.0% 
0.0% 
0.0% 
1.2% 
1.2% 

47.8% 
16.8% 
13.4% 
4.9% 
4.8% 
0.2% 
0.1% 
1.4% 
1.0% 

6.1% 
1.2% 
0.1% 
0.0% 
0.0% 
0.0% 
0.0% 
1.2% 
1.2% 

42.4% 
15.4% 
15.8% 
5.6% 
7.2% 
0.4% 
0.2% 
1.9% 
1.0% 

Source: PRIMES-Maritime, E3Modelling; Note: hydrogen in this table covers both hydrogen used in fuel cell vessels and direct use of 
hydrogen. 

These results indicate a number of important elements to take into account. The increased 
penetration of RLF in the maritime fuel mix will be gradual, with relatively modest shares 
by 2030 (i.e. around 3% of the fuel mix in 2025 and 8.6% in 2030 in all POs) and then an 
acceleration of the uptake by 2040 to reach around 87-89% of the total fuel mix by 2050. 
The overall shares of RLF in the fuel mix in Table 2 also take into account the analysis of 
the  OPS  requirements  at  berth,  which  was  not  available  at  the  time  of  the  common 
economic assessment underpinning the 2030 Climate Target Plan and the Sustainable and 
Smart Mobility Strategy. Electricity used at berth is projected to represent 94-99% of the 
overall electricity used in the maritime sector in 2030 (94% in PO1, 99% in PO2 and 96% 
in PO3) and 46-75% in 2050 (46% in PO1, 75% in PO2 and 53% in PO3).  

While  the  overall  penetration  rate  is  comparable  in  all  three  POs,  due  to  the  fact  that  by 
design  they  achieve  similar  reductions  in  the  GHG  emissions  on  well  to  wake  basis,  the 
type  of  RLF  deployed  diverge  between  them,  in  particular  as  time  progresses  and  more 
technologies mature.  

The  share  of  biofuels,  which  represent  today  the  most  cost-effective  way  to  reduce  the 
GHG  intensity  of  the  fuels,  is  the  highest  in  PO2  (48%  of  the  fuel  mix by  2050),  which 
remains fully goal-based with no incentive for overachievers. Bio-LNG uptake in the fuel 
mix also shows the largest share in PO2. In lack of any specific mandate (like in PO1) or a 
mechanism  to  reward  the  use  of  the  most  advanced  technologies  (like  in  PO3),  PO2 
therefore  focusses  mainly  on  the  currently  cheapest  and  most  readily  available  technical 
solution.  

PO1  results  in  higher  shares  of  hydrogen-based  fuels  (e-fuels,  hydrogen,  ammonia  and 
methanol) as well as electricity, due to constraints on the use of biofuels by design of the 
policy  option  and  incentives  for  renewable  fuels  of  non-biological  origin  (RFNBOs)113. 
This  reflects  the  regulator’s  preference  for  hydrogen  based  fuels  and  for  a  wider 

113 RFNBOs follow the definition of the Renewables Energy Directive. 

53 

 
 
                                                           
availability  of  technological  solutions  and  pathways  to  decarbonisation,  which  would 
alleviate pressure on feedstocks for advanced biofuels. 

PO3  is  also  based  on  a  goal-based  approach  like  PO2,  but  the  share  of  hydrogen-based 
fuels  and  electricity  is  projected  to  be  closer  to  that  in  PO1  as  a  result  of  the  incentives 
given to over-achievers. Hydrogen-based fuels and electricity are projected to deliver 31% 
and 34% of the fuel mix in PO3 and PO1, respectively.114   

Costs for ship operators: The additional fuel costs relative to the baseline are the largest 
cost item resulting from the proposed intervention. The fuel choice resulting from each of 
the  POs  is  also  an  important  driver  of  the  overall  costs  of  the  measure.  PO2  shows  the 
lowest additional capital and fuel costs relative to the baseline. This results directly from 
the highest share of drop-in fuels in the overall energy mix, and in particular biofuels. The 
use  of  these  fuels  does  not  require  significant  capital  investment  on  the  ships  and  is 
currently the cheapest available fuel alternative.  

PO3 and PO1 have higher additional costs relative to the baseline than PO2 as the share of 
hydrogen-based  fuels  (e-fuels,  hydrogen  and  ammonia)  and  electricity  increases.  This 
concerns  also  the  capital  costs  as  specific  propulsion  systems  (fuel  cells  and  electric 
vessels), which are not compatible with current engines, are expected to be used in greater 
proportion.  

Bearing  in  mind  that  the  RLF  penetration  takes  place  gradually  over  time,  fuel  costs  are 
projected to  increase by  2.9-3.2% in  2030 relative to  the baseline and total  costs by  2.6-
2.8%.  The  highest  increase  in  the  fuel  and  total  costs  would  take  place  in  PO1  and  the 
lowest in PO2, with PO3 falling between the two. 

PO2  has  also  slightly  higher  additional  capital  costs  for  equipping  vessels  with  OPS 
(€2.6bn expressed as present value over 2021-2050, relative to the baseline) than PO1 and 
PO3 (€2.5bn). That is due to the larger share of conventional engine ships in PO2115, which 
provides fewer alternatives to the use of OPS in ports.  

Finally, all POs also show a slight decline in operation costs (around 1% compared to the 
baseline),  resulting  from  lower  maintenance  and  crew  costs  driven  by  lower  transport 

114 The electricity to produce synthetic fuels (i.e. e-ammonia, e-methanol, synthetic diesel, synthetic fuel oil and e-gas) is 
projected to be the highest in PO1 (almost 2 TWh in 2030 and 246 TWh in 2050). This would represent around 0.1% of 
renewable electricity generation in 2030 and 4.7% by 2050. In PO3 the electricity to produce synthetic fuels is projected 
at around 0.6 TWh in 2030 and 2030 by 2050 (i.e. less than 0.1% of renewable electricity generation in 2030 and 4.4% in 
2050). PO2 shows the lowest share of synthetic fuels in the energy mix and thus the lowest electricity needs to produce 
them (0.1 TWh in 2030 and 198 TWh in 2050). The electricity is primarily used to produce synthetic diesel blends and 
clean gas. More details are provided in Annex 4. 
115 CAPEX related to OPS have been estimated by assuming OPS equipment installation on vessels powered by internal 
combustion  engines  (as  opposed  to  electric  ships  or  fuel  cells)  from  the  three  ship  types  concerned  by  the  OPS 
requirements.  In  terms  of  cost  estimates,  the  valuation  has  been  done  using  the  high  estimates  from  GloMEEP 
(https://glomeep.imo.org/technology/shore-power/)  taking  into  consideration  the  vessel  size  distribution  on  each  of  the 
ship types as observed in MRV reporting.  

54 

 
 
                                                           
activity relative to the baseline. The costs in Table 3 are presented as present value over the 
2021-2050 time horizon.    

Table 3 Total costs for ship operators compared to the baseline (present value over 2021-2050 horizon) 

Costs for ship operators - present value for 
2021-2050  compared to Baseline (bil. €'2015) 

Baseline (bil. 
€'2015) 

Capital costs 

of which for OPS on vessels 

Fuel costs  
Operation costs 

Total costs 
Source: PRIMES-Maritime, E3Modelling 

428 
0.8 
561 
232 
1,221.1 

PO1 

26.9 
2.5 
69.1 
-2.4 
93.6 

PO2 

22.9 
2.6 
59.1 
-2.2 
79.8 

PO3 

25.8 
2.5 
63.9 
-2.3 
87.3 

Impacts on transport activity: While maritime transport activity would continue growing 
over  the  period  until  2050  in  all  POs,  a  slight  decrease  of  2.7%  for  freight  and  4%  for 
passenger  traffic  compared  to  the  baseline  is  projected  as  a  result  of  the  policy 
intervention. In freight transport, the highest impact is projected on short-sea shipping, as 
this  segment  is  expected  to  operate  mostly  in  voyages  covered  by  the  proposed 
intervention. The situation is similar and reinforced for passenger transport, where higher 
uptake of electric and fuel ships is projected to result in somewhat higher costs.  

Table 4 Changes in the maritime transport activity 

Transport activity (% change to 
Baseline) 

Total freight sea shipping (Gtkm) 

Short sea shipping 
Deep sea shipping 

Passenger Shipping Activity (Gpkm) 
Source: PRIMES-Maritime, E3Modelling 

Baseline (levels) 

PO1 

PO2 

PO3 

2030 
17,075 
3,080 
13,995 
2,426 

2050 
21,354 
3,817 
17,537 
3,016 

2030 
-1.0% 
-1.1% 
-0.9% 
-1.1% 

2050 
-2.7% 
-3.2% 
-2.7% 
-4.0% 

2030 
-1.0% 
-1.1% 
-0.9% 
-1.1% 

2050 
-2.7% 
-3.2% 
-2.7% 
-4.0% 

2030 
-1.0% 
-1.1% 
-0.9% 
-1.1% 

2050 
-2.7% 
-3.2% 
-2.7% 
-4.0% 

The baseline scenario and the policy options take into account  the reduction in  the long-
distance shipping of fossil fuel volumes driven by the carbon policies and National Energy 
and Climate Plans. On the other hand, some increase in the transport of renewable and low 
carbon  fuels  from  EU  producing  countries  to  the  other  EU  countries  is  projected  to 
moderate this decrease to some extent in the policy options.  

6.1.2 

Impacts on RLF prices, feedstock and renewable electricity needs for e-fuels 

Impacts  on  RLF  prices:  The  assessment  assumes  the  implementation  of  measures  by 
various actors that enables the uptake of advanced technologies at scale, not only for the 
maritime  sector.  This  is  particularly  relevant  for  advanced  biofuel  production  routes  that 
are  not  yet  commercially  available.  Novel  routes  relate  mainly  to  advanced  biodiesel 
produced  from  Gasification  and  Fischer-Tropsch  synthesis,  biofuel  oil  produced  from 
Hydrothermal  Upgrading,  and biomethane from  Catalytic  Gasification of biomass.  These 
biomass conversion technologies are capital intensive, yet empirical observations suggest 

55 

 
 
 
that learning effects  due to  scaling of production are possible. The demand for advanced 
biofuels  and  bio-LNG  (Annex  IX  Part A  of  REDII)116  leads  to  additional  production 
capacity in the EU. In the context of the transition towards a climate neutral economy by 
2050, the demand for advanced biofuels comes from all transport sectors (and other sectors 
of the energy system) reducing production costs through economies of scale and learning-
by-doing.  

In the short-term, the demand for advanced biodiesel comes primarily from road transport 
and  that  of  bio-LNG  from  other  sectors  of  the  energy  system.  The  demand  of  bio  heavy 
fuel oil comes mainly from maritime. As such, in the short-term, the demand for RLF in 
the  maritime  sector  contributes  primarily  to  the  cost  reduction  of  bio  heavy  fuel  oil. 
Beyond  2030,  due  to  the  significant  increase  in  the  uptake  of  electric  vehicles  in  road 
transport, maritime becomes a key sector that drives the production of advanced biodiesel 
and bio-LNG and  further reduces the costs of scalable components  of these technologies 
through  an  increase  in  cumulative  production  capacity  and  technological  learning.  A 
counterbalancing effect would however come into play from the increase in feedstock costs 
driven by the demand for biomass feedstock from other sectors. These insights are based 
on the modelling of bioenergy demand in the context of the EU climate ambition for 2030 
and  2050,  which  means  that  significant  quantities  of  bioenergy  are  needed  by  other 
transport  modes  (including  aviation)  and  energy  sectors.  Hence,  the  biomass  system  is 
pushed towards more expensive feedstocks, outweighing to some extent the benefits from 
scaling  the  production  that  may  be  brought  from  the  increase  in  the  advanced  biofuels 
demand  in  the  maritime  sector.  In  the  PRIMES  biomass  model,  which  is  used  for  the 
purpose  of  this  assessment,  the  reduction  in  the  costs  of  scalable  components  of  these 
technologies and the impacts due to higher feedstock demand are both taken into account.  

Annex IX Part B biofuels are mainly represented by the FAME and the HVO production 
route  that  use  used  cooking  oil  as  feedstock.  These  are  mature  technologies/pathways 
commercially available today that have benefited from cost reductions due to the increase 
in  the  demand  for  biodiesel  used  in  road  transport.  On  the  other  hand,  the  production 
technologies for advanced biofuels are not yet available at scale, and require investments in 
first-of-a-kind  plants.  Their  scale-up  would  benefit  from  learning  effects  and  result  in 
lower  costs.  Another  reason  that  leads  to  cost  differences  between  Annex  IX  Part  B  and 
advanced biofuels (Annex IX Part A) is that the latter require substantially more quantities 
of biomass feedstock input compared to Part B biofuels produced from used cooking oil. 
This leads to overall higher feedstock costs of advanced biofuels compared to Part B. Food 
and feed crop-based biofuels are out of scope of the policy options. 

Similarly to advanced biofuel routes, the demand for hydrogen and  hydrogen-based fuels 
(e-fuels,  ammonia  and  methanol)  from  maritime  but  also  from  other  transport  sectors 
drives an increase in hydrogen demand and eventually leads to large-scale deployment of 

116 Annex IX Part A and Part B biofuels follow the definition of the Renewables Energy Directive. 

56 

 
 
                                                           
hydrogen  generation  technologies.  The  modelling  considers  learning-by-doing  effects, 
reducing the costs of electrolysers, which is a critical cost component. 

The  evolution  of  the  RLF  prices  used  in  the  modelling  supporting  the  assessment  of  the 
policy  options  is  consistent  with  those  used  for  the  common  economic  assessment 
underpinning  the  2030  Climate  Target  Plan  and  the  Sustainable  and  Smart  Mobility 
Strategy and is provided in Annex 4. The price of biofuels (weighted average price of bio 
heavy oil  and biodiesel) used in international  maritime remains  relatively  stable between 
2030  and  2050,  due  to  the  competition  for  biomass  feedstock  with  other  energy  and 
transport sectors and despite the reduction in the costs of scalable components as explained 
above. However, the ratio between the biofuels price and the price of liquid fossil fuel used 
in maritime products goes down over time, to 2.1 in 2030 and 1.5 by 2050. Similarly, the 
ratio between the e-liquids prices and liquid fossil fuel prices goes down from 3.6 in 2030 
to 1.9 by 2050.   

Types  of  biofuels  and  feedstock:  Biofuels  and  bio-LNG  consumption,  together,  is 
projected to increase almost by a factor of 10 between 2030 and 2050, from around 3 Mtoe 
in 2030 up to 32 Mtoe in 2050. The highest supply is projected in PO2 (close to 32 Mtoe) 
and the lowest in PO1 (around 26 Mtoe) with PO3 falling in between (28 Mtoe). In their 
vast majority, Annex IX Part A (advanced biofuels and bio-LNG)117 would be supplied to 
the maritime sector (more than three-quarters of supply to the maritime sector in 2030 and 
90% in 2050, similarly across policy options). Annex IX Part B biofuels would cover the 
remainder of the biofuel demand. Biofuels imports for the maritime sector are projected to 
account for around 1.5% in 2030 to 4% in 2050 of the total biofuel demand in the sector. 
These would be biodiesel imports that are assumed to be exclusively Part B biofuels. More 
details are provided in Annex 4.  

By 2030, the vast majority of the feedstock used is projected to originate from forestry and 
from biomass waste flows, whether agricultural residues, wood waste or manure. By 2050, 
energy  crops  and  notably  dedicated  energy  crops  (annual  lignocellulosic  crops)  provide 
more  than  one-third  of  the  feedstock  required  to  produce  Part  A  biofuels.  Substantial 
growth  is  also  projected  in  agricultural  residues  used  for  biofuels  production  in 
international maritime that increase by more than a factor of 10 between 2030 and 2050. 

Table 5 Biomass feedstock consumption by type (in Mtonnes) 

Feedstock consumption 

PO1 

PO2 

PO3 

Mtonnes 
Part A 

Perennial crops 
Annual crops 
Forestry products 
Forestry residues 

2030 

2050 

2030 

2050 

2030 

2050 

               0.0  
               0.3  
               3.1  
               1.4  

               6.3  
             33.6  
             14.4  
             11.7  

          0.0  
          0.3  
          3.2  
          1.5  

              7.7  
            40.8  
            18.4  
            14.7  

          0.0  
          0.3  
          3.1  
          1.5  

              6.9  
            36.4  
            15.9  
            12.8  

117 Annex IX Part A and Part B biofuels follow the definition of the Renewables Energy Directive. 

57 

 
 
  
  
  
  
  
  
                                                           
Feedstock consumption 

PO1 

PO2 

PO3 

Mtonnes 

Wood waste 
Agricultural residues 
Manure 

Part B 

2030 
               1.8  
               1.5  
               1.2  

2050 
               6.7  
             15.4  
               2.8  

2030 
          1.8  
          1.5  
          1.2  

2050 
              8.0  
            18.6  
              3.3  

2030 
          1.8  
          1.5  
          1.2  

2050 
              7.2  
            16.8  
              3.0  

Non-agricultural oils 

             0.80  

               1.4  

        0.83  

              1.8  

        0.82  

              1.6  

Source: PRIMES Biomass model, E3Modelling 

Model projections show that EU has sufficient biomass available domestically to produce 
biofuels  and  bio-LNG  for  EU  international  maritime  sector.  By  2030,  there  is  sufficient 
supply of waste lipids (non-agricultural oils, such as used cooking oil), as the demand from 
international  maritime  requires  about  20%  of  the  feedstock  available  in  the  EU.  The 
remaining  feedstock  is  consumed  in  other  transport  sectors  such  as  road  transport  and 
aviation.  By  2050,  the  need  for  waste  lipids  to  produce  Part  B  biofuels  for  international 
maritime  increases,  and  as  a  result  the  sector  requires  higher  shares  of  the  available 
feedstock.  Part  A  biofuels  from  lignocellulosic  feedstock  consume  6  to  20%  of  the 
available feedstock potential  in  the EU by 2050, depending on the type  of feedstock  and 
policy option. Manure used for bio-LNG for international maritime increases from around 
2% in 2030 to 5-6% in 2050. 

Table 6 Used potential for the EU maritime sector as % of domestic potential in EU27 

Used potential 

POA 

POB 

POC 

(% of domestic potential in the EU27)  
Part A 

2030 

2050 

2030 

2050 

2030 

2050 

Perennial crops 
Annual crops 
Forestry products 
Forestry residues 
Wood waste 
Agricultural residues 
Manure 

Part B 

0.2% 
0.2% 
2.8% 
2.3% 
1.7% 
1.4% 
2.4% 

10.9% 
10.6% 
15.4% 
15.9% 
6.4% 
16.1% 
5.3% 

0.2% 
0.2% 
2.9% 
2.4% 
1.8% 
1.5% 
2.4% 

13.3% 
12.8% 
19.7% 
20.0% 
7.7% 
19.4% 
6.4% 

0.2% 
0.2% 
2.9% 
2.3% 
1.8% 
1.5% 
2.4% 

11.8% 
11.4% 
16.9% 
17.4% 
6.9% 
17.5% 
5.8% 

Non-agricultural oils 

20.6% 

27.4% 

21.3% 

34.4% 

21.1% 

29.9% 

Source: PRIMES Biomass model, E3Modelling 

In the production of biofuels, biomass feedstock comprises most of the energy demand to 
produce bioenergy commodities. In addition, bioenergy production requires energy inputs 
in  several  steps  in  the  production  process,  from  biomass  cultivation  or  collection,  to 
transport,  and  conversion  of  biomass  to  bioenergy.  Based  on  insights  from  PRIMES 
Biomass,  the  production  of  all  bioenergy  commodities  projected  in  the  context  of  the 
transition towards a climate neutral economy, requires about 36 Mtoe of electricity, liquid 
fuels  and gas in  2050. This  corresponds  to  less than 3% of the overall energy supply (of 
electricity,  liquid  fuel  and  gas)  for  the  same  year.  The  contribution  of  international 
maritime fuels, is significantly lower than that, with estimates ranging between 0.3% and 

58 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
0.35%  of  the  overall  energy  supply  for  the  POs.  The  energy  use  in  the  production  of 
biofuels is also reflected in the well to tank emissions in all POs. 

Renewable electricity needs for e-fuels: The electricity to produce e-fuels is projected to 
be the highest in PO1 (almost 2 TWh in 2030 and 246 TWh in 2050). This would represent 
around  0.1%  of  renewable  electricity  generation  in  2030  and  4.7%  by  2050.  In  PO3  the 
electricity to produce e-fuels is projected at around 0.6 TWh in 2030 and 230 by 2050 (i.e. 
less than 0.1% of renewable electricity generation in 2030 and 4.4% in 2050). PO2 shows 
the  lowest  share  of  e-fuels  in  the  energy  mix  and  thus  the  lowest  electricity  needs  to 
produce them (0.1 TWh in 2030 and 198 TWh in 2050). The electricity is primarily used to 
produce synthetic diesel blends and e-gas.  

Table 7 Electricity consumption for producing e-fuels for the maritime sector (in TWh and %) 

Electricity consumption for synthetic fuels 

PO1 

PO2 

PO3 

(TWh and %) 
Electricity consumption, TWh 
Share of gross electricity generation, % 

Share of renewable electricity generation, % 
Source: PRIMES model, E3Modelling 

2030 
1.8 
0.0% 

0.1% 

2050 
246 
2.0% 

4.7% 

2030 
0.1 
0.0% 

0.0% 

2050 
198 
1.6% 

3.8% 

2030 
0.6 
0.0% 

0.0% 

2050 
230 
1.9% 

4.4% 

Uncertainties  underlying  the  analysis:  This  assessment  takes  into  account  the  current 
knowledge  related  to  the  possible  evolution  of  technology  costs  and  feedstock  costs.  If 
higher decrease in the costs of e-fuels would take place than assumed in this assessment, 
their  uptake  could  be  higher  especially  in  PO2  and  PO3  due  to  their  increased 
competitiveness  relative  to  biofuels  and  bio-LNG.  This  consideration  also  applies  to 
alternative propulsion systems like fuel cells and electric vessels). This is because PO2 and 
PO3  provides  flexibility  in  terms  of  choice  of  the  fuel  mix.  On  the  other  hand,  if  the 
availability of biofuels and bio-LNG for the maritime sector would be lower, due to higher 
demand  by  other  sectors,  a  higher  share  of  e-fuels  would  be  needed  to  compensate  for 
achieving the mandates in PO2 and PO3. In case the technology costs and feedstock costs 
would be higher than assumed in this assessment, this may results in higher fuel costs and 
subsequently freight rates. 

6.1.3  Regulatory and administrative costs related to businesses 

Regulatory  and  administrative  costs  have  been  looked  at  for  three  main  stakeholder 
categories  that  are  mostly  affected  by  the  regulatory  obligations  resulting  from  the  POs: 
ship owners and operators, bunker suppliers and ports.  

The  administrative  costs  for  ship  owners  and  operators  will  primarily  consist  of 
monitoring, verification and reporting, determined by additional requirements compared to 
the existing EU MRV Regulation.  In essence, the EU MRV Regulation already  provides 
for  an  extensive  monitoring  of  individual  ships’  CO2  emissions  (fuel  consumption  and 
other parameters, such as distance travelled, time at sea and cargo carried on a per voyage 
basis),  which  are  gathered  annually  into  an  emissions  report  submitted  to  an  accredited 

59 

 
 
 
MRV shipping verifier and reported, through THETIS-MRV, to the Commission and to the 
States in which those ships are registered (the so-called ‘flag States’). 

This  initiative  can  therefore  rely  to  a  large  extent  on  the  already  existing  reporting 
requirements in the EU MRV Regulation. However, given that more emissions and energy 
sources  will  be  included,  additional  information  will  need  to  be  monitored,  reported  and 
verified. The following assessment is based on conservative assumptions. 

Administrative costs for ship owners are estimated on the fact that each vessels will have 
to comply with the following information obligations:  

1.  Annual energy compliance plan: Each vessel has to prepare an annual compliance plan, 
which  describes  which  fuels  and  technologies  the  ship  is  planning  to  use.  This  plan 
builds on the EU MRV Monitoring plan and includes additional emissions as well as 
energy sources. The same conservative assumptions have been used as in the EU MRV 
Impact  Assessment118  for  the  preparation  of  the  entire  Monitoring  plan  (i.e.  40  hours 
per ship over the period of 10 years).  

2.  Annual energy report: The annual energy report is the calculation of the annual energy 
consumption of the vessel, broken down to different energy sources/types of fuel and to 
navigation and berth. This report builds on the EU MRV Emission report, but is more 
extensive  as  well-to-tank,  non-CO2  emissions  and  OPS/electricity  consumption  are 
included  as  well.  The  targeted  survey  asked  about  the  corresponding  administrative 
cost.  8  out  of  9  respondents  indicated  that  for  ship  owners,  the  reporting  time  would 
increase by two hours at most, per voyage. However, it could not be verified to what 
extent the reply already included the existing requirements of EU MRV Regulation (i.e. 
part  of  the  baseline)  or  whether  only  additional  elements  were  included.  It  can  be 
assumed  that  specific  information  on  the  use  of  OPS  is  already  included  in  such 
reporting  (as  they  would,  at  least  partly,  replace  the  fuel  use  currently  reported  at 
berth), based on information supplied by the electricity supplier (i.e. electricity bills). 
Similarly for the use of THETIS-MRV system: ship owners and operators are already 
using it and thus, it will only incur incremental familiarisation cost. 

3.  Proof of compliance: Each ship has to carry a document of compliance and cooperate 
during  PSC  inspections.  The  first  requirement  will  not  impose  any  additional 
administrative costs, as the document is supplied by the verifier, and thus only has to 
be  carried  on  board.  The  only  action  during  PSC  is  to  retrieve  the  document  of 
compliance and show it to the inspector. The additional administrative costs of this will 
be a maximum of 15 minutes per inspected ship.  

4.  The  administrative  costs  incurred  by  operators  will  also  cover  the  training  needs  to 
ensure the safe switch to RLF on-board ships. Furthermore it is assumed that training 

118 DG CLIMA, MOVE (2013) – Impact assessment part 2 Accompanying the document Proposal for a Regulation of the 
European Parliament and of the Council on the monitoring, reporting and verification of carbon dioxide emissions from 
maritime transport and amending Regulation (EU) N° 525/2013 

60 

 
 
                                                           
for  alternative  fuels  will  become  standard  in  training  programs  for  new  seafarers  in 
2035. This means that only the ships which switch to RLF before 2035 would need to 
invest in additional training. 

Administrative  cost  for  bunker  suppliers  will  primarily  consist  of  certification  of  fuel 
and upstream emissions/sustainability criteria. The certification requirements will build on 
existing provisions  and sustainability  criteria in  the RED  II.  Fuel  producers already have 
experience  with  certification  of  biofuels  under  RED.  When  a  new  (bio)fuel  needs  to  be 
certified, for instance under the International Sustainability & Carbon Certification Scheme 
(ISCC),  the  entire  supply  chain  has  to  be  certified119.  Certification  schemes  mostly  have 
one-time  registration  fees  that  vary  between  €50  and  €500,  so  these  are  one-off  costs. 
Annual fees per certificate vary from €50 to €500 as well. Finally, fees have to be paid per 
quantity of material declared as sustainable. These fees range between €0.03 and €0.10 per 
metric ton. The costs of an external audit can range from €800 to €2,000 per day. It has not 
been possible to estimate how many certification schemes would be established or what the 
exact impact of certifying upstream emissions would be (several fuel producers have been 
interviewed, but none were able to make an estimate of the effort needed for certification). 
However,  based  on  the  illustrative  costs  listed  above,  it  can  be  assumed  that  the  overall 
certification costs will not have significant impact on the price of alternative fuels.  

Administrative costs for ports are more modest and relate to the publication of guidelines 
and the revision of ports regulations to cover the safe handling, bunkering and use of RLF. 
It is expected that around one third of EU ports will be affected by a significant increase in 
new safety guidelines.  

Table 8 presents an overview of these costs for the entire period 2021-2050, expressed as 
present value. More details on the assumptions used for calculating the costs are provided 
in Annex 4. 

Table 8 Total costs relative to the baseline, expressed as present value for the period 2021-2050 

Administrative costs - present value for 2021-2050 compared to 
Baseline (million €'2015) 

Administrative costs of ship owners  

Prepare and submit annual energy compliance plan  
Collecting additional information (per voyage)  
Cooperate during PSC inspection  
Crew training  

Administrative costs for port authorities  

Set up guidelines in ports  

Source: Ecorys / CE Delft forthcoming, and own calculations 

PO1 

439.0 
32.8 
335.3 
1.0 
69.8 
1.8 
1.8 

PO2 

439.4 
32.8 
335.3 
1.0 
70.2 
1.8 
1.8 

PO3 

439.7 
32.8 
335.3 
1.0 
70.5 
1.8 
1.8 

119 This means that either all suppliers and other stakeholders need to cooperate in the certification, or are already ISCC 
certified themselves. 

61 

 
 
 
                                                           
6.1.4  Enforcement costs  

Similarly  to  the  EU  MRV,  third-party  verifiers  will  verify  the  documents  supplied  by 
operators to check compliance. As the information requirements are based on the ones used 
for the EU MRV Regulation (including in terms of timing and expected  IT system), it is 
reasonable  to  expect  that  the  same  entity  will  be  tasked  by  the  ship  owners  to  verify 
compliance  with  both  regulations.  The  new  tasks  for  the  verifiers  will  be  to  verify  the 
additional elements contained in the annual energy compliance plan and the annual energy 
report, to establish compliance with the required RLF use. 

During  the  targeted  consultation,  the  verifiers  assumed  that  several  hours  are  needed  for 
the necessary verification per single ship on an annual basis and indicated in an interview 
that if the EU has a regulatory requirement that needs to be verified, the verifiers will step 
up to meet the challenge.  

As  the  reporting  and  verification  system  is  similar  in  all  options,  the  additional  costs 
relative  to  the  baseline  are  the  same  in  all  options.  They  are  based  on  the  conservative 
assumption that 5 hours would be need to verify the additional elements in both the annual 
energy  report  as  well  as  the  energy  compliance  plan.120  Ensuring  that  a  ship  has  met  its 
obligations  before  issuing  a  Document  of  Compliance  is  an  important  element  of  the 
intervention to  ensure that  non-compliance do not  get a  competitive advantage from fuel 
costs savings.  

On the side of the public administrations, a PSC officer will have to determine whether the 
Document of Compliance is on board (similar assumption as above is made of 15 minutes 
per  inspection,  which  is  the  upper  bound  based  on  a  conservative  assumption  that  each 
vessel  under  EU  MRV  Regulation  is  inspected  every  year).  At  the  same  time,  it  is 
proposed to  allow for the use of  electronic certificates, which  can remove the need for  a 
physical check in its entirety.  

Furthermore, additional one-off cost for adapting the EU MRV IT system (THETIS-MRV) 
should be foreseen for the EU budget to accommodate the additional information as well as 
additional  functionalities  related  to  the  RLF  obligations.  In  addition,  a  new  module  in 
THETIS-EU should support PSC officers as well as EU flag state inspectors in their work. 
Based on the cost of THETIS-MRV121 and experience with existing THETIS-EU modules 
supporting various pieces  of EU legislation, such  IT-developments  costs  are  estimated at 
€300,000.  PO3  would  need  an  additional  tool  to  support  the  tool  to  trace  and,  whenever 
necessary, balance over- or under-compliance. This tool is estimated to cost €200,000. 

120 According to the IA on the revision of the EU MRV Regulation, p. 51 (overview of administrative burden), 
verification costs turned out to be significantly lower than estimated in the 2013 EU MRV impact assessment: 
https://ec.europa.eu/clima/sites/clima/files/transport/shipping/docs/swd_2019_10_en.pdf  
121 Source: EMSA 2020 

62 

 
 
                                                           
Table 9 summarises all enforcement costs relative to the baseline for the period 2021-2050, 
expressed as present value. More details on the assumptions used for calculating the costs 
are provided in Annex 4. 

Table 9 Summary of the enforcement costs for the period 2021-2050 

Administrative costs - present value for 2021-2050 compared 
to Baseline (million €'2015) 
Total enforcement costs   

Verify annual emissions report 
Approve annual compliance plan 
Additional time during audits/inspections 
Adaptation to the IT system 

Source: Ecorys / CE Delft forthcoming, EMSA 2020, and own calculations 

PO1 

83.3 
41.0 
41.0 
1.0 
0.3 

PO2 

83.3 
41.0 
41.0 
1.0 
0.3 

PO3 

83.5 
41.0 
41.0 
1.0 
0.5 

6.1.5 

Impact on ports to provide the necessary infrastructure 

The uptake of alternative maritime fuels in maritime transport will require several actions 
from ports. The impact  of the proposed intervention will depend on the type of technical 
solutions adopted. Indeed, drop-in fuels can, to a very large extent, rely on existing fuel oil 
infrastructure  (for  liquid  drop-in  fuels)  or  LNG  bunkering  (for  the  gaseous  fuels).  Fuels 
like  methanol,  hydrogen  and  ammonia  would  require  various  degrees  of  adaptation  / 
modification of the bunkering facilities or even new infrastructure. The provision of OPS 
also  requires  the  installation  of  appropriate  connection  points  at  berth,  port  level 
substation(s) and high-voltage electricity supply infrastructure. 

The investments required by ports are likely to be distributed over time in all POs in such a 
way that they would first target the installation of OPS infrastructure (required as of 2030 
in  all  POs  for  certain  ship  types)  and  then  gradually  accompany  the  deployment  of 
hydrogen,  ammonia  and  methanol.  While  the  provision  of  OPS  is  covered  by  AFID,  the 
current  uptake  of  this  solution  remains  very  limited  in  European  ports.  However,  on  this 
particular point the three POs will not differentiate as the requirements at berth are defined 
in  the same manner for  all options. Overall, it can be expected that PO1 will lead to  the 
highest levels of ports investments given the higher penetration of non-drop-in RLF in the 
overall energy mix. It will be followed respectively by PO3 and PO2.  

The level of ports investments are likely not to be uniform across all ports but to depend 
largely  on  the  size  of  the  port,  the  type  of  traffic  that  it  usually  accommodates  and  to  a 
lesser extent the port layout and the need for connection to the grid122. In other words, the 
infrastructure needs of a large transhipment port are likely to be different from those of a 
port  of  a  smaller  size  mostly  used  for  passengers  or  those  of  a  cruise  ship  terminal.  It  is 
also worth noting that the bunkering offer can be an element of competition among ports. 
As for the likelihood to invest in RLF bunkering infrastructure, it can be assumed that the 
largest 25 freight ports will invest in multiple types of alternative fuels due to willingness 

122 https://sustainableworldports.org/ops/costs/investments/  

63 

 
 
 
                                                           
and financial possibilities to invest. It is also expected that the largest passenger ports will 
invest to facilitate cruise and ferry traffic.  

Another  aspect  adding  to  complexity  concerns  the  fact  that  the  costs  of  infrastructure 
investment are highly port specific and depend on a series of local conditions (e.g. the port 
layout  mentioned  above).  Identifying  an  average  or  typical  investment  cost  for  a  given 
infrastructure  is  therefore  not  possible.  Instead,  an  indicative  range  of  the  required 
investments  has  been  identified  based  on  a  review  of  past  investments  projects  and  case 
studies of RLF investment by ports. However, the size of the identified range is significant. 
Investments  in  a  hydrogen  infrastructure  are  valued  between  €35  million  to  more  than 
€100 million123. The cost of onshore power supply installation varies between €1 and €25 
million (dependent on the size and complexity)124.  

Based on the above, and considering the high range of installation costs for hydrogen and 
power demand estimations by EMSA for the OPS, the total investments in alternative fuels 
infrastructure  over  the  period  2025-2050  would  be  €9.9bn  (€2.5bn  for  hydrogen 
infrastructure and €7.4bn for OPS). This is equivalent to additional capital costs relative to 
the baseline estimated at €5.7bn, expressed as present value over 2021-2050 horizon. This 
figure is based on the assumption that the installation of the infrastructure in the EU will 
focus on the 25 large ports for hydrogen and the TEN-T core and comprehensive ports for 
OPS. This estimate is considered to be indicative of the scale of investments that will be 
needed,  considering  the  challenges  linked  to  the  number  and  complexity  of  the  factors 
impacting these types of investments. This cost is the same for all POs. 

6.1.6 

Impact on innovation 

All  POs  are  expected  to  have  a  positive  impact  on  innovation  as  they  will  foster  the 
deployment of more advanced technologies (including to  improve energy efficiency)  and 
fuel  solutions.  Compared  to  the  use  of  drop-in  fuels  in  conventional  internal  combustion 
engines,  the  deployment  of  fuel  cells  and  electric  propulsion  represent  arguably  the 
solutions  requiring the highest  innovation  efforts, in  particular with  a view to  scale them 
for  use  in  longer  distances  and,  potentially,  deep-sea  shipping.  Table  10  presents,  as  a 
proxy, an indication of the penetration of fuel cell-powered ships and electric ships in the 
overall vessel stock for all POs by 2030 and 2050 (compared to the baseline).  

123 Source: North Sea Port (2020), https://en.northseaport.com/volth2-signs-cooperation-agreement-with-north-sea-port-
for-the-development-of-a-green-hydrogen-plant. In the absence of proper reference points for the development of 
infrastructure of hydrogen as marine fuel, this investment bandwidth is estimated on the basis of costs for the deployment 
of hydrogen plants in ports.  
124 Based on the analysis of project submitted  for funding through INEA and referenced with literature, source: 
Greencruiseport (2018) 
http://www.greencruiseport.eu/files/public/download/studies/Opportunities%20and%20Limitations%20for%20Connectin
g%20Cruise%20Vessels%20to%20Shore%20Power_04.01.2018_Bergen.pdf  

64 

 
 
                                                           
Table 10 Stock of fuel cell and electric ships (difference to the baseline and share of the stock) 

Fuel cell and electric ship vessels  

PO1 

PO2 

PO3 

2030 

2050 

2030 

2050 

2030 

2050 

Stock - difference to the Baseline 

fuel cell ships 
electric ships 

Share of the total stock (in %) 

fuel cell ships 
electric ships 

Source: PRIMES-Maritime, E3Modelling 

0 
46 

0.0% 
0.3% 

3,523 
1,251 

19.7% 
7.0% 

0 
7 

0.0% 
0.1% 

2,446 
380 

13.7% 
2.1% 

0 
26 

0.0% 
0.2% 

3,372 
969 

18.9% 
5.4% 

While  all  options  have  a  noticeable  positive  impact  on  the  deployment  of  these 
technologies (and hence on the effective innovation potential to support their deployment), 
PO1  results  in  the  highest  share  of  fuel  cell-powered  ships  (19.7%)  and  electric  ships 
(7.0%)  by  2050,  followed  by  PO3  (18.9%  and  5.4%  respectively)  and  PO2  (13.7%  and 
2.1% respectively). It is interesting to notice that the gap between PO1 and PO3 is much 
lower than with PO2. This is expected to be the result of the application of the mechanism 
for overachievers within the PO3. We can also observe that the innovation push is mainly 
unlocked  after  2030.  This  is  likely  to  result  from  the  combined  effect  of  tightening  the 
GHG limits and the achievement of a sufficient TRL. 

Other aspects that have not been quantified by the modelling activities concern the further 
development  of  internal  combustion  engines,  to  be  able  to  operate  more  frequently  as 
“dual-fuel” engines or to use emerging fuels (such as ammonia) as well as the necessary air 
pollution  abatement-measures  to  further  reduce  ship  emissions.  In  addition,  the 
development  and  deployment  of  energy  efficiency  measures,  including  the  use  of  wind 
assistance, is expected to increase as a means to mitigate the fuel costs increase induced by 
the proposed intervention. 

As also highlighted in Section 6.2.1, all POs under consideration are also expected to have 
a  positive  impact  on  employment  levels  in  R&I  related  to  the  provision  of  marine  RLF. 
This  is  also  explained  by  the  increased  share  of  hydrogen,  hydrogen-based  fuels  and  e-
fuels.  

6.1.7 

Impact on the competitiveness of other parts of the EU maritime cluster 

The expected impact on ship operators has already been presented in Section 6.1.1 and on 
ports in Section 6.1.5. This section focuses on the possible changes to the competitiveness 
of  a  wider  set  of  actors  composing  the  EU  maritime  cluster,  namely  the  international 
competitiveness  of  the  shipping  industry,  shipbuilding  industry,  the  marine  equipment 
industry,  the  fuel  suppliers  and  bunkering  facilities.  The  impact  on  competitiveness  is 
based a qualitative assessment following consultations and stakeholders interviews. 

Table 11 Expected impacts on competitiveness of the EU maritime cluster 

Stakeholder category 
Shipping industry 
Shipbuilding industry 

PO1 
Small positive 
Small positive 

PO2 
No change 
No change 

PO3 
Small positive 
Small positive 

65 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
 
Stakeholder category 
Marine equipment industry 
Fuel suppliers  
Bunker facilities 

PO1 
Small positive 
Small positive 
No change 

PO2 
No change 
No change 
Negative 

PO3 
Small positive 
Small positive 
Negative 

In  practice,  a  small  positive  improvement  of  the  competitive  position  of  the  shipping 
industry, the shipbuilding industry, the marine equipment industry and the fuel suppliers is 
expected  to  be  seen  in  line  with  the  acceleration  of  the  RLF  uptake  and  in  particular  a 
higher  demand  for  the  most  advanced  solutions  (zero  or  near-zero  propulsion).  This  is 
mainly  resulting  from  the  already  strong  competitive  position  of  the  EU  industry  in  the 
delivery of specialised vessels / solutions. For the bunker facilities the accelerated uptake 
of  RLF  has  negative  consequences  in  particular  with  higher  shares  of  non-drop-in  fuels 
which will require dedicated infrastructure. 

6.1.8 

Impact on third countries 

Three  main  aspects  can  be  relevant  when  considering  the  impact  that  a  measure 
incentivising the uptake of RLF can have on third countries. These concern: impact on fuel 
production  and  distribution,  impact  on  shipbuilding,  and  impact  of  trades  with  third 
countries. However, these impacts are not easily quantifiable. As a result, this section will 
focus on identifying the most relevant aspects and trends.   

Concerning  fuel  production  and  distribution,  all  policy  measures  will  incentivize  the 
production of  RLF, which will have to be made available to  the sector. Given the global 
nature  of  maritime  transport,  there  is  an  interest  in  the  widest  possible  distribution  and 
availability of RLF. In order to prevent fuel shortage, all POs have been modelled so that 
they could be sustained by production in EU countries. However, bunkering of RLF is also 
allowed  in  third  countries  that  comply  with  the  certification  requirements.  While  the 
production of conventional bunker fuels was mainly focussed in Asia, followed by Europe 
and  the  Middle-East125,  the  production  of  RLF  does  not  necessarily  have  to  emerge  in 
countries that currently produce conventional fossil bunker fuels. Since different feedstock 
and  input  factors  are  required,  this  could  open  possibilities  for  new  market  actors  to 
emerge.  Countries  with  favourable  conditions  for  the  production  of  renewable  electricity 
could  be  attractive  production  locations  for  e-fuels126.  In  addition,  the  largest  bunkering 
hubs outside Europe such as Singapore, Fujairah, Hong Kong, Busan, and Panama could 
also be impacted and may start offering higher quantities of RLF to their customers.  

As  mentioned  in  Section  6.1.7,  the  impact  on  shipbuilding  will  vary  among  the  POs  in 
line with the increased uptake of more advanced and innovative solutions. However, even 
in the case of drop-in fuels the proposed intervention could have an effect on increasing the 
demand  for  energy-efficient  new-built  vessels  (as  a  way  to  mitigate  the  expect  fuel  cost 
increase)  and  boost  the  deployment  of  advanced  energy  efficiency  solutions  for  the 

125 https://www.cedelft.eu/publicatie/assessment_of_fuel_oil_availability/1858  
126 See for example, Ricardo Energy & Environment (2019), Electrofuels for shipping: How synthetic fuels from 
renewable electricity could unlock sustainable investment in countries like Chile  

66 

 
 
 
                                                           
existing  fleet.  The  most  important  shipbuilding  nations  outside  Europe  are  China,  Japan 
and the Republic of Korea.  

The increase in fuel cost induced by the three POs may also have an impact on trade with 
third countries. This would depend on the type of cost increases for ship operators. Table 
12 provides an indication for each PO compared to the baseline.  

Table 12 Percentage of costs increase for ship operators compared to the baseline in 2030 and 2050 

Costs for ship operators (% change 
compared to Baseline) 

Capital costs 
Fuel costs  
Operation costs 

Total costs 
Source: PRIMES-Maritime, E3Modelling 

Baseline (bil. 
€'2015) 

PO1 

PO2 

PO3 

2030 

22.6 
32.0 
13.3 
67.8 

2050 

36.0 
50.6 
16.8 
103.3 

2030 

2050 

2030 

2050 

4.1% 
3.2% 
-0.3% 
2.8% 

13.3% 
26.7% 
-2.6% 
17.3% 

3.8% 
2.9% 
-0.3% 
2.6% 

11.3% 
28.1% 
-2.4% 
17.3% 

2030 

3.9% 
3.0% 
-0.3% 
2.7% 

2050 

13.0% 
27.2% 
-2.5% 
17.4% 

In effect, the fuel costs increase for 2030 vary between 2.9% and 3.2% and between 26.7% 
and 28.1% in 2050. The impact on the total cost of operators remains around 17% by 2050 
in all POs. The cost increase compared to the baseline remains limited in the first years of 
the policy intervention to gradually increase over time. The impact of the POs on EU trade 
with  third  countries  is  therefore  likely  to  remain  limited.  Section  6.2.2  looks  in  greater 
details at the potential impact of the POs on freight rates. 

6.2  Social impacts 

The social impacts have been analysed through three main aspects: the impact on jobs in 
the  different  parts  of  the  EU  maritime  sector,  the  impact  on  freight  rates  (as  a  proxy  for 
costs related to maritime transport services) as well as the issue of connectivity of remote 
islands and peripheral maritime regions, and last but not least the health benefits.  

6.2.1 

Impact on jobs in the different parts of the EU maritime cluster 

Two  types  of  impacts  can  be  distinguished  on  jobs:  the  direct  impact  on  employment, 
measured  in  number  of  jobs,  reflecting  potential  job  creation  /  losses,  and  the  indirect 
impact,  related  to  changes  of  skills  and  knowledge  of  employees.  These  impacts  are 
expected to differ depending on the technology choices that will be made for compliance. 
Differences  among  the  POs  will  therefore  result  from  the  variation  in  the  expected 
penetration levels  of the different  fuels  in  each  option.  Table 13 presents an overview of 
the impact on employment per technology.  

Table 13 Assumed impacts per technology on employment levels 

Stakeholder 
category 
Seafarers 

Bunker 
suppliers 

Biofuels 

Electro-liquids 

Hydrogen 

OPS 

No change in manning 
levels 
No change in 
employment levels 

No change in manning 
levels 
Possible increase 
depending on size / 
type / efficiency of 
facility 

No change in manning 
levels 
Possible increase 
depending on size / 
type / efficiency of 
facility 

No change in manning 
levels 
Possible increase 
depending on size / 
type / automation level 
/ efficiency of facility 

67 

 
 
 
Biofuels 

Stakeholder 
category 
Equipment 
suppliers 
Ship 
construction and 
repair 
Research and 
development 
Source: Ecorys / CE Delft forthcoming  

No change in 
employment levels 
No change in 
employment levels 

No change in 
employment levels 

Electro-liquids 

Hydrogen 

OPS 

Possible increase in 
initial stages 
Depends on demand 

Possible increase in 
initial stages 
Depends on demand 

No change in 
employment levels 
Depends on demand 

Possible increase in 
initial stages 

Possible increase in 
initial stages 

No change in 
employment levels 

While direct impacts on any of the options may be limited in certain cases (e.g. manning 
levels  on-board  vessels),  the  training  needs  arising  from  the  growing  penetration  of 
alternative  fuels  is  a  common  factor  for  all  the  POs  and  for  all  segments  of  the  EU 
maritime  sector.  The  need  to  upgrade  skills  will  result  in  potentially  significant 
investments  in  training  and  certification  of  seafarers  (see  also  Section  6.1.3.  for  the 
assessment  of  training  costs),  as  these  are  not  included  in  current  training  and  education 
programmes nor required by existing regulations (e.g. STCW Convention). However, this 
evolution  is  also  a  potential  benefit,  as  it  is  likely  to  increase  the  competitiveness  of 
European employees in the global market, and improve the image of the sector and inspire 
more people (young people as well as women) to opt for a maritime career. 

Table 14 presents the overview of the qualitative assessment of the expected employment 
impact of the POs.  

Table 14 Expected impacts of the policy options on employment 

Stakeholder category 

PO1 

Seafarers 

Bunker suppliers 

Equipment suppliers 

Small positive 

Small positive 

PO2 

Small positive 

Small positive 

PO3 

Small positive 

Small positive 

Medium positive 

Medium positive 

Medium positive 

Ship construction & repair 

Medium positive 

Small positive 

Medium positive 

Research and development 

High positive 

High positive 

High positive 

Source: Ecorys / CE Delft forthcoming Note: All impacts are presented against today’s situation. 

In practice, the employment impact is expected to be marginally positive for the seafarers. 
Equipment  suppliers  and  ship  construction  and  repair  should  see  more  positive  impacts 
reflecting  an  expected  increase  in  investments,  and  changes  in  the  fleet,  equipment,  and 
facilities.  For  the  bunkering  sector,  the  job  growth  may  be  more  restrained  as  potential 
increases  in  the  new  facilities  may  be  counterbalanced  by  losses  in  “older”  forms  of 
bunkering. Finally, R&D employment should see a clear increase in all options. 

6.2.2 

Impact on freight rates and connectivity of remote islands and peripheral regions 

The impact on freight rates of the proposed intervention could be used as a determinant of 
the potential impact on final consumer prices, bearing in mind that maritime transport is an 
essential  vector  of  EU  trade  (75%  of  all  EU  external  trade  in  volume  and  31%  of  EU 
internal trade). By extension the impact on freight rates will be used as an indicator of the 
potential  impact  of  the  measure  on  the  connectivity  of  remote  islands  and  peripheral 

68 

 
 
 
regions.  However,  it  is  difficult  to  directly  relate  freight  rates  to  consumer  prices. 
Historical data showed a decline of the cost of maritime transport in the transport of certain 
commodities, while over the same period freight rates were not following the same trend. 

Drawing conclusions on the impacts of fuel prices on freight rates is also complex, due to 
the  diversity  of  the  maritime  sector.  The  proportion  of  fuel  costs  in  the  operating  costs 
differ indeed from one  market  segment to  another. For instance, while bunker costs may 
account for around 35% of the freight rate of a small tanker, this proportion is much higher 
(53%) for container/bulk vessels. The type of traffic can also influence the importance of 
fuel price fluctuation. Generally, the share of bunker cost is lower for deep sea shipping, 
compared to short sea shipping. This results in important differences on the impact of fuel 
prices on freight rates among different sectors. While the general freight index oil shows a 
strong correlation with the price of marine diesel, freight rates in the dry bulk sector (Baltic 
Dry  Index)  are  decoupled  from  bunker  prices  and  mainly  influenced  by  the  demand  and 
supply of raw materials, fleet composition and demand and supply of ships. 

Nevertheless,  based  on  the  existing  literature127  on  the  relation  between  fuel  prices  and 
freight rates, the impacts on the freight rates have been estimated for 2030 and 2050 and 
are  provided  in  Table  15.  Drawing  on  the  modelling  exercise  performed  with  PRIMES-
Maritime model, the increase in  the price of ‘diesel  blend’ is  estimated at  around 7% by 
2030  relative  to  the  baseline  and  at  42%  by  2050  in  all  POs.  The  ‘diesel  blend’  covers 
diesel blended with biodiesel, e-fuels, hydrogen, ammonia and methanol. This is relevant 
in  all  POs,  because  the  blended  diesel  which  would  be  mostly  decarbonised  by  2050  is 
projected to represent around 51% of the fuel mix used in short sea shipping by 2030 and 
36% by 2050.  

Table 15 Possible impacts of the projected ‘diesel blend’ price increase on freight rates 

Segment  
General 
Containers 
Dry bulk 

Freight rate elasticity 
0.018-0.36 
0.11-0.36 
0.28 

2030 
0.1%-2.5% 
0.8%-2.5% 
2.0% 

2050 
0.8%-15.1% 
4.6%-15.1% 
11.8% 

Source: own calculations based on Ecorys (forthcoming) and PRIMES-Maritime 

As the impact of the proposed intervention remains limited on freight rates, and given the 
low share of transport costs on final  consumer prices, the intervention  is not  expected to 
lead to any significant on commodity, product and raw material prices. 

6.2.3  Public health  

All POs are estimated to have a positive impact on public health due to the decrease in air 
pollution.  For  instance,  by  2050,  in  all  POs  NOx  and  PM10  emissions  associated  to 

127 UNCTAD (2010). Oil Prices and Maritime Freight Rates: An Empirical Investigation., OECD (2008) 
Clarifying Trade Costs in Maritime Transport, Hummels(2007) Transportation costs and international trade 
in the second era of globalization, Mirza and Zitouna (2009) Oil prices, geography and endogenous 
regionalism – all within the range provided. 

69 

 
 
 
                                                           
maritime transport are projected to decrease by 24-27% relative to the baseline (with small 
differences  among  POs  as  shown  in  Section  6.3).  These  decreases  are  driven  by  the 
reduction in transport activity relative to the baseline, the uptake of zero-emission vessels 
and the uptake of on-shore supply. The POs would results in €9.4 to 10.3bn savings in the 
external costs of air pollution relative to the baseline128, expressed as present value over the 
2021-2050 period.  

Table 16 External costs savings on air pollution 

External costs - present value for 2021-2050 
compared to Baseline (bil. €'2015) 

External costs of air pollution 
Source: PRIMES-Maritime 

Baseline (bil. 
€'2015) 

124 

PO1 

-10.3 

PO2 

-9.4 

PO3 

-10.0 

Savings happening as the result of the use of cleaner energy sources at berth, in particular 
OPS,  are  particularly  important  as  they  would  contribute  reducing  the  air  pollution 
pressure on ports and port cities.  

6.3  Environmental impacts 

The  environmental  impacts  have  been  assessed  in  terms  of  fossil  fuel  savings  and  GHG 
emissions reductions, as  well as impacts on air quality. An analysis of the risk of carbon 
leakage and the possible traffic diversion resulting from the proposed intervention is also 
provided in this section.  

6.3.1  Fossil fuels savings  

All  POs  achieve  significant  fossil  fuel  savings  relative  to  the  baseline,  estimated  to  be 
around  13%  by  2030  and  89  to  91%  by  2050.  The  share  is  slightly  higher  for  passenger 
ships  and  short  sea  shipping  than  for  deep-sea  shipping.  This  is  in  line  with  previous 
conclusions concerning the frequency of the journeys within the scope of the proposal. Oil 
products and fossil LNG are gradually replaced over time with renewable and low-carbon 
liquid and gaseous fuels. This also reduces the EU fossil fuel dependency.   

Table 17 Fossil fuel savings in the policy options relative to the baseline 

Fossil fuel use in maritime (% 
change to Baseline) 
Total shipping 
oil products 
LNG 

Baseline (ktoe) 
2050 
2030 
55,675 
45,793 
45,135 
43,597 
10,540 
2,196 

PO1 

PO2 

PO3 

2030 
-13.2% 
-12.3% 
-30.1% 

2050 
-88.6% 
-88.9% 
-87.1% 

2030 
-13.1% 
-12.2% 
-30.1% 

2050 
-90.7% 
-91.7% 
-86.2% 

2030 
-13.1% 
-12.2% 
-30.1% 

2050 
-90.2% 
-91.0% 
-86.9% 

Source: PRIMES-Maritime, E3Modelling 

6.3.2 

Impacts on GHG emissions and air quality 

Impacts  on  GHG  emissions:  As  the  policy  intervention  requires  to  improve  the  GHG 
performance of the energy used on-board of the ship the GHG emissions are also expected 
to  be  reduced,  both  as  a  result  of  the  use  of  RLF  and  the  slight  changes  in  the  transport 

128 To monetise the costs, the CE Delft (2019) Handbook on the external costs of transport, has been used. 

70 

 
 
 
 
                                                           
activity  as  described  in  Section  6.1.1.  Table  18  presents  the  evolution  of  maritime  GHG 
emission  both  on  tank-to-wake  (consumption)  and  well-to-wake  (including  upstream 
emissions related to fuel production, transport, etc.) basis. On a well-to-wake approach, the 
highest savings are shown in PO3, followed by PO1 and PO2. The levels of CH4 emissions 
are  increasing  by  2050  relative  to  the  baseline,  as  a  result  of  a  larger  uptake  of 
decarbonised gaseous fuels; this outcome is due to the fact that no significant progress on 
methane  slip  control  is  assumed  in  the POs.  However,  this  increase  is  lower  in  PO1  and 
PO3, which generally see a higher penetration of hydrogen-based fuels (e-fuels, hydrogen, 
methanol and ammonia) as well as electricity. 

Table 18 Evolution of GHG emissions from maritime transport on a tank-to-wake and well-to-wake basis 

Maritime transport GHG 
emissions  
(% change to Baseline) 

Tank to wake GHG emissions 

CO2 emissions 
CH4 from slippage 
N2O from slippage 

Well to wake GHG emissions 
Source: PRIMES-Maritime, E3Modelling 

Baseline 
(kt CO2-eq) 

PO1 

PO2 

PO3 

2030 

2050 

2030 

2050 

2030 

2050 

2030 

2050 

144,474 
144,363 
96 
16 
166,662 

169,166 
168,708 
440 
18 
199,015 

-12.9% 
-12.9% 
-6.2% 
-6.3% 
-11.1% 

-88.4% 
-88.6% 
7.5% 
-23.3% 
-77.3% 

-12.8% 
-12.8% 
-6.2% 
-6.2% 
-11.0% 

-90.6% 
-90.9% 
14.9% 
-19.9% 
-76.8% 

-12.9% 
-12.9% 
-6.2% 
-6.2% 
-11.1% 

-90.1% 
-90.4% 
9.5% 
-22.7% 
-78.0% 

In  terms  of  tank-to-wake,  CO2  emissions  from  international  maritime  are  projected  to  be 
81%  to  84%  lower  relative  to  1990  in  the  POs.  This  is  consistent  with  the  climate 
neutrality objective for 2050 as explained in Section 1.5. 

All POs result in significant reductions in the GHG emissions intensity of fuels relative to 
the baseline, as shown in Table 19, estimated at around 6% on well to wake basis for 2030 
and 73-74% for 2050. Relative to the current period this is equivalent to 7% reduction by 
2030 and 74-75% by 2050.129 

Table 19 Evolution of GHG intensity of fuels from maritime transport on a tank-to-wake and well-to-wake basis 

Maritime transport GHG 
intensity of fuels (% change 
to Baseline) 

Tank to wake GHG intensity 
Well to wake GHG intensity 

Baseline (gCO2eq/MJ) 

PO1 

PO2 

PO3 

2030 
75 
87 

2050 
72 
84 

2030 
-8% 
-6% 

2050 
-86% 
-73% 

2030 
-8% 
-6% 

2050 
-89% 
-73% 

2030 
-8% 
-6% 

2050 
-89% 
-74% 

Source: PRIMES-Maritime, E3Modelling 

Impacts  on  air  pollutant  emissions:  The  analysis  of  impacts  on  air  pollutants  covers 
impacts  on  nitrogen oxide (NOx),  carbon monoxide (CO), non-methane volatile organic 
compounds (NMVOCs), sulphur oxide (SOx) emissions and PM10. Air pollution emissions 
are  reduced  in  all  POs  relative  to  the  baseline,  including  air  pollution  at  berth,  with  the 

129 The GHG intensity of fuels shown here are based on the actual GHG emissions and energy use, without accounting 
for multipliers in PO3 to provide incentives for the zero-emission technologies. These incentives are discussed in Annex 
4.  

71 

 
 
                                                           
widening of the use of OPS (or equivalent technologies) by the most polluting fleet. The 
highest reduction are expected in NOx, SOx and PM10, which in all POs reach 23%-27% 
reduction in 2050 as compared to the baseline. The reduction in levels of air pollutants will 
be  higher  for  passenger  ships  than  for  freight  ships  (34%-39%  for  NOx,  SOx  and  PM), 
however this is also due to slightly higher decrease of passenger traffic activity compared 
to the baseline as a result of the policy intervention. The impact of the reduction through 
the  use  of  OPS  (or  equivalent)  is  not  homogenously  distributed  and  will  be  localised, 
depending on the volume and type of traffic for each port. Thus port-cities and the adjacent 
areas are those with a direct benefit.  

Table 20 Evolution of air pollutant emissions from maritime transport 

Air pollution emissions (% 
change to Baseline) 
Total shipping  

NOx 
CO 
NMVOC 
PM10 
SOx 

Source: PRIMES-Maritime, E3Modelling 

Baseline (kt) 

PO1 

PO2 

PO3 

2030 

2050 

2030 

2050 

2030 

2050 

2030 

2050 

1,574 
164 
62 
74 
302 

1,664 
236 
74 
64 
249 

-6% 
-6% 
-6% 
-6% 
-6% 

-27% 
-16% 
-22% 
-27% 
-27% 

-6% 
-6% 
-6% 
-6% 
-5% 

-24% 
-11% 
-19% 
-24% 
-23% 

-6% 
-6% 
-6% 
-6% 
-6% 

-27% 
-15% 
-22% 
-27% 
-26% 

Impacts  on  external  costs:  Based  on  the  GHG  emissions  and  the  reduction  in  the  air 
pollutant emissions presented above, Table 21 presents the savings in external costs of air 
pollution and climate change relative to the baseline130, expressed as present value over the 
2021-2050 period. These have been monetised using the Handbook on the external costs of 
transport. As already explained in Section 6.2.3, the initiative would result in a reduction of 
external costs of air pollution of €9.4 to 10.3bn relative to the baseline. The reduction in 
external costs of GHG emissions is projected to be more significant at €135.9 to 138.6bn 
relative to the baseline over the 2021-2050 period, expressed as present value.   

Table 21 Changes in external costs of air pollution and climate change relative to the baseline, expressed as present 
value over the 2021-2050 period 

External costs - present value for 2021-2050 
compared to Baseline (bil. €'2015) 

Baseline (bil. 
€'2015) 

PO1 

PO2 

PO3 

External costs of air pollution 
External costs of GHG emissions 

Total external costs 
Source: PRIMES-Maritime, E3Modelling 

6.3.3  Carbon leakage 

124 
363 
487 

-10.3 
-135.9 
-146.2 

-9.4 
-138.5 
-148.0 

-10.0 
-138.6 
-148.6 

In  the  absence  of  any  fuel  requirement  imposed  on  maritime  operators,  ship  would 
continue use of conventional fuels. In the event that conventional fuels were not available 
in the EU, ships would bunker them in non-EU ports during one of their regular calls. In 

130 CE Delft (2019) Handbook on the external costs of transport. 

72 

 
 
  
  
  
  
  
  
  
  
 
 
                                                           
other words, without obligations on demand, carbon leakage would occur without any need 
for ships to modify their normal activity. 

If obligations are imposed on ships for the  use of (some proportion of) RLF for voyages 
within the scope of the  mandates, ships would have  an interest  in  reducing the length  of 
those voyages. In this case, carbon leakage could still occur, but would require ships to re-
route and alter their normal course of business. 

The potential for ships re-routing to reduce the amount of traffic that falls in scope of the 
initiative  has  been  analysed  for  2030  by  comparing  the  situation  without  re-routing  (i.e. 
direct  link  from  port  A  to  port  B,  where  port  A  is  a  non-EU/EEA  port  and  port  B  is  an 
EU/EEA port) with a situation including an intermediate stop to a non-EU/EEA port (port 
C), closer (or the closest) to the EU/EEA port (port B). The analysis, performed with the 
TRUST model by TRT, takes into account the cost types according to different ship types 
along different  routes,  as illustrated in  Annex 4, as well as the increase in  the fuel  blend 
cost  projected  as  a  result  of  the  initiative.  The  analysis  has  been  performed  for  PO1  and 
PO3 and three categories of ships: container ships, dry bulk ships and liquid bulk ships.  

For container ships, the analysis shows that, for the vast majority of routes, total travel cost 
increases in case of an intermediate stop to a non-EU/EEA port. In PO1 although fuel costs 
in  case  of  a  route  diversion  (i.e.  with  an  intermediate  stop  to  a  non-EU/EEA  port)  are 
projected to be reduced by 1-6% relative to the Baseline in 2030 (i.e. €26,000 to €242,000 
depending  on  the  route  and  ship  type),  travel  time  costs  would  increase  by  4-13%  (i.e. 
€13,300  to  €102,000)  and  costs  at  ports  would  go  up  by  50%  (i.e.  €47,500  to  €137,000 
depending on the ship type). These results suggest that the risk of leakage resulting from 
container ships’ route diversion to reduce the amount of traffic that falls in the scope of the 
initiative  is  low,  due  to  the  increase  in  the  travel  time  costs  and  costs  at  ports  that 
outweighs the reduction in the fuel costs.131 For PO3, the analysis shows similar results as 
PO1, with fuel costs projected to reduce by 1-6% (i.e. €26,000 to €238,600), while travel 
times costs and costs at ports would increase at the same rate as in PO1. This, for example, 
results  in  an  increase  of  total  travel  costs  ranging  from  about  €17,000  for  a  21,000  TEU 
ship  travelling  from  Shanghai  to  North  Europe  (Antwerp,  Rotterdam,  Hamburg)  and 
performing an intermediate stop in Egypt (Port Said) to near €201,000 if the intermediate 
stop is performed in Turkey (Mersin). Similar considerations apply to dry bulk ships and 
liquid bulk ships, as illustrated in Annex 4, showing that the risk of re-routing to reduce the 
amount of traffic that falls in scope of the initiative is low.  

131  It  is  worth  considering  that  container  ships  usually  perform  several  stops  along  the  route  to  load/unload  cargo  and 
therefore the whole journey from the origin port to the destination port would not fall under  the scope of the initiative. 
Container  ships  might  find  convenience  in  relocating  one  of  the  stops  to  the  closest  non-EU/EEA  port  (rather  than 
performing an additional stop). Such a case, however, would limit the leakage only to the final leg of the trip with limited 
impacts on the overall effectiveness of the initiative. 

73 

 
 
                                                           
7.  HOW DO THE OPTIONS COMPARE? 

7.1  Effectiveness 

The  effectiveness  of  the  options  is  examined  against  the  policy  objectives  identified  in 
Sections  4.1 and 4.2. However, as  already indicated in  Section 5.2.1, the three POs have 
been designed to address the key specific objectives  “by design” and to mostly differ on 
their approach to technology developments (SO2).  

As  the  type  of  intervention  in  all  retained  POs  is  of  a  regulatory  nature,  they  are  all 
expected to produce the same results with regards to SO1 (predictability of the regulatory 
environment).  While  it  could  be  argued  that  a  prescriptive  approach  (PO1)  provides  the 
highest possible degree of predictability, the design of the goal-based approaches presented 
(PO2 and PO3) are expected to perform equally well in this respect. This is due to the fact 
that the proposed regulation will clearly identify the performance level to be met as well as 
indicate  how  this  performance  will  be  measured.  Given  the  long  lifetime  of  vessels  (and 
the  fuel’s  distribution  infrastructure),  it  is  important  that  the  framework  sets  a  clear 
pathway and targets towards 2050 to provide a clear signal to allow the market to develop 
and mature.  

SO3  (stimulation  of  production  and  price  gap),  SO4  (demand  signal)  and  SO5  (carbon 
leakage) are equally addressed by all POs through the focus of the proposed intervention 
on  demand-side  requirements.  This  approach  is  designed  to  complement  the  already 
existing regulatory framework (in particular RED II and AFID). By boosting demand for 
certain quantities of RLF, all POs are expected to address the interdependency issue, which 
has been identified as an obstacle to the development of mature ecosystem for marine RLF.  

Concerning  the  issue  of  price  gap  (SO3),  all  POs  are  expected  to  be  equally  effective  in 
tackling it. In PO1, the regulator would give precise indications on the types of fuel to be 
used, which would minimise uncertainty for both demand and supply. This would result in 
a more rapid achievement of critical mass and quicker reduction of the price gap. However, 
PO1  is  also  the  option  that  is  more  rigid  and  less  easily  adaptable  to  changing 
circumstances.  Whenever  technological  advances  or  unexpected  market  developments 
require  it,  the  regulator  would  need  to  modify  the  mandates  and  this  would  require  time 
and difficult negotiations to account for past investments. 

PO2 leaves total flexibility to the operators to decide on the most appropriate RLF options 
to meet the specified targets.  It would therefore draw operators to the most cost-effective 
technologies  for  their  individual  situation,  and  those  better  reflecting  their  strategic 
planning. As this selection process matures, it is expected that the market will reduce the 
number of technologies  further and  reach on a longer term  a more optimal result than in 
PO1.  However,  PO2  is  also  the  scenario  in  which  a  greater  convergence  towards  fewer 
technologies  –  those  initially  cheaper  –  is  likely  to  develop  and,  therefore,  its  ability  to 
reduce the price gap for some of the less mature technologies might be lower.  

74 

 
 
PO3 would combine the flexibility of the goal-based approach in PO2, with the advantages 
of  the  wider  availability  of  technologies  of  PO1  that  results  from  the  incentive  schemes, 
and would appear to be at least as effective as the other two options in reducing the price 
gap of RLF.  

All POs will perform equally well in limiting the risk of carbon leakage (SO5). This is the 
result  of  the  intervention’s  focus  on  the  demand  for  fuels.  Indeed,  given  the  large 
autonomy of ships and the ability to bunker outside the EU, any regulatory approach based 
solely  on  EU  supply  can  easily  be  circumvented  in  the  maritime  sector.  In  the  same 
manner, possible  remaining risks of  carbon leakage (as presented in  6.3.2) will affect all 
POs equally.  

Given the nature of the main market barrier addressed by the initiative, all POs will have a 
positive effect on the development of new RLF technology for the maritime sector (SO2). 
However, their effectiveness in doing so, and in particular in allowing the introduction of 
new technologies (hence reducing the risk of technology lock-in), differ. While the share 
of  RLF  in  the  overall  maritime  fuel  mix  is  the  highest  in  PO2,  it  mainly  results  from  a 
larger  uptake  of  bio-fuels  compared  to  other  technologies  considered  (notably  e-fuels, 
hydrogen and ammonia). This is explained by the fact that economic actors will react to the 
goal-based  target  by  preferring  the  cheapest  and  most  technologically  mature  way  of 
achieving the goal. As PO1 implies a technology choice, it allows to better steer the type of 
technologies  used,  and  hence,  if  selected,  also  to  accelerate  the  development  of  new 
solutions.  

In the projections made in support of this initiative, PO1 is the one delivering the highest 
usage share of hydrogen-based fuels (e-fuels, hydrogen and ammonia) and electricity. This 
will however depend on the ability of the  regulator to  foresee and reflect the technology 
developments well into the future.  

While in practice, PO3 is based on the same principles as PO2, it also includes a specific 
mechanism  to  reward  overachievement,  which  not  only  provides  flexibility  to  the 
economic actors, but also boosts the uptake of the most advanced technology, via a built-in 
multiplier for the use of zero-emission solutions. This is also reflected in the impacts of the 
POs  on  innovation  (see  6.1.6).  In  summary,  when  it  comes  to  technology  development, 
PO1 and PO3 are performing better than PO2 as they are less prone to technology lock-in 
and are also stimulating the uptake of more advanced technology solutions (electricity or 
hydrogen-based fuels). In comparison to PO2, PO3 delivers ca. 5 percentage points more 
in  fuel  cell ships and 3  percentage points in  electric ships. While the capacity  of PO3 to 
foster technology development results directly from  the design of the policy option  itself 
(through the mechanism for overachievers), the capacity of PO1 depends on the agility of 
the regulator to reflect the technical progresses.  

Table 19 summarises the analysis of impact of the three POs in terms of their effectiveness 
to address the SOs.  

75 

 
 
Table 22 Comparison of impact of policy options in terms of the specific objectives (relative to the baseline) 

Specific objectives / compared to baseline 

SO1:  Enhance  predictability  through  the  setting  of  a  clear  regulatory  environment 
concerning the use of alternative fuels in maritime transport 

SO2: Stimulate technology development 

SO3:  Stimulate  production  on  a  larger  scale  of  RLF  with  sufficient  high  technology 
readiness level (TRLs) and reduce the price gap with current fuels and technologies 

PO1  PO2  PO3 

+++ 

+++ 

+++ 

++ 

++ 

+ 

++ 

++ 

++ 

SO4: Create demand from ship operators to bunker alternative fuels with a sufficient 
high TRL or connect to the electric grid while at berth. 

+++ 

+++ 

+++ 

SO5: Avoid carbon leakage 

+++ 

+++ 

+++ 

7.2  Efficiency 

The  combined  measures  under  the  three  POs  have  economic,  social  and  environmental 
impacts.  The  net  benefits  for  all  three  options  is  positive,  with  the  highest  net  benefits 
shown by PO2 (€61.9bn) and PO3 (€55.0bn).  

Table 23 Costs and benefits of the policy options relative to the baseline over the full scope of the policy intervention 
(2021-2050), expressed as present value 

Costs and benefits - present value for 2021-
2050 compared to Baseline (bil. €'2015) 

PO1 

PO2 

PO3 

Costs 

Capital costs 

of which for OPS on vessels 
of which for ports 

Fuel costs  
Operation costs 
Administrative costs of ship owners  
Administrative costs for port authorities  
Enforcement costs   

Total costs  

Benefits 

External costs savings of air pollution 
External costs savings of GHG emissions  

Total benefits 

32.6 
2.5 
5.7 
69.1 
-2.4 
0.4 
0.0 
0.1 
99.8 

10.3 
135.9 
146.2 

Net benefits 
Source: PRIMES-TREMOVE, E3Modelling and Ecorys / CE Delft forthcoming  

46.4 

28.6 
2.6 
5.7 
59.1 
-2.2 
0.4 
0.0 
0.1 
86.0 

9.4 
138.5 
147.9 

61.9 

31.5 
2.5 
5.7 
63.9 
-2.3 
0.4 
0.0 
0.1 
93.6 

10.0 
138.6 
148.6 

55.0 

It  is  important  to  keep  in  mind  that  these  calculations  are  made  on  the  basis  of  current 
knowledge  related  to  the  possible  evolution  of  technology  costs  and  feedstock  costs.  As 
explained in section 6.1.2, the costs may turn out to be somewhat different if the evolution 
of the technology costs and feedstock costs proves to be different.  

Benefits  are  very  similar  across  the  three  POs  as  they  have  been  designed  to  provide 
comparable  emissions  reductions  over  time,  in  line  with  the  objectives  of  the  CTP.  As  a 
result,  the  impact  on  capital  costs  and  fuel  costs  are  the  most  important  cost  elements 

76 

 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
 
where the three POs differ. As explained in Section 6.1.1, these differences result from the 
variation in the fuel mix among the three POs. PO2 remains the least expensive option as it 
does  not  contain  any  additional  “constraint”  for  the  operators  than  meeting  the  GHG 
intensity  target.  Operators  are  assumed  to  make  a  rationale  decision  and  focus  on  the 
cheapest  and  most  readily  available  options,  i.e.  biofuels.  In  both  PO1  and  PO3,  the 
introduction  of  specific  mandates  for  more  advanced  fuels  (PO1)  or  the  mechanism  for 
overachievers  (PO3)  result  in  a  more  diverse  fuel  mix  and  a  higher  penetration  of  the 
electricity  and  hydrogen-based  fuels,  that  are  more  expensive  but  potentially  more 
performant technology solutions.  

Because it relies on a technology choice by the regulator, PO1 would be the most sensitive 
to possible mistakes in identifying the potential of certain technologies. Having to respect 
the legal requirements on the fuel mix, market operators would not have the possibility to 
quickly  adapt  their  fuel  choices  to  economic  and  technological  developments,  but  would 
have to wait for modifications in the regulatory framework to take into account any change 
in the optimal adjustment path.  

On  the  contrary,  PO2  leaves  full  freedom  to  operators  to  meet  the  goal  with  fuels  and 
technologies of their choice. This  is  likely to translate in  operators always opting for the 
least  cost  solution,  but  also,  possibly,  taking  lower  risk  in  experimenting  with  other 
technologies.  This  could  make  the  fuel  mix  more  prone  to  technology  lock-in  and 
vulnerable to price fluctuations, as the amount of fuel alternatives would be more limited 
than in the other scenarios. 

PO3 would provide operators with an equal degree of flexibility as PO2, but would offer 
additional incentives to invest in more advanced solutions. As a result, a broader range of 
technologies is likely to be tested in PO3 – and potentially rolled out if successful – than in 
the other two options. For this reason, PO3 is expected to best meet the objectives of the 
proposed intervention.  

In  conclusion,  PO3  would  be  the  most  robust  policy  option  to  unexpected  developments 
and possible wrong predictions on the side of both maritime operators and the regulator. It 
would  offer  significant  net  benefits  with  respect  to  PO1  not  only  on  the  basis  of  current 
projections, but also in possible alternative scenarios. PO3 would also be better suited than 
PO2 in preparing the sector for different technological developments.  

For this reason, PO3 appears at least as efficient as PO2 in meeting the objectives despite 
slightly  lower  net  benefits  quantified  on  the  basis  of  current  projections.  These 
considerations are also well reflected in the stakeholders’ views (see Section 7.5). 

7.3  Coherence 

In  general,  there  are  no  specific  issues  regarding  internal  coherence,  inconsistencies  or 
gaps among the POs, which were designed to ensure that all drivers are addressed. This is 
ensured by the general policy approach described in Section 5.2.15.2.1. 

77 

 
 
All options are coherent with the key EU policy objectives, in particular the environmental 
objective of the Union to become a climate neutral economy by 2050 and other elements 
presented as part of the ‘Fit for 55’ package. The POs build upon the directions outlined in 
the EGD, as regards ramping-up the production and deployment of sustainable alternative 
transport fuels, accelerating the deployment of zero-and low-emission vehicles and vessels, 
and regulating access of the most polluting ships to EU ports as well as obliging docked 
ships to use shore-side electricity.  

As  explained  in  Section  1.5,  the  level  of  ambition  proposed  in  this  initiative  is  fully 
coherent  with  the  common  economic  assessment  underpinning  the  2030  Climate  Target 
Plan  and  the  Sustainable  and  Smart  Mobility  Strategy  and  is  also  consistent  with  the 
conclusions drawn in the 2050 Long Term Strategy (Clean Planet for All). The objective of 
the  proposed  intervention  is  based  on  the  recognition  of  the  major  potential  of  RLF  in 
decarbonising maritime transport and the need to significantly improve their penetration in 
the  maritime  fuel  mix,  for  the  sector  to  appropriately  contribute  to  the  EU  climate 
objectives.  

In this context, the proposed POs are designed as an integral part of the overall “basket of 
measures” to address maritime emissions (see Section 1.2). More precisely, the proposed 
intervention  is  expected  to  specifically  address  the  technology  barrier  related  to  RLF 
uptake and, by doing so, make available a wider and cheaper range of abatement options. 
As  a  result,  a  cap-and-trade  mechanism,  such  as  the  ETS,  would  be  able  to  achieve  its 
target  –  other  things  equal  –  at  a  lower  price  of  carbon  and  lower  cost  for  society. 
Conversely, carbon pricing would narrow the price gap between fossil fuels and RLF and 
support progress  on  alternative fuels  technologies. Even though, in  all analysed POs, the 
penetration rate of RLF is expected to become significant only after 2035 (reaching around 
30% of the overall fuel mix in 2040), rapid policy intervention is necessary to address the 
long  lead  times  related  to  RLF  deployment  and  to  reflect  the  long-lived  nature  of  the 
vessels  and,  generally,  the  fuel  infrastructure.  As  regards  the  coherence  with  other  EU 
policies  on  RLF,  all  POs  have  been  designed  to  complement  the  existing  framework  (in 
particular  RED  II  concerning  fuel  supply  and  AFID  concerning  the  deployment  of  the 
distribution infrastructure) and fill a specific gap concerning the lack of demand-side push 
on  the  uptake  of  marine  RLF.  Sustainability  and  eligibility  criteria  of  RLF  and  the 
corresponding  certification  requirements  will  be  based  on  the  RED  II  provisions.  While 
coherence and consistency with AFID is guaranteed with all POs, PO1 may facilitate the 
identification  of  the  need  to  deploy  new  infrastructure  for  a  given  technology  (as  the 
number of technology options is limited and a technology choice is made ex-ante) through 
AFID. However, in all options, the highest share of RLF is expected to be compatible with 
existing infrastructure.  

The proposed POs are also fully  consistent with the EU MRV framework and have been 
designed to build as much as possible on the existing monitoring, reporting and verification 

78 

 
 
requirements  and  systems  in  order  to  facilitate  compliance  by  operators  as  well  as 
compliance checks by the public authorities. 

7.4  Proportionality and subsidiarity 

None of the options goes beyond what is necessary to achieve the objectives. The proposed 
intervention  ensures  the  minimum  uptake  of  RLF  in  the  maritime  sector  necessary  for 
delivering  the  EU  climate  ambition.  To  do  so,  the  initiative  addresses  the  technology 
barriers  currently  hampering  the  deployment  of  RLF  in  the  maritime  sector,  which  is  an 
essential component of the overall approach to shipping emissions. The proposed measures 
are designed to boost the uptake of RLF in the EU, which is unlikely to be realised by the 
sector  without  a  specific  regulatory  push  (as  seen  from  the  limited  uptake  and  existing 
plans and also confirmed by answers in the OPC as referenced in Section 2.1). The POs are 
all expected to provide a stable and predictable regulatory framework, which would unlock 
and  stimulate  investments  to  develop  the  necessary  fuel  ecosystem  (predictable  level  of 
demand, increase production and distribution of marine RLF, etc.).  

The  options  are  designed  not  to  impose  any  disproportionate  impacts  on  the  shipping 
operators,  notably  by  setting  targets  that  imply  a  gradual  introduction  of  RLF  in  the 
maritime  fuel  mix,  which  is  increased  over  time  (from  around  3%  in  2025  to  more  than 
85% in 2050). This approach is expected to provide sufficient time for the market to adjust: 
for operators to plan the shift towards higher levels of RLFs and for the suppliers to ramp-
up  production  and  provide  appropriate  levels  of  RLF  to  meet  upcoming  demand.  In  this 
context,  it  is  important  to  note  that  while  the  initiative  will  not  require  that  the  RLF  are 
bunkered in the EU (for the reasons of carbon leakage explained above), the target levels 
have been set in such a way that they can be answered, if necessary, by sufficient level of 
such fuels produced in the EU. Also, concerning the particular case of emissions at berth, 
the  specific  requirements  for  the  use  of  OPS  (or  equally  performant  alternative  such  as 
batteries)  are  foreseen  to  be  phased-in  with  a  sufficient  lead-time  and  first  mandated  to 
only the most polluting ships in ports, i.e. containerships, passenger ships and ro-pax ships, 
to avoid imposing disproportionate impacts to the entire fleet and the ports.   

The  long  time  horizon  included  in  each  PO  (up  to  2050)  is  also  an  important  element 
allowing  proportionality  for  the  sector.  Given  the  long  lead  times  related  to  RLF 
deployment  as  well  as  the  long-lived  nature  of  the  concerned  assets  (vessels  and 
infrastructure),  this  long  time  perspective  is  an  important  aspect  of  the  proposed 
intervention. It is also critical to provide the highest degree of predictability to all market 
operators, and hence facilitate planning and investments.  

In  terms  of  technology  developments,  PO2  and  PO3  are  expected  to  provide  more 
flexibility for operators to comply compared with PO1, as it allows them to make their own 
technology  choice  to  meet  the  given  standard.  By  introducing  a  mechanism  on  over-
achievement,  PO3  also  provides  a  greater  incentives  for  the  best  performers.  Given  the 
diversity of the maritime sector, an ex-ante technology choice as in PO1 may create sub-

79 

 
 
optimal  situations,  in  which  the  type  of  selected  fuels  are  not  the  most  economically  or 
environmentally efficient choice for specific operators.  

Overall, emissions reductions produced by each PO significantly outweigh the costs of the 
measure imposed on the sector. They also guarantee that the sector adequately contributes 
to the overall CO2 emissions targets set for the entire European economy. 

Given  then  international  nature  of  maritime  transport,  the  proposed  intervention  at  EU 
level  is  also  expected  to  deliver  the  highest  benefits  compared  to  regional  or  national 
requirements,  which  would  trigger  the  development  of  technical  solutions  that  may  not 
necessarily be compatible among each other. EU action is also justified by the fact that the 
nature and scope of the identified problems is the same across all EU Member States.  In 
the  absence  of  specific  provisions  on  RLF  at  global  level  (IMO),  this  initiative  is  also 
expected to provide substantial input to such debate, expected to start in the second half of 
2021. 

7.5  Stakeholder’s views on the options  

87%  (118/136)  of  the  OPC  respondents  finds  it  either  relevant  or  very  relevant  to 
complement existing supply-side policy with demand-side policy to promote the uptake of 
RLF in maritime transport. Only 2 % (3/136) find it less relevant or not relevant at all. 

Similarly to the feedback received on the inception impact assessment, respondents to the 
OPC voiced a clear preference for goal-based approach to regulate ships during navigation 
(53%  (71/136))132.  All  stakeholder  groups  preferred  a  goal-based  approach.  However, 
during the interviews and the roundtable revealed diverging views on what this goal-based 
requirement  should  be.  Stakeholders  in  ship  owning  and  ship  management  and  NGOs 
preferred  a  broader  approach  including  also  energy  efficiency  criteria,  i.e.  the  amount  of 
fuel  or  energy  used  per  transport  work  irrespective  of  its  GHG  footprint.  Most  other 
stakeholder groups argued for a goal-based requirement of the fuel only. 

For ships at berth, most stakeholder groups also prefer a goal-based approach. Even though 
the situation is more balanced with the prescriptive approach concerning the regulation of 
ships at berth, the goal-based approach is also the one which received the largest share of 
support  (42%  (57/136))133.  However,  academia,  R&I  stakeholders  slightly  prefer 
‘requirements  on  the  share  of  sustainable  alternative  fuels’.  Representatives  of  port 
management  and  administration  as  well  as  port  terminal  operators  or  other  port  service 
providers are indifferent between the two.  

Another  closely  related  requirement  for  the  policy  voiced  by  most  stakeholders  is 
technology  neutrality.  Multiple  stakeholders,  including  NGOs  and  technology  suppliers 

132 15 % prefer a prescriptive approach for ships in navigation and 25 % choose ‘other’, ‘no opinion’ or ‘no answer’. 
133 23 % prefer a prescriptive approach for ships in navigation and 35 % choose ‘other’, ‘no opinion’ or ‘no answer’. 

80 

 
 
                                                           
explicitly  indicated  that  prescriptive  measures  for  a  certain  technology  would  be 
suboptimal, because of the high risk of technology lock-in and stranded assets. 

On  this  aspect  of  the  stakeholders’  views  vis-à-vis  the  overall  policy  approach,  PO2  and 
PO3  would  both  be  superior  to  PO1.  The  PO3  mechanism  to  reward  overachievement 
addresses better the flexibility needs of the economic actors while boosting the uptake of 
the most advanced technology and, consequently reducing the risk of technology lock-in. 
Annex 2 provides further information on the stakeholder consultation. 

7.6  Summary on the comparison of options 

All  POs  are  comparable  in  meeting  the  effectiveness  criteria,  even  though  PO2  is  less 
suitable for tackling the need of technology development. Also while PO1 may be effective 
on this issue, it will require the regulatory framework to be sufficiently flexible to reflect 
technology  development 
technology  options.  Concerning 
list  of  selected 
effectiveness, PO3 ranks first followed by PO1 and then PO2.  

the 

in 

As regards efficiency, all POs are also producing very similar results. Both PO2 and PO3 
are  providing  greater  flexibility  to  the  operators  to  choose  technology  to  meet  the  given 
target. However, in the lack of any mechanism to incentivise the uptake of more advanced 
technology  options,  PO2  is  expected  to  foster  first  the  most  cost-efficient  options  and 
hence deliver the best cost-benefit ratio. Indeed, as all POs have been designed to provide 
comparable  emissions  reductions  over  time,  in  line  with  the  objectives  of  the  CTP,  the 
diversity of the fuel  mix is  what  will influence most the overall cost  of the initiative. As 
PO2  focusses  mainly  on  the  cheapest  solutions  (64.6%  of  the  fuel  mix  is  delivered  by 
biofuels in liquid or gaseous form), it is the one delivering the best cost-benefit ratio. This 
is however done “at the expense” of a greater stimulation of most advanced technologies 
(SO2) and a more divers fuel mix. In terms of cost-benefit ration, PO2  is followed by PO3 
and then PO1.  

In terms of coherence, all options are perfectly coherent with the overall policy objectives 
of  the  Green  Deal  and  with  the  other  measures  developed  to  address  ship  emission.  The 
consistency with infrastructure policy (in particular AFID) may be facilitated by PO1 as it 
implies a clear technology choice, which allows to better plan the resulting infrastructure 
needs. However, PO2 and PO3 remain highly performant, considering that, as indicated in 
Section 6.1.1, around three quarters of the RLF expected to be deployed under these POs 
may not require specific infrastructure (bio- and e-fuels, bio- and e-gas can be considered 
as drop-in fuels in this respect).  

The  proportionality  is  also  guaranteed  in  all  POs.  The  prescriptive  approach  implied  by 
PO1 may not be the most optimal, and turns to be also the most costly one. Both PO2 and 
PO3 provides the highest degree of flexibility for the sector to make the most appropriate 
choices  to  comply  with  the  proposed  targets  and  therefore  perform  similarly  in  terms  of 
proportionality.  The  introduction  of  the  mechanism  for  over-achievers  in  PO3  requires 
slightly  higher  administrative  costs  for  the  public  authorities,  but  this  is  considered 

81 

 
 
justified in terms of the incentives it provides on the uptake of most advanced technologies 
(hence  addressing  SO2).  While  the  use  of  this  mechanism  may  come  with  a  limited 
additional burden for the operators, it remains a voluntary scheme and its use is likely to be 
subject on an individual assessment by the concerned operators.  

Table  24  summarises  the  performance  of  the  three  POs  on  each  assessment  criteria 
compared to the baseline. It also provides an overview of the stakeholder preferences.  

Table 24 Comparison of the policy options 

Assessment criteria / compared to baseline 

Effectiveness 

Efficiency 

Coherence 

Proportionality 

Stakeholder preferences 

8.  PREFERRED OPTION 

PO1  PO2  PO3 

+++ 

++ 

+++ 

++ 

+++ 

+++ 

+++ 

++ 

++ 

++ 

+++ 

+++ 

+ 

++ 

+++ 

Based  on  the  combined  analysis  of  cost-benefit  ratio,  acceptance  by  stakeholders  and 
expected effectiveness and proportionality, the preferred option is therefore policy option 
3 (goal-based approach with reward mechanisms for overachievers). 

This  option  strikes  the  best  balance  between  the  achieved  objectives  and  the  overall 
implementation  costs.  It  provides  net  benefits  amounting  to  €55.0bn  over  the  2021-2050 
period  (expressed  as  present  value).  Through  the  goal-based  approach,  this  PO  also 
answers  the  needs  for  flexibility,  which  have  been  stressed  by  stakeholders  during  the 
consultation activities (in particular operators and ports). An important aspect where PO3 
is  also  superior  compared  to  the  two  other  approaches  concerns  the  introduction  of  a 
mechanism for rewarding over-compliance through the use of the most advanced  – zero-
emission – technologies. In doing so, this PO also reduces the risk of technology lock-in 
and ensures several technology options can be used by operators as soon as they become 
mature  and  contribute  to  meeting  the  defined  targets.  This  choice  of  this  PO  as  the 
preferred  one  is  thus  determined  by  the  need  to  create  lead  markets  for  zero-emission 
technologies, which will be necessary to deliver on the post-2030 climate objectives. This 
mechanism  however  implies  additional  administrative  costs,  which  are  considered 
justifiable compared to  the benefits  it provides, in particular in  fulfilling  the objective of 
stimulating technology developments.  

As  regards  the  type  of  legal  instrument  which  would  implement  the  preferred  policy 
option, a Regulation appears to be the most appropriate choice. 

82 

 
 
 
 
Annex 3 contains a more detailed description of the regulatory measures envisaged, as well 
as  an  indication  of  how  implementation  could  take  place  in  practice,  based  on  already 
existing practices set out in the EU MRV system as well as the applicable PSC procedures. 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

The Commission will follow the progress, the impacts and results of this initiative through 
a set of regular monitoring tools as well as dedicated evaluations.  

Indication  on  the  RLF  penetration  in  the  maritime  fuel  mix  will  be  the main  criterion  to 
evaluate the impacts of the proposed initiative. The evaluation arrangements of the impacts 
of this initiative, as well as the identification of the operational objectives and monitoring 
plan  have  been  developed  for  the  preferred  option,  PO3.  A  set  of  operational  objectives 
were  derived  from  the  general  and  specific  objectives  of  the  initiative,  which  reflect  the 
nature  and  type  of  measures  adopted.  The  monitoring  should  start  immediately  after  the 
entry into force of the Regulation.  

One of the most important elements of the monitoring framework will be the data collected 
through the EU MRV that ships calling EU ports need to fulfil, in which they indicate the 
quantities and types of fuel consumed during the journeys covered by the Regulation. This 
will  allow  to  have  an  annual  indication  of  the  penetration  rate  of  RLF  in  the  maritime 
transport  fuel  mix,  which  is  one  of  the  main  indicators  of  progress.  In  this  respect,  it  is 
worth  noting  that  the  MRV  requirements  also  concern  ships  at  berth.  As  a  result,  data 
collected through the EU MRV will allow providing an accurate picture of the use of RLF 
in the maritime sector not only while in navigation (addressing problem 1) but also at berth 
(problem  2).  In  addition,  data  on  alternative  fuel  infrastructure  collected  under  the 
framework of the AFID would also allow to identify what impacts this initiative will have 
on the deployment of port infrastructure, in particular on-shore power connection points.  

In this context, additional information will be collected on the use of electricity on the ship 
side  and  the  first  review  of  the  Regulation  will  also  include  assessment  on  possible 
extension of the requirements at berth to additional ship types. 

The  Commission  will  also  initiate  an  evaluation  to  verify  whether  the  objectives  of  the 
initiative have been reached, based on the data collected through EU MRV, the evolution 
of  the  distribution  infrastructure  as  well  as  a  series  of  targeted  surveys.  This  should  also 
provide an indication on the impact of the initiative on production levels of marine RLF as 
well  as  the  cost  evolution  of  these  fuels.  Interactions  with  other  policies  aimed  at 
decarbonisation  of  the  maritime  sector  will  also  form  an  important  element  of  such  an 
assessment  to  ensure  continued  consistency  and  complementarity  between  initiatives.  If 
necessary, the evaluation will inform future decision-making processes to ensure necessary 
adjustments for reaching the set objectives, while also taking into account developments of 
other policy initiatives. 

83 

 
 
The  list  of  operational  objectives,  indicators  and  data  sources  is  presented  in  Annex  7 
(Table 70). Some of these monitoring arrangements will be established more in detail only 
after thorough discussion with Member States and key stakeholders. 

84 

 
 
 
 
 
Annex 1: Procedural information 

1.  LEAD DG, DeCIDE PLANNING/CWP REFERENCES 

The  lead  DG  is  Directorate  General  for  Mobility  and  Transport  (MOVE),  Unit  D1: 
Maritime Transport and Logistics 

DECIDE reference number: PLAN/2020/6945 

The development of this initiative was announced under item 8 in Annex I to the Adjusted 
Commission Work Programme 2020134. The Inception  Impact Assessment  was published 
on 27 March 2020135.  

2.  ORGANISATION AND TIMING 

The Inter Service Steering Group (ISSG) for the Impact Assessment was set up in February 
2020 and includes the following DGs and Services: SG, LS, CLIMA, ENV, ENER, RTD, 
GROW, MARE, COMP, TAXUD as well as EMSA (European Maritime Safety Agency).  

The ISSG approved the Inception Impact Assessment and discussed the main milestones in 
the  process,  in  particular  the  consultation  strategy  and  main  stakeholder  consultation 
activities, the task specifications to launch the contract for the external  IA support study, 
the key deliverables from the support study, and the draft impact assessment report before 
submission  to  the  Regulatory  Scrutiny  Board.  In  total,  5  meetings  of  the  ISSG  were 
organised to discuss this impact assessment, including virtual meetings, resulting from the 
COVID-19 crisis. These meetings took place on 24 February 2020, 30 April 2020, 1 July 
2020, 1 October 2020 and 14 December 2020.  Further consultations with  the  ISSG were 
carried out by e-mails. When necessary bilateral discussions were also organised with the 
most concerned services.  

3.  CONSULTATION OF THE RSB 

The Regulatory Scrutiny Board received the draft version of the impact assessment report 
on  18  December  2020.  The  Board  meeting  took  place  on  20  January  2021,  following 
which  it  gave  a  negative  opinion  on  the  report.  The  Board  also  made  several 
recommendations  which  were  addressed  in  the  revised  impact  assessment  report  as 
follows:  

Table 25 Modification of the IA report in response to RSB recommendations 

RSB recommendations 

Modification of the IA report 

134 https://ec.europa.eu/info/sites/info/files/cwp-2020-adjusted-annexes_en.pdf  
135 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12312-FuelEU-Maritime-  

85 

 
 
                                                           
(1)  The  report  is  unclear  about  how  it 
has established the fuel specific targets 
and  pathways  for  the  maritime  sector, 
and  what  the  key  assumptions  and 
uncertainties are. It does not show how, 
and  under  what  conditions,  they  are 
compatible  with 
the  overall  EU 
2030/2050  climate  targets.  The  report 
does  not  analyse  the  implications  and 
feasibility  of  alternative  targets  and 
pathways. 

(2)  The  report  is  not  sufficiently  clear 
on  how  it  ensures  coherence  with  the 
other ‘Fit for 55’ initiatives. It does not 
explain  how  it  takes  into  account  the 
uncertainty on the future content of the 
most directly related climate initiatives. 

Main considerations 

A new Section 1.5 has been added to the report, to explain 
the trajectory for the RLF uptake. It also explains the 
compatibility with the overall EU 2030/2050 climate 
targets. In addition, Section 5.4 includes a qualitative 
assessment of the implications and feasibility of alternative 
trajectories for RLF uptake. 

A  new  Section  1.2  has  been  added  based  on  elements 
provided  in  the  previous  Annex  7  (deleted  now  to  avoid 
duplication).  The  new  Section  1.5  also  adds  clearer 
explanation  on  the  trajectories  for  RLF  as  assessed  in  the 
context  of  the  analytical  work  underpinning  the  Climate 
Target  Plan  and  the  Smart  and  Sustainable  Mobility 
Strategy.  

This,  in  conjunction  with  Section  5.3,  explains  how  the 
different elements of the “basket of measures” for maritime 
transport are complementing to each other.  

report  does  not  explain 
(3)  The 
convincingly  why the present initiative 
cannot  be 
into  existing 
instruments that are part of the ‘Fit for 
55’ package. 

integrated 

As per consideration (2) above 

(4) The report is not always clear on the 
content  of  the  options  and  how  they 
will  function.  It  does  not  sufficiently 
explain  the  functioning  of  the  reward 
mechanisms  for  overachievers  and  its 
possible  interaction  with  the  Emission 
Trading  System.  The  report  does  not 
show  clearly  why  it  prefers  the  option 
with 
for 
overachievers. 

reward  mechanisms 

the 

Details have been added in Section 5.2.2 on the description 
of each of the policy options including elements related to 
certification. Concerning the scheme for over-achievers, 
additional elements have been introduced in the detailed 
description of PO3.  

Details on reporting and enforcement have been added to 
Section 5.2.3, which outlines aspects of policy design that 
all options have in common. 

While some elements from Annex 6 have been brought to 
the main text in chapter 5 to facilitate the reading and 
understand the design of the policy options, the long list of 
policy measures identified in the early stages of the analysis 
has been kept to the Annex in order to still limit the size of 
the document.  

Concerning the choice of the preferred policy option, 
clarifications have been brought to chapter 7 (in particular 
Sections 7.1, 7.2 and 7.6). 

Adjustment requirements 

86 

 
 
 
 
 
(1)  The  report  should  explain  how  the 
fuel-specific targets (or parameters) for 
transport  were  chosen.  It 
maritime 
should  make  clear  how  the  proposed 
pathways  towards  these  targets  align 
with  the  GHG  reduction  targets  of  the 
Climate  Law,  and  how  they  follow  or 
differ  from  the  Climate  Target  Plan 
modelling scenarios. The report should 
explain  the  assumptions  behind  the 
maritime  fuel  targets,  and  under  what 
conditions  they  are  compatible  with 
targets for the other transport sectors. 

(2)  The  report  should  justify  why  it 
does  not 
include  any  alternative 
maritime fuel targets and pathways. Do 
the  costs  of  alternative  pathways 
disqualify them as unfeasible? It should 
present  at  least  a  qualitative  check  on 
the  feasibility  and 
implications  of 
deviating from the set target,  including 
for the overall ‘Fit for 55’ package. 

(3)  The  report  should  better  explain 
how  the  initiative  is  coherent  with  the 
most  directly  related  other  ‘Fit  for  55’ 
initiatives  (in  particular  the  Renewable 
Energy  Directive, 
the  Emissions 
Trading  System  (ETS)  and  the  Energy 
Taxation  Directive).  Would 
this 
initiative  make  some  of  the  others 
superfluous for the maritime sector? As 
the  baseline  does  not 
the 
envisaged changes of  the other ‘Fit  for 
55’ initiatives, the report should explain 
why  it  does  not  include  alternative 
policy  scenarios  in  the  options,  to 
reflect  the  uncertainty  on  the  future 
content of these other initiatives. 

include 

The  new  Section  1.5  adds  explanations  on  the  trajectories 
for  RLF  as  assessed  in  the  context  of  the  analytical  work 
underpinning  the  Climate  Target  Plan  and  the  Smart  and 
Sustainable  Mobility  Strategy  and  consequently  how  the 
fuel-specific targets for this initiative have been established. 
Specific  indication  have  consequently  be  added  in  the 
description of the policy options under Section 5.2.2. 

The new Section 1.5 adds explanation on the trajectories for 
RLF  as  assessed  in  the  context  of  the  analytical  work 
underpinning  the  Climate  Target  Plan  and  the  Smart  and 
Sustainable Mobility Strategy.  

A  new  Section  5.4  has  also  been  added  to  discuss  the 
feasibility of alternative pathways for marine RLF uptake.  

A  new  Section  1.2  has  been  added  based  on  elements 
provided  in  the  previous  Annex  7  (deleted  now  to  avoid 
duplication).  The  new  Section  1.5  also  adds  clearer 
explanation  on  the  trajectories  for  RLF  as  assessed  in  the 
context  of  the  analytical  work  underpinning  the  Climate 
Target  Plan  and  the  Smart  and  Sustainable  Mobility 
Strategy.  

This,  in  conjunction  with  Section  5.3,  explains  how  the 
different elements of the “basket of measures” for maritime 
transport are complementing to each other.  

Section  5.1  (What  is  the  baseline  from  which  options  are 
assessed?) clarifies that the other ‘Fit for 55’ initiatives are 
not part of the baseline. It further explains how coherence is 
ensured. 

(4) The  report  should  explain  why  this 
initiative cannot be (partly) covered by 
the  other  ‘Fit  for  55’  initiatives.  For 
example,  could  the  voluntary  transfer 
of  balances  and  a  possible  reward 
scheme 
for  overachievers  not  be 
integrated in the ETS? 

A  new  Section  1.2  has  been  added  based  on  elements 
provided  in  the  previous  Annex  7  (deleted  now  to  avoid 
duplication).  The  new  Section  1.5  also  adds  clearer 
explanation  on  the  trajectories  for  RLF  as  assessed  in  the 
context  of  the  analytical  work  underpinning  the  Climate 
Target  Plan  and  the  Smart  and  Sustainable  Mobility 
Strategy.  

In  addition,  elements  from  the  former  Annex  6  have  been 
moved  to  the  main  text  and  extended  under  Section  5.3  to 
explain  how  other  measures  included  in  the  ‘Fit  for  55’ 
package would not sufficiently address the objectives of this 
initiative.  

Concerning 
transfer  of  balances,  more 
information has been included in the description of PO3 in 

the  voluntary 

87 

 
 
 
(5)  The  report  should  clarify 
the 
the  problems 
connection  between 
concerning  greenhouse  gases  and  local 
air  pollution.  It  should  properly  reflect 
the  latter  throughout  the  intervention 
logic  (i.e.  also  in  the  options  and 
impact analysis). 

and 

supply 

(6)  The  report  should  provide  more 
detail  on  how  far  scaling  up  of  RLF 
demand  will  contribute  to  reducing 
costs and prices. It should provide more 
detail  about  the  sources  of  greater 
competing 
feedstock 
demands.  It  should  explain  better  the 
cost  differences  between  standard  and 
advanced  biofuels.  The  report  should 
the  high-energy 
also  acknowledge 
demand  for  producing  biofuels.  The 
impact  assessment  should  be  explicit 
about  how  coherence  will  be  ensured 
with the EU’s overall renewable energy 
for 
competition 
policy 
feedstock,  or  accounting  of 
total 
renewable targets), and how the risk for 
overlapping regulation is avoided. 

(e.g. 

for 

the 

values 

(7)  The  report  should  further  specify 
the content of the options and how they 
would  function.  In  particular,  it  should 
and 
target 
specify 
technology  shares,  and  explain  better 
certification, reporting and enforcement 
under  the  different  options.  It  should 
the  scheme  for 
also  specify  how 
overachievers would function. It should 
explain  how  the  proposed  options  are 
cost-effective. 

the 

reward  mechanisms 

(8)  The  report  should  elaborate  the 
assessment  and  comparison  of  options. 
It  should  justify  better  why  the  option 
for 
with 
overachievers  is  the  preferred  option, 
given that the net benefits of the option 
these  mechanisms 
without 
are 
to  be  higher.  It  should 
estimated 
explain  why  the  preferred  option  does 
not  lead  to  a  higher  GHG  emission 

Section 5.2.2. 

Clarifications have been added in Section 2.1 and further in 
chapter 5. In both cases,  the  problem definition  focuses on 
the  uptake of specific fuels. However, the introduction of a 
specific  problem  at  berth  recognises  the  fact  that,  when 
ships are in ports, effects on air quality impose an additional 
constraint  on  the  techncial  solution  to  be  chosen,  being 
cognisant  to  the  fact  that  not  all  RLF  will  have  equal 
performance in terms of reduction of air pollutants. 

A new Section 6.1.2 has been added to provide an overview 
of  the  impact  on  RLF  prices,  feedstocks  and  renewable 
electricity  needs  for  e-fuels.  This  provide  greater details  in 
particular  on  the  sources  of  feedstocks  that  have  been 
assumed in this analysis. It also discusses the energy needs 
for producing biofuels.  

Concerning  coherence  with  the  overall  renewable  energy 
policy,  these  points  are  also  covered  by  Sections  1.5  and 
5.4. In addition to this, clarification on the risk of overlaps 
is provided in Sections 1.2 and 5.3, which describe also how 
the  different  elements  of  the  “basket  of  measures”  (and 
hence  other  initiatives  of  the  “Fit  for  55”  package)  are 
complementing each other.  

Details have been added in Section 5.2.2 on the description 
of  each  of  the  policy  options  including  elements  related  to 
certification.  Concerning  the  scheme  for  over-achievers, 
additional  elements  have  been  introduced  in  the  detailed 
description of PO3.  

Details  on  reporting  and  enforcement  have  been  added  to 
Section  5.2.3,  which  outlines  aspects  of  policy  design  that 
all options have in common. 

While  some  elements  from  Annex  6  have  been  brought  to 
the  main  text  in  chapter  5  to  facilitate  the  reading  and 
understand the design of the policy options, the long list of 
policy measures identified in the early stages of the analysis 
has been kept to the Annex in order to still limit the size of 
the document.  

As presented in Section 6.3.2, the  preferred option, PO3 is 
actually  the  one  delivering  the  highest  degree  of  GHG 
emissions reductions from  maritime  transport on a  well-to-
wake  basis.  Further  clarifications  have  been  added  so 
Sections 7.1, 7.2 and 7.6, in particular on the effectiveness 
of the three assessed policy options in tackling the specific 
objectives  of  this  initiative.  It  also  clarifies  that  the  main 
difference in terms of costs between the options result from 
the  fuel  costs  associated  with  the  different  energy  mix 
delivered. While PO2 remains the least expensive option as 

88 

 
 
 
reduction 
than 
rewards for overachievers. 

the  option  without 

it  does  not  contain  any  additional  “constraint”  for  the 
operators  than  meeting  the  GHG  intensity  target  (hence 
allowing them to select the cheapest compliance option), it 
does not address the SO2 (technology development) as good 
the other options.  

(9)  The 
impact  assessment  should 
discuss  the  importance  of  the  sectors 
and  activities  that  are  excluded  from 
the  scope  of  the  options.  It  should 
analyse  the  effect  of  these  exemptions 
on the realisation of the targets. 

Further  clarifications  have  been  added  in  Section  5.2.3  to 
explain why it is proposed to replicate the MRV approach in 
terms  of  types  and  size  of  ships  covered  by  the  initiative. 
This  approach  strikes  a  balance  between  environmental 
effectiveness and the administrative burden. Broadening the 
scope  to  ships  above  400  GT  (which  is  the  minimum  size 
applicable 
international  conventions)  would  bring 
minimal benefits in terms of emission reductions but would 
significantly increase the  number of regulated entities. The 
approach  currently  proposed  allows  to  address  the  highest 
emitters  in  terms  of  GHG  and  air pollutants  while  limiting 
the number of regulated ships.  

in 

The  Board  issued  a  second,  positive  opinion  on  3  March  2021,  including  some 
further recommendations. These have been addressed in this final version of the Impact 
Assessment report as detailed in the table below. 

Table 26 Modification of the IA report in response to RSB recommendations 

RSB recommendations 

Modification of the IA report 

the 

(1)  The  report  does  not  sufficiently 
stress 
importance  of  getting 
maritime  renewable  fuel  technologies 
ready  in  time  to  reach  the  post-2030 
climate target.  

Main considerations 

An explicit reference to the need for increase uptake of RLF 
in order to reach the post-2030 climate targets has been 
added in section 2.3.  

Furthermore, section 5.3.1 explains the need for the 
legislative instrument to establish the necessary conditions 
for lead markets to start emerging as rapidly as possible and 
to support the deployment of new fuel technologies to 
deliver on the post-2030 climate objectives 

(2) The report is not clear enough about 
the  uncertainties  underlying the impact 
assessment.  

An explicit reference to uncertainties has been added in the 
introduction of section 6 that points out to the methodology 
described  in  Annex  4.  Additional  paragraphs  highlighting 
the uncertainties have been added in sections 6.1.2 and 7.2. 

Adjustment requirements 

(1)  The  report  should  briefly  explain 
why  the  transport  sector  should  reduce 
its  CO2  emissions  only  by  90%  by 
2050.  It  should  similarly  clarify  how 
this  margin  has been distributed across 
the transport sectors.  

Details have been added in Section 1.5.2.2 on the 
implications of meeting th European Green Deal objectives 
for the transport sector in general and for the maritime 
transport in particular.  

89 

 
 
 
 
 
A specific reference has been added to section 5.3.1 on the 
need for the legislative instrument to establish the necessary 
conditions  for  lead  markets  to  start  emerging  as  rapidly  as 
possible  and  to  support  the  deployment  of  new  fuel 
technologies to deliver on the post-2030 climate objectives. 

(2)  The  report  discusses  the  relation 
between  the  demand-side  measures  in 
the  cost-
the  maritime  sector  and 
efficient  emissions  trading  system,  and 
compares  the  cost-efficiency  and  cost-
effectiveness  of  the  options.  However, 
the  report  and  executive  summary 
should highlight more prominently that 
the  choice  for  the  preferred  option  is 
determined  by  the  need  to  create  lead 
markets  for  new  fuel  technologies  to 
deliver  on 
the  post-2030  climate 
objectives. It should better explain how 
evaluation 
the  monitoring 
arrangements  will 
ensure 
complementarity  between  the  various 
policy initiatives over time.  

help 

and 

An explicit reference to uncertainties has been added in the 
introduction of section 6 that points out to the methodology 
described  in  Annex  4.  Additional  paragraphs  highlighting 
the uncertainties have been added in sections 6.1.2 and 7.2.  

Concerning  the  expected  impact  of  the  preferred  option 
(mechanism  to  reward  over-achievers)  on  stimulating  new 
technologies, figures have been added to section 7.1. 

Further  clarifications  have  been  added  in  Section  5.2.3  on 
the size of ships considered under the initiative and possible 
links with specific measures on supply.  

report 

(3)  The 
should  be  more 
uncertainities 
about 
transparent 
underlying the analysis. In particular, it 
should discuss uncertainties in the costs 
of  renewable  fuels  and  the  demand  by 
other sectors, and their possible effects 
on the greening and competitiveness of 
the  maritime  sector.  It  could  also  be 
more  nuanced  on  the  expected  effects 
of  the  preferred  option’s  scheme  for 
over-achievers  on  stimulating  new 
technologies, by better aligning the text 
with the presented scenario outcomes. 

(4) The report should better justify why 
it  excludes  smaller  ships  and  certain 
categories of ships (e.g. fishing vessels) 
from  the  scope  of  the  intiative,  as  this 
would  significantly  limit  the  reduction 
of  particulate  matter  emissions.  The 
report  should  also  consider  to  what 
extent  exempted 
ships  could  be 
affected  by  the  supply  measures  of  the 
(to  be  revised)  Renewable  Energy 
Directive,  as  their  smaller  size  limits 
their bunkering capacity. 

4.  EVIDENCE, SOURCES AND QUALITY 

The  impact  assessment  is  based  on  research/analyses  done  by  the  Commission  with 
support  of  EMSA.  The  Commission  also  contracted  an  external,  independent  consultant 
(Ecorys and CE Delft) to support this impact assessment. The external support study will 
be published alongside this report.  

90 

 
 
 
Qualitative  and  quantitative  data  supporting  this  impact  assessment  has  been  collected 
from Member States, shipping owners and operators, ports, fuel and technology producers, 
academia and non-governmental organisations.  

Modelling of the policy options in a consistent way with the scenarios prepared in support 
of the Climate Target Plan has been performed by E3Modelling with the PRIMES model, 
including  its  PRIMES-TREMOVE  and  PRIMES-Maritime  modules.  Specific  analysis  on 
the  risk  of  carbon  leakage  in  the  introduction  of  extra-EU  journeys  in  the  scope  of  the 
policy options has been carried out by TRT with the TRUST model.  

This  report  also  draws  on  the  activities  of  two  Commission’s  expert  groups,  namely  the 
European Ports Forum136 (EPF) and the European Sustainable Shipping Forum137 (ESSF), 
in particular its sub-group on Sustainable Alternative Power for Shipping.  

136 https://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=3542  
137 https://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=2869  

91 

 
 
 
 
 
 
                                                           
Annex 2: Stakeholder consultation   

1. 

INTRODUCTION  

This annex provides a summary of the outcome of the consultation activities, which have 
been carried out for the FuelEU Maritime initiative (including in the context of the external 
support  study).  It  provides  a  basic  analysis  of  the  range  of  stakeholder  groups  that  were 
engaged in those activities and a summary of the main issues that they raised. 

The objectives of the consultation activities were to:  

  Collect  stakeholder  views  on  draft  policy  measures  and  policy  options  (POs) 

discussed in this impact assessment;  

  Gather evidence on expected costs and benefits of draft policy measures; and  
  Help  in  identifying  gaps  in  the  intervention  logic  or  areas  requiring  further 

attention. 

The main consultation activities included:  

  An open public consultation (OPC), organised by the Commission, running from 2 

July 2020 to 10 September 2020;  

  A targeted stakeholders  consultation (TC) organised by the consultant responsible 
for  the  impact  assessment  support  study,  running  from  18  August  2020  to  18 
September  2020  and  directed  at  experts  from  the  European  Sustainable  Shipping 
Forum  (ESSF).  The  consultant  also  conducted  a  series  of  interviews  with 
stakeholders,  including  industry  representatives  and  national  authorities,  between 
10 July 2020 and 1 December 2020; 

  A  stakeholders  roundtable,  organised  by  the  Commission  on  18  September  2020 
with  members  of  European  Sustainable  Shipping  Forum138  (ESSF)  and  the 
European Ports Forum139 (EPF); 
  Regular expert group meetings. 

The information collected from stakeholders was key in allowing the Commission to refine 
the  design  of  the  POs  as  well  as  to  assess  their  economic,  social  and  environmental 
impacts,  compare  them  and  determine  which  PO  is  likely  to  maximize  the  benefits/costs 
ratio for the society.  

138 https://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=2869  
139https://ec.europa.eu/transparency/regexpert/index.cfm?do=groupDetail.groupDetail&groupID=3542  

92 

 
 
                                                           
2.  FEEDBACK ON THE INCEPTION IMPACT ASSESSMENT  

The  Commission  received  81  replies  to  the  Inception  Impact  Assessment  (IIA)140  during 
the public feedback period (27 March - 24 April 2020).  

Most  of  the  feedback  was  submitted  by  companies  and  business  associations  (54/81), 
including  beyond  the  “traditional”  maritime  stakeholders  and  also  covering  expertise  on 
fuel  supply  and distribution.  NGOs, academia and citizens also  responded directly to  the 
IIA publication. Several public authorities provided feedback to the IIA (DE, SP, SE, City 
of Stockholm). 

In general, the initiative as presented in the inception impact assessment received positive 
reactions. Some representatives of the sector stressed the importance to pursuing activities 
at global (IMO) level as well as the need to develop a series of support measures (including 
financial support) for boosting the uptake of alternative fuels in maritime transport. There 
was  no  clear  preference  emerging  concerning  the  fuels  and  technologies  that  would 
ultimately  provide  the  best  pathway  to  reduce  emissions.  Concerning  the  regulatory 
approach,  the  majority  of  respondents  was  in  favour  of  goal-based  measures  over 
prescriptive measures.  

3.  METHODOLOGY 

Expert Group Meetings  

As part of its consultation strategy, the Commission held several expert group meetings to 
gather  specialised  input.  On  these  occasions,  the  Commission  presented  the  FuelEU 
Maritime initiative and gathered stakeholders’ opinions on the proposal and the POs. 

On 2 March 2020, the Commission consulted a targeted group of stakeholders in the sub-
group Sustainable Alternative Power for Shipping (SAPS) in the context of the ESSF. The 
meeting  was  attended  by  approximately  60  participants.  On  this  occasion,  several 
stakeholders such as individual independent experts, associations, third country authorities 
and Member States representatives participated (BE, DE, DK, ES, FI, FR, HR, IE, LT, NL, 
PT  and  SE).  They  welcomed  the  initiative  and  many  participants  confirmed  their 
availability to support the work by sharing their knowledge.  

On 4 March 2020, the Commission consulted the EPF Plenary. The meeting gathered ports 
associations and representatives from Member States (BE, DK, EL, ES, FR, LV, MT, IE, 
PL and RO). The 38 participants stressed that clarity and certainty about the fuels  of the 
future  is  crucial  for  first  movers  and  investors.  The  importance  of  port  call  optimization 

140https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12312-FuelEU-

Maritime/feedback?p_id=7658088   

93 

 
 
                                                           
was also mentioned as important, which, besides the maritime sector, requires cooperation 
between all port stakeholders.  

On  17  June  2020,  another  ESSF  SAPS  sub-group  meeting  was  held  with  individual 
independent  experts,  associations, 
third  country  authorities  and  Member  States 
representatives  (BE,  DE,  DK,  ES,  FI,  FR,  HR,  IE,  LT,  NL,  PT  and  SE)  making  up 
approximately 80 participants. The meeting focused on discussions on the feedback from 
the IIA. The participants noted suggestions concerning predictability for first movers and 
investors,  mandatory  requirements  with  regards  to  the  availability  of  OPS  for  the  ports, 
highlighted  that  requirements  should  target  different  ship  types  and  ship  sizes,  and 
expressed preferences for a goal-based approach where port incentive schemes decided by 
port managing bodies would be one way to support it. 

On  18  September  2020,  a  joint  ESSF  and  the  EPF  Roundtable  took  place  with 
approximately  150  participants.  The  ESSF  plenary,  the  ESSF  SAPS  sub-group,  the  EPF 
plenary  and  the  EPF  sub-group  Sustainable  Ports  were  invited.  Present  on  this  occasion 
were associations representing ports, ship owners and operators, equipment manufacturers, 
bunker suppliers,  industry, trade unions,  third country  authorities, individual independent 
experts  and  Member  States  representatives  (CY,  FR,  IE,  IT,  PL,  PT  and  SE).  Following 
information-sharing  about  the  initiative  and  the  preliminary  outcome  of  the  impact 
assessment,  the  Roundtable  meeting  was  split  into  two  panel  sessions,  covering  both  the 
role  of  FuelEU  Maritime  in  the  sector’s  decarbonisation  strategy,  and  how  to  ramp-up 
sustainable  alternative  fuels  through  FuelEU  Maritime.  The  participants  stressed  the 
importance of a stable regulatory framework with sufficient flexibility for a sector where 
there  was  no  “one  size  fits  all”  and  the  need  to  act  rapidly  on  a  measure  stimulating 
demand.  

On 4 December 2020, the ESSF Plenary was informed about progress on the development 
of the FuelEU Maritime initiative. On 8 December 2020, the final ESSF SAPS sub-group 
meeting  of  the  year  was  held  with  approximately  80  participants.  In  a  poll  about  the 
updated policy options in which half the participants responded, the new PO 3 came out as 
the preferred approach with 53 % in favour (while 8 % expressed support for a prescriptive 
approach (PO1), 23 % for a goal-based approach (PO2)). 

Open Public Consultation  

The  OPC  was  launched  on  2  July  2020  and  closed  on  10  September  2020.  Given  the 
importance  of  the  measure  including  in  the  recovery  from  the  crisis,  the  OPC  has  been 
open for a period of 10 weeks instead of the standard 12 weeks. 

The aim of the OPC was to gather views on the main elements of the impact assessment; 
problem definition and respective drivers, the issue of subsidiarity, the added value of an 
EU level intervention, and preliminary policy options and policy measures.  

94 

 
 
A  total  of  136  responses141  were  received,  covering  a  variety  of  stakeholder  groups.  The 
responses came from ship  owning  and ship  management  (40), energy producers and fuel 
supply (37), short sea shipping (25), national public authorities (15), interest organizations 
(14),  ports  management  and  administrators  (13),  port  terminal  operator  or  other  port 
services  provider  (13),  academia  research  and  innovation  (12),  inland  waterways  sector 
(11),  shipbuilding  and  marine  equipment  manufacturers  (10),  regional  or  local  public 
authorities (9), logistics suppliers, shippers and cargo owners (9), technical standardization 
bodies and class societies (2), investment and financing (2), and other (17).142 

Responses were received from respondents residing or based in 14 EU Member States (BE, 
CY,  DE,  DK,  EE,  EL,  ES,  FI,  FR,  IT,  NL,  PL,  SE  and  UK),  as  well  as  from  Norway, 
Turkey  and  United  States. Most  responses  were  received  by  stakeholders  in  BE  (30), 
followed by DE (15), NL (13), and IT (11).  

Targeted Consultation 

A targeted consultation (TC) survey was distributed to four Commission expert groups143, 
and 32 responses were received. 

The responses came from ports management and administrators (7), ship owning and ship 
management  (7),  shipbuilding  and  marine  equipment  manufacturers  (6),  and  interest 
organisations  (5),  technical  standardization  bodies  and  class  societies  (3),  port  terminal 
operator  or  other  port  services  provider  (3),  energy  producers  and  fuel  supply.  (2), 
academia  research  and  innovation  (2),  short  sea  shipping  (2),  regional  or  local  public 
authorities  (2),  national  public  authorities  (2)  and  other  (3).  No  respondents  represented 
logistics  suppliers,  shippers  and  cargo  owners,  investment  and  financing  or  the  inland 
waterways sector.144 

Stakeholder Interviews  

A  total  of  18  interviews  were  conducted  in  the  framework  of  the  impact  assessment 
support  study,    covering  a  wide  range  of  stakeholder  categories,  namely  equipment 
providers (2), fuel suppliers (3), shipping companies (3), port (4), Member State (1 - NL), 
shipper and cargo owner (3), port state control authority (1), and trade union (1).  

141https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12312-FuelEU-Maritime-/public-
consultation  
142 Participants were asked to indicate which interests they represented. They could select one or more options as 
appropriate, so the results add up to more than the 136 total replies to the OPC. 
143 The groups were the two ESSF sub-groups on Sustainable Alternative Power for Shipping and Ship Energy Efficiency, 
as well as the European Ports Forum and the ART Fuels forum. 
144 Participants were asked to indicate which interests they represented. They could select one or more options as 
appropriate, so the results add up to more than 32 total replies to the TC. 

95 

 
 
                                                           
4.  ANALYSIS OF RESULTS OF THE STAKEHOLDER CONSULTATION 

The remainder of the report presents the main findings from the analysis of stakeholder 
contributions to the consultation process.  They are presented in the following sections and 
structured around the main elements of the intervention logic (problems, drivers, 
objectives) as well as the key aspects of policy design.  

Problems 

80% of the OPC respondents confirmed that it is ‘very relevant’ to promote the uptake of 
sustainable alternative fuels and diversify the fuel mix of maritime transport to accelerate 
the  decarbonisation  of  shipping145.  In  addition,  a  majority  of  the  OPC  respondents  also 
support a policy framework for ships at berth: 37% indicated that this is ‘very relevant’ and 
30% indicated ‘relevant’. This conclusion is supported by the TC results: 34% of the TC 
respondents indicated that a policy for ships at berth is ‘very important’, and 47% indicated 
that this policy scope is ‘important’.  

The  results  from  the  TC  also  confirmed  that  without  policy  intervention,  the  expected 
levels  of  RLF  use  in  maritime  transport  will  only  increase  moderately,  if  at  all,  by  2030 
and 2050. 

Figure 7 Projections for the uptake of low-carbon fuels (TC) without policy intervention. 

Until 2050: The at-berth-use of zero-/low-carbon fuels
and power of ships calling at EU ports

Until 2050: The in-navigation-use of zero-/low-carbon
fuels and power of ships calling at EU ports

Until 2030: The at-berth-use of zero-/low-carbon fuels
and power of ships calling at EU ports

Until 2030: The in-navigation-use of zero-/low-carbon
fuels and power of ships calling at EU ports

0

2

4

6

8

10

12

14

16

18

20

No Answer

No opinion

decreases

remains the same

increases moderately

increases significantly

145 15 % answered “relevant”, 2 % “somewhat relevant”, and 3 % did not provide an answer to this question. 

96 

 
 
 
 
 
                                                           
When  adding  the  qualitative  results  from  the  stakeholder  interviews,  position  papers 
submitted  alongside  the  replies  to  the  OPC,  and  the  joint  ESSF  and  EPF  Roundtable 
discussions, the conclusion is that there is consensus among all stakeholder groups on the 
problems as identified by the initiative. They also support the underlying objective of the 
FuelEU Maritime initiative to promote the uptake of RLF in the maritime fuel mix.  

In  addition,  the  OPC  responses  indicate  consensus  about  going  beyond  addressing  only 
CO2 emissions from fuels used in navigation and at berth. In the OPC, only 16 out of the 
136 participants considered that the approach should be based on CO2 only. 35 respondents 
considered that other GHG should be addressed (in particular methane and nitrous oxides) 
and 74 respondents favoured an approach covering GHG emissions at large as well as air 
pollution. In the qualitative responses on how to weigh the relative advantages and assess 
possible trade-offs  of fuels  between GHG and  air pollutants, no real  consensus  emerged. 
Some  participants  pointed  out  to  the  fact  that  certain  air  pollutants  are  to  be  regulated 
beyond  a  fuel-specific  initiative,  others  that  a  focus  on  GHG  is  still  most  relevant  for 
achieving  the  climate  goals  or  that  the  balance  between  air  pollution  and  climate  change 
needs to be kept. A few participants pointed out to needs to undertake a valuation exercise 
of the external costs of different emissions.  

Problem drivers  

The TC results confirmed that all five drivers identified in the framework of the initiative 
are  regarded  as  relevant.  The  most  relevant  barrier  to  tackle  is  considered  to  be  ‘higher 
costs of alternative fuels compared to fossil fuels’. The least relevant of the five barriers is 
‘the risk of bunkering outside of the EU’.  

The  OPC  results  imply  that  none  of  the  mentioned  barriers  are  regarded  irrelevant  (the 
lowest average score of the options is 2.9/5). The barriers that received the highest sore are 
‘higher  price  of  sustainable  alternative  fuels’  and  ‘high  risk  of  investment  in  vessels 
technology  and  port  infrastructure’.  The  lowest  scoring  measure  is  the  ‘lack  of 
communication  between  actors  and 
the  environmental 
lack  of 
performance, including of the fuel performance’.  

transparency  on 

The barriers which were mentioned most often during the stakeholder interviews, the joint 
ESSF  and  EPF  Roundtable  meeting  and  in  positions  papers  are  related  to  the  costs  of 
adopting  alternative  fuels;  both  the  ’higher  fuel  prices  compared  to  the  conventional 
bunker  fuels’  and  the  ’high  investment  costs’.  Another  issue  which  was  pointed  out  in 
multiple  position  papers  and  interviews  was  the  ‘lack  of  predictability  and  high  risk  for 
investors’. 

These  findings  are  in  line  with  the  quantitative  survey  results  as  presented  above.  Both 
consultation  results  suggest  that  the  different  stakeholders  agree  that  high  fuel-  and 
investment costs together with uncertainty for the investors are the most important barriers.  

97 

 
 
Figure 8 OPC feedback on the importance of the different barriers preventing the uptake of RLF 

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

Lack of predictability of the regulatory framework

28,1% 

33,3% 

17,0% 

8,9% 

4,4% 

8,1% 

High risk of investment in vessels technology and port
infrastructure

38,5% 

34,8% 

14,1% 

2,2% 

3,0% 

7,4% 

Lack of mature technologies (e.g. on ships and on shore)

22,2% 

21,5% 

20,0% 

17,0% 

9,6% 

9,6% 

Higher price of sustainable alternative fuels

48,1% 

26,7% 

9,6% 

5,2% 

3,0% 

7,4% 

Lack of communication between actors and lack of
transparency on the environmental performance,incl.of the…

5,9% 

17,0% 

30,4% 

25,2% 

7,4% 

14,1% 

Insufficient supply (fuel production and infrastructure) of
sustainable alternative fuels or on-shore power supply

Insufficient demand for sustainable alternative fuels or on-
shore power supply

31,9% 

30,4% 

16,3% 

6,7% 

5,2% 

9,6% 

23,7% 

32,6% 

17,0% 

7,4% 

7,4% 

11,9% 

Bunkering (i.e. fuel supply) of ships outside the EU

17,8% 

22,2% 

17,8% 

10,4% 

13,3% 

18,5% 

Presence of split incentives in the sector

17,0% 

28,1% 

15,6% 

13,3% 

4,4% 

21,5% 

Other reasons, please specify

17,8% 

8,9% 

1,5% 
2,2% 
0,0% 

69,6% 

Most important

Important

Somewhat important

Less important

Least important

Not answered / no opinion

Table 27 Comparison of the scores on relevance of barriers per stakeholder group (OPC)146

146 Participants were able to indicate one or more interests appropriate. One participant may belong to more than one 
stakeholder group and thus, the number of total contributions does not add up to 136 (the total number of OPC 
contributions). 

98 

number of contributionsLack of predicatability of the regulatory frameworkHigh risk of investment Lack of mature technologies Higher fuel pricesLack of communication transparency Insufficient supply of sustainable alternative fuels or OPSInsufficient demand for sustainable alternative fuels or OPSBunkering of ships outside the EUSplit incentivesNational public authorities 154,14,24,04,43,24,44,33,63,8Ship owning and ship management403,44,24,14,33,14,33,22,83,5Short sea shipping253,34,23,83,93,03,73,02,93,4Ports management and administrations133,54,23,53,83,33,54,33,33,8Port terminal operator or other port services provider133,44,03,54,03,23,53,53,23,4Inland waterways sector113,03,83,03,63,33,94,13,03,5Shipbuilding and marine equipment manufacturers104,04,12,74,02,53,63,23,63,3Academia, research and innovation123,74,13,74,23,13,83,52,83,5Energy producers and fuel supply 374,04,22,84,32,63,63,93,43,5Interest organisations 143,93,52,94,23,13,13,43,33,9 
 
 
 
                                                           
Even though there is some agreement, the quantitative results show that there are points on 
which  the  stakeholder  groups  disagree.  The  ‘lack  of  mature  technology’  is  generally 
regarded  as  an  important  barrier  by  national  public  authorities,  ship  owners  and 
management  and  short  sea  shipping,  while  the  same  barrier  is  considered  relatively 
unimportant  by  the  inland  waterways  sector,  shipbuilding  and  marine  equipment 
manufacturers, energy producers and fuel suppliers and interest organisations.  

Another  barrier  that  receive  divergent  rating  is  the  ‘insufficient  demand  of  sustainable 
alternative  fuels  or  OPS’.  For  this  category,  inland  shipping  and  port  management  and 
administration  give  this  barrier  the  highest  score,  whereas  short  sea  shipping,  interest 
organizations and academia, research and innovation give the same barrier a relatively low 
score. 

When comparing the barriers that should be addressed with priority by the EU according to 
different  stakeholder  groups,  ‘higher  fuel  prices’,  ‘high  risk  of  investment’  and  ‘lack  of 
predictability for the regulatory framework’, are rated highly by most stakeholders.  

Policy objectives 

In  the  targeted  questionnaire,  respondents  were  asked  about  the  importance  of  a  list  of 
policy objectives.  

Figure 9 Importance of the FuelEU Maritime Initiative (TC).  

In your view, how important is it for the FuelEU Maritime Initiative  
(from 1 not important to 5 very important): 

to establish a number of support measures (e.g. funding, R&I,
etc.) to allow for the development of new fuel solutions in…

to provide a clear framework for assessing the environmental
performance of marine fuels.

to avoid technology lock-in and favour the uptake of more
advances technologies.

to provide flexibility on the choice of fuels that can be allowed in
maritime transport.

to ensure coordinated timing of investments in production,
distribution and use of sustainable alternative fuels.

to provide more certainty on the size of the demand for
sustainable alternative fuels.

 To provide more certainty on the climate and environmental
requirements for ship operations.

0

5

No Answer

2

4

6

8

10

12

14

16

18

20

4

3

2

1

99 

 
 
 
It  is  clear  that  all  of  the  seven  proposed  policy  objectives  are  considered  relevant,  with 
‘providing  more  certainty  on  the  climate  and  environmental  requirements  for  ships  in 
operation’ being the most important policy objective.  

Goal-based approach or prescriptive policy 

In the public consultation, participants were consulted on their preference for either setting 
requirements on the share of specific sustainable alternative fuels to be used in ship’s fuel 
mix while at berth (including use of onshore power) i.e. a prescriptive approach or setting 
performance  requirements  based  on  the  carbon-intensity  of  energy  used  in  marine 
operations i.e. a goal-based approach.  

For ships in navigation, 52 % of respondents preferred a goal-based approach, while 15 % 
preferred  a  prescriptive  approach.  However,  during  the  interviews  and  the  roundtable  it 
became  clear that there  are diverging views on  what  this performance-based requirement 
should  be.  Stakeholders  in  ship  owning  and  ship  management  as  well  as  interest 
organisations  preferred a goal-based approach at  the ship  level,  i.e. a requirement for the 
operational  performance  of  a  ship.  Most  other  stakeholder  groups  argued  for  a 
performance-based  requirement  of  the  fuel,  i.e.  a  standard  for  the  embedded  GHG 
emissions in the fuel per unit of energy. 

For ships at berth, the preference for a prescriptive approach was slightly bigger than for 
ships  in  navigation  with  support  from  23  %  of  the  participants,  while  42  %  indicated  a 
preference for a goal-based approach. 

The results from the qualitative consultations show that all stakeholder groups expressed a 
preference  for  goal-based  over  prescriptive  policy.  Another,  closely  related,  requirement 
for the policy, which was voiced by most stakeholders is  technology neutrality. Multiple 
stakeholders explicitly indicated that prescriptive measures for a certain technology would 
be  suboptimal,  because  of  the  high  risk  of  technology  lock  in  and  stranded  assets. 
However, there is less consensus about the form which such a goal-based approach should 
take.  

On the one hand, there are proponents of the inclusion of carbon pricing, either through the 
inclusion  of  the  maritime  sector  in  the  EU  ETS  or  through  establishing  a  new  emissions 
trading scheme. An alternative option which was advocated for in the position papers and 
interviews  is  an  emission  cap  for  ships.  In  either  case,  as  pointed  out  by  several 
stakeholders, there should be some flexibility for the market to ensure that the efforts for 
decarbonisation can be done where this is most efficient. This suggests either a system in 
which carbon permits can be traded, or a fleet based approach. 

Potential policy measures  

100 

 
 
According to the OPC results, all of the policy measures envisaged are regarded to be of 
importance  at  least  to  some  extent.  Of  the  participants  who  rated  the  options,  the  policy 
measures receiving the highest scores (i.e. scores above 4.00/5) were:  

  Set  a  clear  regulatory  pathway  for  decarbonising  the  current  marine  fuel  mix 

(average score: 4.29/5, 123 responses) 

  Accelerate research and innovation enabling the use of sustainable alternative fuels 

and power (average score: 4.21/5, 123 responses) 

  Establish economic incentives to reduce the price differential between conventional 

 

 

and sustainable fuels (average score: 4.18/5, 125 responses) 
Increase public funding and financial support to overcome the high investment risk 
in sustainable alternative fuel supply or OPS infrastructure (average score: 4.15/5, 
123 responses) 
Increase  public  funding  and  incentivise  private  investment  to  overcome  the  high 
investment  risk  in  vessels  powered  by  sustainable  alternative  fuels  or  propulsion 
systems (average score: 4.11/5, 124 responses) 

Several respondents added their own suggestions for measures, the most noteworthy being 
to pursue a policy within the IMO (6 responses). 

Being  asked  specifically  about  support  measures,  the  TC  respondents  are  most  positive 
about  funding  for  R&I  (average  score:  4.21/5,  32  responses),  CEF  funding  for  specific 
projects  on  the  deployment  of  infrastructure  (average  score:  4.21/5,  32  responses)  and 
technological  developments  and  standardization  aspects  (average  score:  4.29/5,  32 
responses). All other options147 scored well below (3.70 or less). These results are also in 
line with what was communicated by different stakeholders during the interviews. 

Ship types and scope 

58 % to the OPC respondents indicated that the requirements should apply to all ship types, 
while 15 % thought they should apply to certain ship types only e.g. the highest emitters.  

At the same time, there is no agreement on the right geographical scope for the measures: 
both the options ‘ships calling at ports of the EU’ and ‘ships sailing in the territorial waters 
and  Exclusive  Economic  Zones  of  the  EU  Member  States’  got  approximately  an  equal 
amount of votes with 30 % and 24 % respectively. It is noteworthy that a negligible 2 % 
thought that the scope should be ships bunkering in ports of the European Union, so this 
option is extremely unpopular. 

147 The other options were low- or zero-emission provisions in public procurement contracts; differentiation of port fees 
and harmonized reward schemes for green ships; identification and sharing of best practice for the promotion of 
sustainable alternative fuels in MS; and public support for the deployment of fleet with advanced propulsion. 

101 

 
 
                                                           
In addition to this, it was suggested in an interview that the right approach would be to start 
with policy for ships which regularly visit the same ports, since in those cases it is easier 
for the ships and ports to adapt. 

Measuring environmental performance  

There is relatively good agreement about how emissions should be included in the policy 
framework. 56 % of OPC respondents prefer a “well-to-wake” approach. It is furthermore 
preferred  by  54  %  of  stakeholders  that  this  takes  both  greenhouse-gas  and  air  quality 
emissions into account. 

During the stakeholder interviews, the joint ESSF and EPF Roundtable and in the position 
papers, there is also agreement between stakeholders on the fact that emissions should be 
measured on a well-to-wake basis. In the feedback to the IIA, 13 out of the 81 participants 
also  mentioned  their  preference  for  a  well-to-wake  approach.  However,  one  stakeholder 
argued that although all emissions should be considered, the shipping sector should only be 
responsible  for 
tank-to-wake  emissions.  Multiple 
i.e. 
stakeholders also pointed out the need for a certification system for sustainable alternative 
fuels as necessary to ensure the sustainability of alternative fuels on the market. 

the  exhaust  emissions 

the 

All stakeholder groups thus generally agree that the emissions under this policy should be 
calculated on a “well-to-wake” basis.  

Policy framework for ships at berth 

Most of the OPC respondents think that it is either very relevant (37 %) or relevant (29 %) 
that emissions at berth are included in the scope of a policy framework. This is supported 
by the TC results. However, there is less agreement about how such requirements should 
apply. Both the option to make the policy apply to all ships at berth (22 %) and the option 
to  prioritize  the  highest  emitters  (30  %)  gained  a  substantial  amount  of  votes.  12  % 
indicated that action should only be taken once critical infrastructure is made available in 
majority  of  EU  ports,  while  8  %  preferred  prioritising  the  ships  and  the  ports  already 
equipped with zero-emissions technologies (including OPS). 

During the interviews, the joint ESSF and EPF roundtable and in the position papers there 
seems  to  be  an  agreement  that  OPS  requirements  for  ships  at  berth  is  relevant  and 
necessary for achieving the decarbonisation objectives. Also, most stakeholders agree that 
there  will  be  an  important  role  for  OPS  in  reaching  the  targets.  However,  mandating  the 
use  of  OPS  in  ports  is  a  very  unpopular  option.  All  the  interviewed  ports  stressed  that 
mandating OPS is not a good option because the viability varies greatly from port to port. 
Even ports who already invested in OPS infrastructure were against such a policy. A goal-
based policy at berth would therefore have more support from the stakeholders. 

102 

 
 
5.  CONCLUSION 

The  objectives  of  the  consultation  activities  have  been  largely  achieved:  all  relevant 
stakeholders groups have been consulted and most provided their views on current barriers 
hindering  the  uptake  of  sustainable  alternative  fuels  and  the  policy  measures  under 
consideration.  Where  available,  respondents  also  provided  additional  quantitative  and 
qualitative information.   

The  consultations  showed  that  there  is  consensus  among  all  stakeholder  groups  on  the 
problems  as  identified  by  the  initiative.  They  also  support  the  underlying  objective  to 
promote the uptake of RLF in the maritime fuel mix.  

The  consultations  confirmed  that  all  five  drivers  identified  in  the  framework  of  the 
initiative are regarded as relevant. The results suggest that the different stakeholders agree 
that  high  fuel  and  investment  costs  together  with  uncertainty  for  investors  are  the  most 
important barriers. In terms of policy objectives, ‘providing more certainty on the climate 
and environmental  requirements for ships in  operation’ appears to  be the most important 
policy  objective  in  view  of  stakeholders.  All  stakeholder  groups  also  expressed  a 
preference  for  goal-based  over  prescriptive  policy,  which  also  concurs  with  another 
requirement  for  the  policy  voiced  by  most  stakeholders,  the  technology  neutrality.  As 
regards  the  policy  measures,  setting  a  clear  regulatory  pathway  for  decarbonising  the 
current  marine  fuel  received  the  highest  scores  from  the  stakeholders.  On  geographical 
scope, there was no obvious preference on the right geographical scope for the measures. 
In terms of measuring environmental performance and how emissions should be included 
in  the  policy  framework,    majority  of  stakeholders  prefers  a  “well-to-wake”  approach  as 
that it takes into account not only emissions from the combustion of fuel on board the ship, 
but  also  upstream  emissions  from  production,  transport,  and  distribution  of  fuels.  As 
regards  ships  at  berth,  OPS  requirements  are  found  to  be  relevant  and  necessary  for 
achieving the decarbonisation objectives by most stakeholders. The information collected 
corresponded  in  general  to  the  objectives  and  expectations  of  the  consultation  activities 
defined for each stakeholder. The results have helped shape the assessment of impacts and 
the choice of policy options and policy measures.  

103 

 
 
 
 
 
Annex 3: Who is affected and how? 

1.  PRACTICAL IMPLICATIONS OF THE INITIATIVE 

1.1.  Outlook of the preferred option implementation 

The  FuelEU  Maritime  initiative  aims  at  increasing  the  uptake  of  RLF  in  EU  maritime 
transport  with  a  view  to  reducing  emissions  from  the  sector  in  navigation  and  at  berth. 
Ensuring a more diverse fuel mix and a higher penetration of RLF is critical to ensure the 
sector’s  contribution  to  the  European  ambition  of  climate-neutrality  by  2050.  Reducing 
emissions from ships at berth is also particularly important to control air pollution in ports 
and port cities. 

The  preferred  policy  option  identified  in  the  context  of  the  impact  assessment,  policy 
option 3, is defined as a goal-based approach with a mechanism to reward overachievers. It 
envisages  a  compliance  and  enforcement  regime,  based  on  reporting  and  verification  of 
GHG intensity of on-board energy usage (metric expressed in CO2e/kWh). It will rely, to 
the extent possible, on the reporting requirements already included in the EU MRV scheme 
as well as the corresponding IT tool, THETIS-MRV. However, the amount of data required 
for  checking  compliance  with  this  initiative  will  be  different  as  it  will  cover  additional 
energy sources (not currently covered in EU MRV, such as electric propulsion) as well as 
additional  emissions  (well-to-tank  emission  factors  and  non-CO2  emissions  such  as  CH4 
and  N2O).  The  regulation  will  apply  equally  to  all  ships  above  5000  gross  tonnes, 
regardless  of  the  flag  they  are  flying,  during  the  voyages  involving  EU  ports:  intra-EU, 
extra-EU inbound and outbound. 

1.2. 

Implications on market operators and public authorities  

Ship operators are the stakeholder category mostly impacted by the proposed intervention 
as they are in practice the regulated entities. They will have to comply with the maximum 
GHG intensity limits for the energy used on board which will be set by the regulation and 
are  expected  to  apply  as  of  2025  and  be  gradually  strengthen  in  5-year  intervals. 
Compliance  will  be  determined  for  the  voyages  involving  EU  ports:  intra-EU,  extra-EU 
inbound  and  outbound.  Compliance  will  not  be  checked  on  voyage-per-voyage  basis  but 
on  an  annual  basis,  allowing  ship  operators  to  average  results  between  the  regulated 
voyages. They will also have the possibility to acquire excess compliance points generated 
by other ships or roll-over negative points for the next reporting period. Should that prove 
not possible, operators will have to pay a compensation amount to acquire their document 
of compliance.  

As  the  approach  under  the  preferred  policy  options  will  be  goal-based,  market  operators 
will enjoy full flexibility as regard the type of RLF they wish to use to meet the regulatory 
targets. They would also be free to bunker the compliance fuels outside the EU provided 

104 

 
 
that its GHG performance can be certified in accordance with the applicable criteria. The 
compliance  costs  will  therefore  result  in  a  gradual  increase  of  fuel  costs  as  well  as  an 
increase  in  capital  costs  (resulting  from  the  deployment  of  new,  innovative,  propulsion 
systems) compared to the baseline. The compliance costs are distributed over time and are 
expected to gradually increase in line with the further penetration of RLF in the fuel mix. 
This has also as consequence that the compliance costs are more limited in the early phases 
of the intervention; the overall costs increase for ship operators are estimated to be around 
2.7% by 2030 and up to 17.4% by 2050 in PO3. 

Ports  will  be  indirectly  impacted  by  the  proposed  regulatory  requirements  as  they  will 
have  to  ensure  access  to  bunkering  infrastructure  for  marine  RLF.  However,  policy 
intervention  under  FuelEU  Maritime  will  not  directly  require  ports  to  install  specific 
infrastructure  (such  requirements  are  set  by  the  EU  Alternative  Fuel  Infrastructure 
Directive,  which  also  is  currently  being  reviewed).  It  is  also  worth  noting  here  that  the 
bunkering  offer  can  be  an  element  of  competition  among  ports.  In  practice,  most  of  the 
investments  for  ports  are  likely  to  result  in  the  provision  of  OPS  connection  for  ships  at 
berth, focussing initially on container ships, passenger ships and ro-pax vessels, as well as, 
in  the  longer-term,  the  provision  of  specific  infrastructure  dedicated  to  hydrogen  or 
ammonia. In order to guarantee the safe handling of fuels and bunkering operations, ports 
are  expected  to  develop  relevant  provisions  into  their  port  rules  and  port  bye-laws, 
accounting for the different dimensions of alternative fuels/OPS deployment. This will be a 
role of the port authorities in close cooperation with port administrations. Whilst doing so, 
port authorities are expected to  follow  existing regulations and best-practice  guidance, at 
EU or international level. Considering the existence of such instruments, and the fact that 
the 
mainly  port  authorities  will  develop  national 
administrative  cost 
the  ports/port 
administrations/port operators. 

impact  significantly  on 

is  not  expected 

level  regulatory 

framework, 

to 

In terms of administrative requirements, compliance will be demonstrated by operators 
through  the  submissions  of  additional  information  obligations  in  parallel  to  the  ones 
already existing for the EU MRV.  These concern in particular:  

  Annual  energy  compliance  plan:  Each  vessel  will  have  to  prepare  an  annual 
compliance plan, which describes which fuels and technologies the ship is planning 
to use. This plan builds on the EU MRV Monitoring plan.  

  Annual  energy  report:  The  annual  energy  report  is  the  calculation  of  the  annual 
GHG performance of the vessel’s energy production. It should be broken down to 
different  energy  sources/types  of  fuel.  In  practice  this  report  builds  upon  the  EU 
MRV  Emission  report  (incl.  type  of  fuel,  fuel  consumption  figures)  and  adds 
specific emission factors covering all regulated emissions on a well-to-wake basis. 
  OPS consumption: As part of the annual energy report, all ships have to register the 
exact amount of electricity consumed while at berth (i.e. replacing the fuel used at 

105 

 
 
berth  currently  reported  under  EU  MRV),  or  demonstrate  the  use  of  of  equally 
performant  alternative  (e.g.  batteries,  hydrogen  etc.).  This  will  impact  mainly  the 
containerships, passenger ships and ro-pax vessels, who will be subject to specific 
OPS requirements at berth.    

The  following  actions  result  from 
requirements:  

the  above  mentioned  additional 

information 

  Prepare and submit annual energy compliance plan (for the next year);  
  Prepare and submit annual energy report, including the OPS consumption (for the 

previous year);  

  Transfer  excess  or  negative  compliance  points  or  pay  compensation  amount  if 

needed;  

  Carry document of compliance with the regulatory requirements;  
  Cooperate during audits/inspections.  

Similarly to the verification cycle established for the MRV Regulation, compliance checks 
will have to be made by an accredited verifier, which will issue, on that basis, a document 
of compliance. In terms of compliance cycle, ships will have up to 6 months following the 
reported  year  to  receive  their  document  of  compliance.  Within  the  deadlines  specified  in 
the EU MRV Regulation, they will have to submit all relevant information to the verifier 
(e.g.  proof  of  fuel  consumption  during  the  regulated  journeys,  type  of  fuel  used,  fuel 
certificates, etc.) so that it can check performance against the target. 

Indirectly,  marine  equipment  providers  will  be  able  to  further  strengthen  their  strong 
competitive  position  as  they,  together  with  European  yards,  are  developing  techniques 
needed  to  use  alternative  fuels.  Especially  the  engine  and  propulsion  systems  needed  for 
alternative fuels  are currently developed by leading EU companies. As a result, the legal 
initiative is expected be a stimulus for research and development in such technologies. 

Fuel suppliers will also be indirect impacted by the regulatory requirements as they will 
have to  certify marine RLF reflecting upstream  emissions and sustainability criteria. The 
certification requirements will build on existing provisions and sustainability criteria in the 
RED, as well as the existing certification scheme such as the International Sustainability & 
Carbon Certification (ISCC) Scheme148. As bunkering may not be limited to the EU, it is 
difficult to assess to which degree EU fuel suppliers will be impacted. However, based on 
existing  literature  and  already  existing  comparable  systems,  these  are  anticipated  not  to 
have  significant  impact  on  the  price  of  RLF  and  illustrative  cost  estimates  have  been 
provided in Section 6.1.2. 

148 https://www.iscc-system.org/process/overview/ 

106 

 
 
                                                           
The impact of national administrations is expected to remain very limited. As the system 
is  building  on  the  existing  MRV  one,  it  is  also  expected  to  rely  on  the  existing  IT  tool, 
THETIS-MRV, which should  be enhanced to  handle the new information /  data streams. 
This will be done at EU-level. Most of the compliance check will in practice be done by 
third-party verifiers which will be audited / controlled on a regular basis. The document of 
compliance will be registered electronically and the system will allow a rapid identification 
of  non-compliant ships.  The need for additional Port State Control inspections is therefore 
considered limited.  

2.  SUMMARY OF COSTS AND BENEFITS 

Table 28 Overview of benefits 

I. Overview of Benefits (total for all provisions) – Preferred Option – PO3 (relative to the baseline, expressed as present 
value over 2021-2050) 

Description 

Amount 

Comments 

Reduction of external costs 
related to air pollution 
relative to the baseline 
(i.e. present value over 
2021-2050)  

Reduction of external costs 
related to GHG emissions 
relative to the baseline 
(i.e. present value over 
2021-2050)  

Increased use of innovative 
fuels and propulsion 
technologies 

Reduced operation costs for 
ship operators relative to the 
baseline (i.e. present value 
over 2021-2050) 

Table 29 Overview of costs 

Direct benefits 

EUR 10.0 billion 

EUR 138.6 billion 

Direct benefit to society at large. It is the effect of the reduction 
of air pollution from ships resulting from the use of cleaner fuels 
and propulsion solutions. For instance, NOx and PM10 emissions 
associated to maritime transport are projected to decrease by 27% 
by 2050 relative to the baseline. These also include savings 
related to air pollution resulting from the use of OPS (or equally 
performant alternative) by the most polluting ships at berth 
(container ships, passenger ships and ro-pax vessels).  

Direct benefit to society at large. These savings result directly 
from the gradual decrease of the GHG intensity of fuels used on-
board as well as to a modest reduction in the transport activity (-
2.7% by 2050 compared to the baseline). 

Significant increase of innovative propulsion in the fleet reaching 
18.9% of fuel cell-powered vessels and 5.4% of electric 
propulsion by 2050 (compared to no penetration of these 
technologies in the baseline).  

Indirect benefits 

EUR 2.3 billion 

The main beneficiary group will be the ship operators. The 
reduction in operation costs result from lower maintenance and 
crew costs. Some of this reduction will also be partly driven by 
lower transport activity relative to the baseline. 

II. Overview of costs – Preferred option – PO3 (relative to the baseline, expressed as present value over 2021-2050) 

Citizens/Consumers  

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

Compliance 
costs resulting 

Direct costs 
(relative to 

Impact on 
consumer prices 

EUR 89.7 billion 
for ship operators 

107 

 
 
 
 
 
 
 
 
 
 
 
expected to be 
limited (as 
freight rates 
increase remain 
contained)  

from the 
introduction of 
the GHG 
intensity 
targets of on-
board energy 
usage 

Administrative 
and 
enforcement 
costs 

the baseline 
in present 
value over 
2021-2050)  

Indirect 
costs 
(relative to 
the baseline 
in present 
value over 
2021-2050) 

Direct costs 
(relative to 
the baseline 
in present 
value over 
2021-2050) 

Indirect 
costs 
(relative to 
the baseline 
in present 
value over 
2021-2050) 

covering capital 
costs (EUR 
25.8bn) and fuel 
costs (EUR 
63.9bn) 

EUR 5.7 billion 
for ports to 
provide the 
necessary 
infrastructure 
(OPS and 
hydrogen-related) 

EUR 439.7 
million resulting 
from additional 
information 
obligations, 
cooperation 
during audits and 
inspections and 
crew training. 

EUR 82 million 
for verification 
and approval 

EUR 1.8 million 
resulting from the 
establishment of 
guidelines by 
ports to guarantee 
safe handling of 
RLF. 

Fuel certification 
costs could not be 
quantified but 
based on existing 
literature and 
similar systems 
are expected   not 
to have 
significant impact 
on the price of 
RLF 

EUR 1 million 
for additional 
time during 
audits/inspecti
ons 

EUR 0.5 
million to 
adapt the IT 
system for 
reporting and 
compliance 
checks (EU 
budget) 

108 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Annex 4: Analytical methods 

1.  DESCRIPTION OF THE MODELLING TOOLS USED  

The  main  models  used  for  developing  the  baseline  scenario  for  this  initiative  are  the 
PRIMES  and  PRIMES-TREMOVE  models  (including  their  PRIMES-Maritime  module). 
These models  have  a successful  record of use in the Commission's  energy, transport and 
climate  policy  assessments.  In  particular,  they  have  been  used  for  the  impact  assessment 
accompanying 
the  Staff  Working  Document 
accompanying  the  Sustainable  and  Smart  Mobility  Strategy,  the  Commission’s  proposal 
for  a  Long  Term  Strategy150  as  well  as  for  the  2020  and  2030  EU’s  climate  and  energy 
policy  framework.  In  addition,  the  POLES-JRC151  model  has  been  used  for  the  world 
energy price projections and the GEM-E3 model152 for the macro-economic developments 
by sector of activity, used in the baseline scenario. 

the  2030  Climate  Target  Plan149, 

Modelling of the policy options, in a consistent way with the scenarios prepared in support 
of  the  impact  assessment  accompanying  the  2030  Climate  Target  Plan  and  the  Staff 
Working Document accompanying the Sustainable and Smart Mobility Strategy, has been 
performed by E3Modelling with the PRIMES-Maritime transport module of PRIMES and 
PRIMES-TREMOVE. Specific analysis on the risk of carbon leakage in the introduction of 
extra-EU journeys in the scope of the policy options has been carried out by TRT with the 
TRUST model. The administrative costs for businesses and the costs for authorities draw 
on the impact assessment support study.153 

  The entire energy (energy demand, supply, prices and investments to the future) and 
transport systems, and all GHG emissions and removals from the EU economy 

  Time horizon: 1990 to 2070 (5-year time steps) 

  Geography: individually all EU Member States 

  Impacts: on the energy system (PRIMES and its satellite model on biomass), transport 

(PRIMES-TREMOVE and PRIMES-Maritime). 

The modelling suite has been continuously updated over the past decade. Updates include 
the  addition  of  a  new  buildings  module  in  PRIMES,  improved  representation  of  the 
electricity  sector,  more  granular  representation  of  hydrogen  (including  cross-border 

149  SWD/2020/176 final 
150  https://ec.europa.eu/clima/sites/clima/files/docs/pages/com_2018_733_analysis_in_support_en_0.pdf  
151  The POLES-JRC model provides the global energy and climate policy context and is operated by the JRC. Source: 

https://ec.europa.eu/jrc/en/poles. 
152  Source: https://e3modelling.com/   
153  Ecorys and CE Delft (forthcoming), Assessment of impacts from accelerating the uptake of sustainable alternative 

fuels in maritime transport. 

109 

 
 
                                                           
trade154)  and  other  innovative  fuels,  improved  representation  of  the  maritime  transport 
sector,  as  well  updated  interlinkages  of  the  models  to  improve  land  use  and  non-CO2 
modelling. Most recently a major update was done of the policy assumptions, technology 
costs and macro-economic assumptions. 

PRIMES model 

The PRIMES model (Price-Induced Market Equilibrium System)155 is a large scale applied 
energy system model that provides detailed projections of energy demand, supply, prices 
and investment to the future, covering the entire energy system including emissions. The 
distinctive  feature  of  PRIMES  is  the  combination  of  behavioural  modelling  (following  a 
micro-economic  foundation)  with  engineering  aspects,  covering  all  energy  sectors  and 
markets.  The  model  has  a  detailed  representation  of  policy  instruments  related  to  energy 
markets and climate, including market drivers, standards, and targets by sector or overall. 
It  simulates  the  EU  Emissions  Trading  System  in  its  current  form.  It  handles  multiple 
policy  objectives,  such  as  GHG  emissions  reductions,  energy  efficiency,  and  renewable 
energy  targets,  and  provides  pan-European  simulation  of  internal  markets  for  electricity 
and gas.  

PRIMES offers the possibility of handling market distortions, barriers to rational decisions, 
behaviours and market coordination issues and it has full accounting of costs (CAPEX and 
OPEX) and investment on infrastructure needs. The model covers the horizon up to 2070 
in 5-year interval periods and includes all Member States of the EU individually, as well as 
neighbouring  and  candidate  countries.  PRIMES  is  designed  to  analyse  complex 
interactions within the energy system in a multiple agent – multiple markets framework.  

Decisions  by  agents  are  formulated  based  on  microeconomic  foundation  (utility 
maximization,  cost  minimization  and  market  equilibrium)  embedding  engineering 
constraints  and  explicit  representation  of  technologies  and  vintages;  optionally  perfect  or 
imperfect foresight for the modelling of investment in all sectors. 

PRIMES  allows  simulating  long-term  transformations/transitions  and  includes  non-linear 
formulation  of  potentials  by  type  (resources,  sites,  acceptability  etc.)  and  technology 
learning. Figure 10 shows a schematic representation of the PRIMES model. 

154  While cross-border trade is possible, the assumption is that there are no imports from outside EU as the opposite 

would require global modelling of hydrogen trade. 

155  More information and model documentation: https://e3modelling.com/modelling-tools/primes/  

110 

 
 
 
                                                           
Figure 10: Schematic representation of the PRIMES model 

It  includes  a  detailed  numerical  model  on  biomass  supply,  namely  PRIMES-Biomass, 
which  simulates  the  economics  of  supply  of  biomass  and  waste  for  energy  purposes 
through  a  network  of  current  and  future  processes.  The  model  transforms  biomass  (or 
waste) feedstock, thus primary feedstock or residues, into bio-energy commodities which 
undergo further transformation in the energy system e.g. as input into power plants, heating 
boilers  or  fuels  for  transportation.  The  model  calculates  the  inputs  in  terms  of  primary 
feedstock of biomass and waste to satisfy a given demand for bio-energy commodities and 
provides  quantification  of  the  required  production  capacity  (for  plants  transforming 
feedstock  into  bioenergy  commodities).  Furthermore,  all  the  costs  resulting  from  the 
production  of  bioenergy  commodities  and  the  resulting  prices  are  quantified.  The 
PRIMES-Biomass  model  is  a  key  link  of  communication  between  the  energy  system 
projections  obtained  by  the  core  PRIMES  energy  system  model  and  the  projections  on 
agriculture,  forestry  and  non-CO2  emissions  provided  by  other  modelling  tools  (CAPRI, 
GLOBIOM/G4M, GAINS).  

111 

 
 
 
PRIMES  is  a  private  model  maintained  by  E3Modelling156,  originally  developed  in  the 
context of a series of research programmes co-financed by the European Commission. The 
model  has  been  successfully  peer-reviewed,  most  recently  in  2011157;  team  members 
regularly  participate  in  international  conferences  and  publish  in  scientific  peer-reviewed 
journals. 

Sources for data inputs 

A summary of database sources, in the current version of PRIMES, is provided below: 

•  Eurostat  and  EEA:  Energy  Balance  sheets,  Energy  prices  (complemented  by  other 
sources,  such  IEA),  macroeconomic  and  sectoral  activity  data  (PRIMES  sectors 
correspond to NACE 3-digit classification), population data and projections, physical 
activity  data  (complemented  by  other  sources),  CHP  surveys,  CO2  emission  factors 
(sectoral  and  reference  approaches)  and  EU  ETS  registry  for  allocating  emissions 
between ETS and non ETS 

•  Technology  databases:  ODYSSEE-MURE158,  ICARUS,  Eco-design,  VGB  (power 
technology costs), TECHPOL – supply sector technologies, NEMS model database159, 
IPPC BAT Technologies160 

•  Power Plant Inventory: ESAP SA and PLATTS 
•  RES  capacities,  potential  and  availability:  JRC  ENSPRESO161,  JRC  EMHIRES162, 

RES ninja163, ECN, DLR and Observer, IRENA 
•  Network infrastructure: ENTSOE, GIE, other operators 
•  Other  databases:  District  heating  surveys  (e.g.  from  COGEN),  buildings  and  houses 
statistics  and  surveys  (various  sources,  including  ENTRANZE  project164,  INSPIRE 
archive, BPIE165), JRC-IDEES166, update to the EU Building stock Observatory167 

PRIMES-TREMOVE model  

The PRIMES-TREMOVE transport model projects the evolution of demand for passengers 
and  freight  transport,  by  transport  mode,  and  transport  vehicle/technology,  following  a 
formulation  based  on  microeconomic  foundation  of  decisions  of  multiple  actors. 
Operation,  investment  and  emission  costs,  various  policy  measures,  utility  factors  and 

156  E3Modelling (https://e3modelling.com/) is a private consulting, established as a spin-off inheriting staff, knowledge 
and  software-modelling  innovation  of  the  laboratory  E3MLab  from  the  National  Technical  University  of  Athens 
(NTUA).  

157  SEC(2011)1569 : https://ec.europa.eu/energy/sites/ener/files/documents/sec_2011_1569_2.pdf  
158  https://www.odyssee-mure.eu/  
159  Source: https://www.eia.gov/outlooks/aeo/info_nems_archive.php  
160  Source: https://eippcb.jrc.ec.europa.eu/reference/  
161  Source: https://data.jrc.ec.europa.eu/collection/id-00138   
162  Source: https://data.jrc.ec.europa.eu/dataset/jrc-emhires-wind-generation-time-series   
163  Source: https://www.renewables.ninja/   
164  Source: https://www.entranze.eu/   
165  Source:  http://bpie.eu/   
166  Source: https://ec.europa.eu/jrc/en/potencia/jrc-idees   
167  Source: https://ec.europa.eu/energy/en/eubuildings  

112 

 
 
                                                           
congestion  are  among  the  drivers  that  influence  the  projections  of  the  model.  The 
projections  of  activity,  equipment  (fleet),  usage  of  equipment,  energy  consumption  and 
emissions (and other externalities) constitute the set of model outputs.  

The PRIMES-TREMOVE transport model can therefore provide the quantitative analysis 
for the transport sector in the EU, candidate and neighbouring countries covering activity, 
equipment, energy and emissions. The model accounts for each country separately which 
means  that  the  detailed  long-term  outlooks  are  available  both  for  each  country  and  in 
aggregate forms (e.g. EU level). 

In  the  transport  field,  PRIMES-TREMOVE  is  suitable  for  modelling  soft  measures  (e.g. 
eco-driving,  labelling);  economic  measures  (e.g.  subsidies  and  taxes  on  fuels,  vehicles, 
emissions; ETS for transport when linked with PRIMES; pricing of congestion and other 
externalities  such  as  air  pollution,  accidents  and  noise;  measures  supporting  R&D); 
regulatory  measures  (e.g.  CO2  emission  performance  standards  for  new  light  duty  and 
heavy duty vehicles; EURO standards on road transport vehicles; technology standards for 
non-road  transport  technologies,  deployment  of  Intelligent  Transport  Systems)  and 
infrastructure  policies  for  alternative  fuels  (e.g.  deployment  of  refuelling/recharging 
infrastructure for electricity, hydrogen, LNG, CNG). Used as a module that contributes to 
the  PRIMES  model  energy  system  model,  PRIMES-TREMOVE  can  show  how  policies 
and  trends  in  the  field  of  transport  contribute  to  economy-wide  trends  in  energy  use  and 
emissions. Using data disaggregated per Member State, the model can show differentiated 
trends across Member States.  

The  PRIMES-TREMOVE  has  been  developed  and  is  maintained  by  E3Modelling,  based 
on,  but  extending  features  of,  the  open  source  TREMOVE  model  developed  by  the 
TREMOVE168  modelling  community.  Part  of  the  model  (e.g.  the  utility  nested  tree)  was 
built  following  the  TREMOVE  model.169  Other  parts,  like  the  component  on  fuel 
consumption and emissions, follow the COPERT model. 

PRIMES-Maritime model  

The  maritime  transport  model  is  a  specific  sub-module  of  the  PRIMES  and  PRIMES-
TREMOVE models and aiming to enhance the representation of the maritime sector within 
the  energy-economy-environment  modelling  nexus.  The  model,  which  can  run  in  stand-

168  Source: https://www.tmleuven.be/en/navigation/TREMOVE    
169  Several  model  enhancements  were  made  compared  to  the  standard  TREMOVE  model,  as  for  example:  for  the 
number of vintages (allowing representation of the choice of second-hand cars); for the technology categories which 
include vehicle types using electricity from the grid and fuel cells. The model also incorporates additional fuel types, 
such  as  biofuels  (when  they  differ  from  standard  fossil  fuel  technologies),  LPG,  LNG,  hydrogen  and  e-fuels.  In 
addition, representation of infrastructure for refuelling and recharging are among the model refinements, influencing 
fuel choices. A major model enhancement concerns the inclusion of heterogeneity in the distance of stylised trips; the 
model  considers  that  the  trip  distances  follow  a  distribution  function  with  different  distances  and  frequencies.  The 
inclusion  of  heterogeneity  was  found  to  be  of  significant  influence  in  the  choice  of  vehicle-fuels  especially  for 
vehicles-fuels with range limitations. 

113 

 
 
                                                           
alone  and/  or  linked  mode  with  PRIMES  and  PRIMES-TREMOVE,  produces  long-term 
energy and emission projections, until 2070, separately for each EU Member-State. 

The coverage of the model includes the European intra-EU maritime sector as well as the 
extra-EU  maritime  shipping.  The  model  covers  both  freight  and  passenger  international 
maritime.  PRIMES-Maritime  focuses  only  on  the  EU  Member  State,  therefore  trade 
activity between non-EU countries is outside the scope of the model. The model considers 
the  transactions  (bilateral  trade  by  product  type)  of  the  EU-Member  States  with  non-EU 
countries and aggregates these countries in regions. Several types and sizes of vessels are 
considered. 

PRIMES-Maritime  features  a  modular  approach  based  on  the  demand  and  the  supply 
modules.  The  demand  module  projects  maritime  activity  for  each  EU  Member  State  by 
type  of  cargo  and  by  corresponding  partner.  Econometric  functions  correlate  demand  for 
maritime  transport  services  with  economic  indicators  considered  as  demand  drivers, 
including  GDP,  trade  of  energy  commodities  (oil,  coal,  LNG),  trade  of  non-energy 
commodities, international  fuel  prices, etc. The supply module simulates a representative 
operator controlling the EU fleet, who offers the requested maritime transport services. The 
operator  of  the  fleet  decides  the  allocation  of  the  vessels  activity  to  the  various  markets 
(representing  the  different  EU  MS)  where  different  regulatory  regimes  may  apply  (e.g. 
environmental zones). The fleet of vessels disaggregated into several categories is specific 
to  cargo  types.  PRIMES-Maritime  utilises  a  stock-flow  relationship  to  simulate  the 
evolution of the fleet of vessels throughout the projection period and the purchasing of new 
vessels. 

PRIMES-Maritime solves a virtual market equilibrium problem, where demand and supply 
interact dynamically in each consecutive time period, influenced by a variety of exogenous 
policy  variables,  notably  fuel  standards,  pricing  signals  (e.g.  ETS),  environmental  and 
efficiency/operational  regulations  and  others.  The  PRIMES-Maritime  model  projects 
energy consumption by fuel type and purpose as well as CO2, methane and N2O and other 
pollutant  emissions.  The  model  includes  projections  of  costs,  such  as  capital,  fuel, 
operation  costs,  projections  of  investment  expenditures  in  new  vessels  and  negative 
externalities from air pollution. 

The  model  serves  to  quantify  policy  scenarios  supporting  the  transition  towards  carbon 
neutrality.  It  considers  the  handling  of  a  variety  of  fuels  such  as  fossil  fuels,  biofuels 
(bioheavy170,  biodiesel,  bio-LNG),  synthetic  fuels  (synthetic  diesel,  fuel  oil  and  gas,  e-
ammonia and e-methanol) produced  from  renewable electricity, hydrogen produced  from 
renewable  electricity  (for  direct  use  and  for  use  in  fuel  cell  vessels)  and  electricity  for 
electric  vessels.  Well-To-Wake  emissions  are  calculated  thanks  to  the  linkage  with  the 
PRIMES energy systems model which derives ways of producing such  fuels.  The model 

170   Bioheavy refers to bio heavy fuel oil.  

114 

 
 
                                                           
also  allows  to  explore  synergies  with  Onshore  Power  Supply  systems.  Environmental 
regulation,  fuel  blending  mandates,  GHG  emission  reduction  targets,  pricing  signals  and 
policies  increasing  the  availability  of  fuel  supply  and  supporting  the  alternative  fuel 
infrastructure are identified as drivers, along fuel costs, for the penetration of new fuels. As 
the model is dynamic and handles vessel vintages, capital turnover is explicit in the model 
influencing the pace of fuel and vessel substitution.  

Data inputs 

The main data sources for inputs to the PRIMES-Maritime model, such as for activity and 
energy  consumption,  comes  from  EUROSTAT  database  and  from  the  Statistical 
Pocketbook  "EU transport in  figures171. Other data  comes from different  sources  such as 
research projects (e.g. TRACCS project) and reports. PRIMES-Maritime being part of the 
overall  PRIMES  and  PRIMES-TREMOVE 
the 
EUROSTAT  energy  balances  and  transport  activity;  hence  the  associated  CO2  emissions 
are  assumed  to  derive  from  the  combustion  of  these  fuel  quantities.  The  model  has  been 
adapted  to  reflect  allocation  of  CO2  emissions  into  intra-EU,  extra-EU  and  berth,  in  line 
with  data  from  the  MRV  database.172  For  air  pollutants,  the  model  draws  on  the  EEA 
database. 

transport  model 

is  calibrated 

to 

In  the  context  of  this  exercise,  the  PRIMES-Maritime  model  is  calibrated  to  2005,  2010 
and 2015 historical data. 

TRUST maritime network model 

Maritime transport supply: TRUST maritime network includes the main ports throughout 
Europe, including all ports belonging to the TEN-T core network. Notional maritime links 
provide  sea  routes  to  link  ports  and  allows  the  model  to  compute  travel  distances  of 
maritime  connections.  Using  these  links  each  port  is  at  least  in  principle  linked  to  each 
other.  

Maritime  ports  are  classified  into  three  categories:  bulk  (BLK)  ports,  container  (UNT) 
ports and general cargo (GCG) ports. Most of the ports belong to more than one category 
but some ports have only one or two specialisations. These ports can host only demand for 
those freight segments (e.g. if one port is classified only as a bulk port, routes for general 
cargo and container demand cannot go through that port). 

171  Source: https://ec.europa.eu/transport/facts-fundings/statistics_en  
172  https://mrv.emsa.europa.eu/#public/eumrv 

115 

 
 
                                                           
Figure 11: Seaports and sea routes in the TRUST maritime network model 

The  ship  mode  has  to  be  accessed  through  feeder  modes  (road,  rail  or  inland  waterway 
according  to  existing  infrastructures).  As  a  consequence,  rail  and  road  networks  are  also 
used in the TRUST maritime model as well as inland waterways because trains, barges and 
trucks  are  used  as  feeder  modes  to  connect  internal  zones  with  ports  and  allow  the 
definition of full path between origin and final destination of freight. Connections between 
ports and inland networks are also part of the network. 

Maritime  transport  demand:  maritime  demand  consists  of  Origin-Destination  matrices 
segmented according to  the three freight categories of bulk,  container and general  cargo. 
Matrices  are  in  terms  of  thousand  tonnes  per  year.  Each  segment  of  demand  has  its 
autonomous matrix that is assigned independently to the network. 

TRUST maritime network model is a private model developed and maintained by TRT173. 
It is part of the TRUST transport network model for the assignment of Origin-Destination 
matrices at the NUTS3 level for passenger and freight demand for the whole Europe and 
neighbouring countries.174 

173  Source : http://www.trt.it/wp/wp-content/uploads/2016/09/TRUST-model-detailed-description-1.pdf   
174  TRUST  model,  in  connection  with  ASTRA,  has  been  used  for  several  impact  assessment  support  studies 
commissioned by EC (e.g. Support Study for the Impact Assessment accompanying the revision of the Eurovignette 
Directive (1999/62/EC), Study on the deployment of C-ITS in Europe) and other studies (e.g. The impact of TEN-T 

116 

 
 
 
                                                           
 
Figure 12: Intermodal connection at ports in the TRUST maritime network model 

Data inputs 

The main data sources for inputs to the TRUST model are the EUROSTAT database and 
the Statistical  Pocketbook  "EU transport in  figures175, TENtec  Information system176 and 
ETISplus database. 

2.  BASELINE SCENARIO 

Main assumptions of the Baseline scenario 

The  baseline  scenario  used  in  this  impact  assessment  builds  on  the  baseline  scenario 
underpinning the impact assessment accompanying the 2030 Climate Target Plan and the 
staff working document accompanying the Sustainable and Smart Mobility Strategy, but it 
additionally  considers  the  impacts  of  the  COVID-19  pandemic  and  the  National  Energy 
and Climate Plans.   

Economic  assumptions:  The  modelling  work  is  based  on  socio-economic  assumptions 
describing  the  expected  evolution  of  the  European  society.  Long-term  projections  on 
population  dynamics  and  economic  activity  form  part  of  the  input  to  the  energy  and 
transport model and are used to estimate transport activity and energy demand in transport. 
Population projections from Eurostat177 are used to estimate the evolution of the European 
population  that  is  projected  to  change  very  little  in  total  number  in  the  coming  decades. 

completion on growth, jobs and the environment, Sustainable Transport Infrastructure Charging and Internalisation of 
Transport Externalities). 

175  Source: https://ec.europa.eu/transport/facts-fundings/statistics_en  
176  https://ec.europa.eu/transport/themes/infrastructure-ten-t-connecting-europe/tentec-information-system_en 
177  Source: https://ec.europa.eu/eurostat/web/population-demography-migration-projections/population-projections-data  

117 

Connector linksRoad linksRail linksIntermodal connectionCentroidRoad nodeRail nodeMaritime nodes 
 
 
 
                                                                                                                                                                                
Macro-economic  projections  draw  on  DG  ECFIN.178  In  particular,  the  Commission’s 
Spring Economic Forecast 2020 projected that the EU economy would contract by 7.4% in 
2020  and  pick  up  in  2021  with  growth  of  6.1%.  By  2030,  real  GDP  in  2030  could  be 
approximately  2.3%  lower  compared  to  the  pre-COVID  estimates,  based  on  the  Autumn 
Forecast 2019. 

Energy  prices  assumptions:  The  COVID  pandemics  has  had  a  major  impact  on 
international fuel prices. As a large part of the world went into lockdown, fossil fuel prices 
collapsed  with  crude  oil  spot  prices  halved  compared  to  last  year  levels.  The  oil  price  is 
projected to gradually recover over time, reaching 80USD/bbl in 2030 and 118USD/bbl in 
2050.  It  is  however  projected  to  remain  below  the  projected  pre-COVID-19  pandemic 
levels.179 Figure 13 shows the fuel prices projections used in the baseline scenario. 

Figure 13: International fuel prices assumptions  

in USD'15 per boe 

Oil 

Gas (NCV) 

in €'15 per boe 

Oil 

Gas (NCV) 

‘15 

52.3 

43.7 

‘15 

47.2 

38.7 

‘30 

80.1 

40.9 

‘30 

72.2 

36.2 

‘40 

97.4 

52.6 

‘40 

87.8 

46.6 

‘50 

117.9 

57.8 

‘50 

106.3 

51.2 

Source: Derived from JRC, POLES-JRC model, Global Energy and Climate Outlook (GECO) 

Technology  assumptions:  Modelling  scenarios  on  the  evolution  of  the  energy  and 
transport  system  is  highly  dependent  on  the  assumptions  on  the  development  of 
technologies  -  both  in  terms  of  performance  and  costs.  For  the  purpose  of  the  impact 
assessments related to the “Climate Target Plan” and the “Fit for 55” policy package, these 
assumptions  have  been  updated  based  on  a  rigorous  literature  review  carried  out  by 
external consultants in collaboration with the JRC.  

Continuing  the  approach  adopted  in  the  long-term  strategy  in  2018,  the  Commission 
consulted technology assumption with stakeholders in 2019. In particular, the technology 
database  of  the  main  model  suite  (PRIMES,  PRIMES-TREMOVE,  GAINS,  GLOBIOM, 
and  CAPRI)  benefited  from  a  dedicated  consultation  workshop  held  on  11th  November 

178  The long-term evolution of economic activity was estimated from three sources: DG ECFIN’s short term economic 
forecast, updated t+10 projections up to 2029 and the 2018 Aging Report projections elaborated by the European 
Commission. For the short-term (2020-2021), the projections are based on growth forecast by the Directorate General 
for Economic and Financial Affairs (Spring 2020 Economic Forecast). Projections up to 2029 use the associated t+10 
work from DG ECFIN, which is based on projections of potential output growth and a closure of output gap in the 
medium term. The long-term per capita GDP growth projections of the 2018 Ageing Report are used for the period 
2030-2050, available at: https://ec.europa.eu/info/publications/economy-finance/2018-ageing-report-economic-and-
budgetary-projections-eu-member-states-2016-2070_en 

179  Communication from the Commission ‘Stepping up Europe’s 2030 climate ambition - Investing in a climate-neutral 

future for the benefit of our people’, COM(2020) 562 final. 

118 

 
 
                                                           
2019. EU Member States representatives had also the opportunity to comment on the costs 
elements  during  a  workshop  held  on  25th  November  2019.  The  updated  technology 
assumptions are published together with the EU Reference Scenario 2020. 

Policies included in the Baseline scenario 

The  Baseline  scenario  projects  developments  under  the  current  EU  and  national  policy 
framework.  It  embeds  in  particular  the  EU  legislation  in  place  to  reach  the  2030  climate 
target of at least 40% compared to 1990, as well as national contributions to reaching the 
EU 2030 energy targets on Energy efficiency and Renewables under the Governance of the 
Energy Union. It thus gives a detailed picture of where the EU economy and energy system 
in  particular  would  stand  in  terms  of  GHG  emission  if  the  policy  framework  were  not 
updated  to  enable  reaching  the  revised  2030  climate  target  to  at  least  -55%  compared  to 
1990 proposed under the Climate Target Plan180. 

In  addition  to  the headline targets,  some of the  policies included in  the baseline scenario 
are: 

  For maritime shipping, in addition to emissions being monitored under the Regulation 
on  Monitoring,  Reporting  and  Verification  of  Maritime  Emissions181,  the  Baseline 
scenario  reflects  the  Energy  Efficiency  Design  Index  (EEDI)  and  the  Ship  Energy 
Efficiency  Management  Plan  (SEEMP)  adopted  by  the  International  Maritime 
Organisation, as well as the Sulphur Directive.  

  The  EU  Emissions  Trading  System182  (EU  ETS)  covers  45%  of  EU  GHG  emissions, 
notably  from  industry,  the  power  sector  and  aviation.  Emissions  for  the  sectors  under 
the  system  are  capped  to  reduce  by  43%  by  2030  compared  to  2005.  The  baseline 
scenario additionally assumes that the Market Stability Reserve (MSR) will ensure that 
the  ETS  contributes  to  the  achievement  of  the  overall  target  cost-effectively.  MSR 
functioning is set to be reviewed183 in 2021 and every five years after to ensure its aim 
of tackling structural supply-demand imbalances. 

  Aviation emissions are also covered by the EU ETS. The EU, however, decided in 2014 
to  limit  the  scope  of  the  EU  ETS  to  flights  within  the  EEA  until  2016  to  support  the 
development  of  a  global  measure  by  the  International  Civil  Aviation  Organization 
(ICAO).184 In light of the adoption of a Resolution by the 2016 ICAO Assembly on the 
global measure, the EU  has  decided to maintain  the  geographic scope of  the EU  ETS 
limited  to  intra-EEA  flights  from  2017  until  the  end  of  2023.185  The  EU  ETS  for 
aviation is subject to a new review in the light of the international developments related 

180   COM/2020/562 final 
181  Regulation (EU) 2015/757 
182  Directive 2003/87/EC 
183  Decision (EU) 2015/1814 
184  Regulation (EU) 421/2014 
185  Regulation (EU) 2017/2392 

119 

 
 
                                                           
to  the  operationalisation  of  CORSIA.  This  review  considers  how  to  implement  the 
global  measure  in  Union  law  through  a  revision  of  the  EU  ETS  legislation.  In  the 
absence of a new amendment, the EU ETS would revert back to its original full scope 
from 2024.  

  For  aviation,  in  addition  to  implementation  of  the  EU  Emission  Trading  Scheme,  the 
Baseline  reflects  the  Union-wide  air  transport  performance  targets  for  the  key 
performance  area  of  environment,  Clean  Sky,  Single  European  Sky  and  SESAR,  and 
aircraft CO2 emissions standards, as part of the so-called “basket of measures” that aim 
to reduce emissions from the sector.  

  The revised Renewable Energy Directive186 entered into force in 2018. It establishes a 
new binding renewable energy target for the EU for 2030 of at least 32%, with a clause 
for a possible upwards revision by 2023. 

  The  Fuel  Quality  Directive187  requires  a  reduction  of  the  GHG  intensity  of  transport 

fuels by a minimum of 6% to be achieved by 2020. 

  CO2  emission  standards  for  new  cars  and  vans188  and  for  new  trucks189  have  been 
defined, and will contribute towards reducing emissions from the road transport sector. 
Besides  the  post-2020  CO2  standards  for  new  light  duty  and  heavy  duty  vehicles,  the 
Clean  Vehicles  Directive  and  the  Directive  on  the  deployment  of  alternative  fuels 
infrastructure  contribute  to  the  roll-out  of  recharging  infrastructure.  Furthermore,  the 
uptake of sustainable alternative fuels is supported by the Renewables Energy Directive 
and Fuel Quality Directive. Improvements in transport system efficiency (by making the 
most  of  digital  technologies  and  smart  pricing  and  further  encouraging  multi-modal 
integration and shifts towards more sustainable transport modes) are facilitated by e.g. 
the  TEN-T  Regulation  supported  by  CEF  funding,  the  fourth  Railway  Package,  the 
Directive  on  Intelligent  Transport  Systems,  the  European  Rail  Traffic  Management 
System  European  deployment  plan,  the  Regulation  establishing  a  framework  for  the 
provision  of  port  services,  and  others.  The  Baseline  also  accounts  for  other  initiatives 
addressing air pollution from inland waterways vessels, as well as road safety, and thus 
reducing the external costs of transport. 

  The  Effort  Sharing  Regulation190  (ESR)  sets  binding  annual  reduction  targets  for 
member  states,  with  an  aim  to  reduce  emissions  by  30%  compared  to  2005  by  2030. 
The ESR targets  are set  according to  national  wealth and cost-effectiveness.  The ESR 
allows for flexibilities such as transfers between member states.  

In  addition,  these  policies  will  continue  pushing  further  GHG  emissions  reduction,  and 
increasing  energy  savings  and  renewable  energies  deployment  after  2030,  either  because 

186  Directive 2018/2001/EU 
187  Directive 2009/30/EC 
188  Regulations (EU) 2019/631 
189  Regulation (EU) 2019/1242 
190  Regulation (EU) 2018/842 

120 

 
 
                                                           
they do not  have a "sunset  clause" (notably ETS, and since recently, Article 7 in  revised 
EED), or because of the technological learning and cost reductions that they are expected 
to  induce.  Moreover,  most  actions  in  the  energy  and  transport  system  have  long-term 
impacts.  The  baseline  captures  these  dynamics,  but  it  needs  to  be  emphasised  that  no 
intensification  of  policies  post-2030  was  assumed  and  no  target  for  GHG  emissions 
reduction in 2050 was set concerning climate neutrality.  

The  Baseline  scenario  considers  existing  national  policies  and  those  reflected  in  the 
National Energy and Climate Plans.  

The Baseline scenario models  the policies already  adopted, but  not  the target  of net-zero 
emissions  by  2050.  As  a  result,  there  are  no  additional  policies  introduced  driving 
decarbonisation after 2030. However, climate and energy policies are not rolled back after 
2030 and several of the measures in place today continue to deliver emissions reduction in 
the long term.   

Main results of the Baseline scenario 

EU freight transport activity for  inland modes is projected to  grow  at  a rate of 1.2% per 
year on average between 2015 and 2050, despite the significant impact of the COVID-19 
pandemic.  Growth  rates  per  mode  of  transport  would  however  be  different.  The  highest 
growth is projected in the rail freight transport, driven by the assumed completion of the 
TEN-T  core  network  by  2030  and  of  the  comprehensive  network  by  2050,  supported  by 
the CEF, Cohesion Fund and ERDF funding. Road freight transport would grow by 1.2% 
per year followed by inland navigation transport that is projected to grow by around 0.9% 
per year.   

The COVID-19 pandemic had a major impact on global shipping, affecting all its segments 
from passenger ships to container ships and oil tankers. About 30% of all goods in the EU 
are transported by ships. International maritime transport activity (intra and extra-EU) is 
projected  to  be  21%  lower  in  2020  relative  to  2015.  From  2021  onwards  however  it  is 
projected to start recovering and grow strongly by 2025 and beyond (i.e. 20% growth for 
2015-2030 and 50% for 2015-2050), due to the rising demand for primary resources and 
container  shipping.  Passsenger  shipping  activity  (i.e.  passenger  cruise  and  Ro-Pax)  has 
been affected more strongly than the freight shipping due to the travel restrictions linked to 
the COVID-19 pandemic. Its activity is projected to be around 40% lower in 2020 relative 
to  2015  but  to  strongly  recover  from  2021  onwards.  Passenger  shipping  activity  is 
projected  to  grow  by  24%  during  2015-2030  and  by  54%  for  2015-2050  despite  the 
significant impact of the COVID-19 pandemic on the sector.   

The  baseline  scenario  projects  a  limited  uptake  of  biofuels  in  international  maritime  by 
2050 (0.1% in 2030 and 1.3% in 2050). No other type of renewable and low carbon fuels is 
foreseen  to  enter  the  international  maritime  fuel  mix  by  2050  without  further  EU  level 
intervention. Only a very small uptake of electricity (0.1% of the fuel mix) is projected by 
2030 and 2050 due to the on-shore power supply at berth.  

121 

 
 
The existing provisions of EU legislation (in particular the Sulphur Directive or the AFID), 
which could have encouraged the uptake of alternative fuels, in particular LNG, have not 
produced  yet  any  significant  uptake  of  new  sources  of  energy  in  maritime  transport. 
However, by 2050 LNG is projected to represent around 19% of the international maritime 
fuel  mix,  mainly  as  a  result  of  more  stringent  requirements  on  air  pollution  control  (in 
particular  SOx  and  NOx  emissions).  Even  though  the  GHG  benefits  of  LNG  remain 
modest (in particular due to possible methane slip) the technology provides a good solution 
to air pollution issues, allowing reductions in SOx and NOx emissions and, as a result, it 
represented  an  attractive  compliance  option  to  the  Sulphur  Directive.  In  the  longer  term, 
LNG can pave the way  to  the use of bio-LNG or e-gas, which would also offer  climate-
related benefits. In the Baseline scenario, the LNG-fuelled fleet is projected to be around 
5,100 by 2050. 

Figure 14 Projected evolution of EU27 international maritime transport activity in the Baseline scenario 

Source: PRIMES-Maritime model, E3Modelling  

Tank-to-wake  GHG  emissions  from  international  shipping  (including  CH4  and  N2O 
emissions from slippage) are projected to increase by 14% by 2030 and by 34% by 2050 
relative  to  2015.  This  is  driven  by  the  sustained  growth  projected  for  transport  activity, 
even  when  accounting  for  the  impact  of  the  COVID-19  pandemic,  and  despite  the 
significant  improvements  in  energy efficiency taking place over time.  On a well-to-wake 
basis, this is equivalent to 15% increase during 2015-2030 and 38% for 2015-2050. 

Total  transport  Tank-to-Wheel  CO2  emissions  (including  international  shipping)  are 
projected to decrease from approximately 994 Mtons in 2015 to about 888 Mtons in 2030 
and 713 Mtons in 2050, or by 11% and 28%, respectively. The reduction in CO2 emissions 
is primarily achieved in road transport due to the roll-out of efficient internal combustion 
engine vehicles and the uptake of electric vehicles, especially in the period after 2030, but 
also  due  to  the  shift  to  rail.  Specifically,  the  emissions  of  road  transport  are  projected  to 
decrease from 732 Mtons in 2015, to 588 Mtons in 2030 (or 20% compared to 2015) and to 
386  Mtons  in  2050  (or  47%  compared  to  2015).  Emissions  from  rail  transport  also 

122 

05,00010,00015,00020,00025,00020152020202520302035204020452050ContainersDry Bulk carriersGeneral Goods shipsTankers 
 
 
decrease, by 3 Mtons in 2050 (or 65% compared 2015). The reduction in these segments 
compensates for the increase of CO2 emissions in aviation, which from 120 Mtons in 2015, 
increases  to  140 Mtons  in  2030  (by  17%)  and  144  Mtons  in  2050  (by  21%),  and 
international shipping that increases its emissions by around 42 Mtons between 2015 and 
2050.  

Well-to-Wheel  (WTW)  emissions  (including  those  from  international  maritime)  are 
projected to follow a similar declining trend. In the Baseline scenario they decrease from 
1,118 Mtons CO2eq in 2015, to 1,019 Mtons CO2eq in 2030 and 838 Mtons CO2eq in 2050.  

The  Baseline  scenario  results  are  closely  aligned  to  those  of  the  EU  Reference  scenario 
2020. 

Figure 15 Reduction of Tank-to-Wheel CO2 emissions by transport segment in the EU27 between 2015 and 2050 in the 
Baseline scenario 

Source: PRIMES model, E3Modelling  

3.  METHODOLOGICAL APPROACH FOR MODELLING POLICY OPTIONS  

In Policy Option 1 the shares of renewable and low carbon fuels ‘in navigation’ by 2030 
and  2050  have  been  set  in  a  consistent  way  with  the  analysis  underpinning  the  MIX 
scenario of the 2030 Climate Target Plan and the Sustainable and Smart Mobility Strategy. 
This ensures consistency with the available fuel production capacity in the EU and reflects 
the expected levels of demand from other energy and transport sectors. It ensures that the 
feedstock  for  the  production  of  biofuels  and  bio-LNG  is  sufficient  for  satisfying  the 
demand from all sectors, including the maritime sector, by 2030 and 2050. It also ensures 
that sufficient production capacities are in place for ensuring the demand for e-fuels.  

The  evolution  of  the  overall  share  of  renewable  and  low  carbon  fuels  additionally  takes 
into  account  the  analysis  of  the  on  shore  power  requirements  at  berth,  which  was  not 
available  at  the  time  of  the  modelling  exercise  performed  for  the  impact  assessment 
underpinning  the  2030  Climate  Target  Plan.  Electricity  used  at  berth  is  projected  to 

123 

713 
 
 
 
represent  around  1.2%  of  the  total  energy  mix  in  2030  and  1%  by  2050  in  all  policy 
options, driven by the requirements for on-shore power supply at berth.  

Policy  Options  2  and  3  have  been  designed  to  achieve  comparable  well-to-wake  GHG 
emissions reductions over time with Policy Option 1, to  allow the comparability of costs 
and benefits. GHG performance of fuels/technologies is assessed on a well-to-wake basis, 
and is not limited to CO2, but also includes other GHG such as CH4 and N2O emissions. In 
addition,  the  well-to-tank  emission  factors  take  into  account  the  context  of  the  analysis 
underpinning  the  2030  Climate  Target  Plan,  where  the  power  generation  sector  is  set  to 
achieve  decarbonisation  by  2050.  The  fuel  mix  in  Policy  Options  2  and  3  have  been 
derived  to  achieve  comparable  emissions  reductions  with  those  in  Policy  Option  1.  This 
also ensures consistency with the analysis underpinning the 2030 Climate Target Plan. 

In addition, in Policy Option 3 when establishing the ships performance in achieving the 
yearly target, higher weight is attributed to zero-emission technologies. More specifically, 
GHG intensity of fuels is derived as the ratio between the GHG emissions and the energy 
use by type of fuel: 

𝐺𝐻𝐺𝐼𝑇 =

∑ 𝐺𝐻𝐺𝐼𝑥 ∙ 𝑘𝑊ℎ𝑥
𝑥
∑ 𝑘𝑊ℎ𝑥 ∙ 𝑀𝑥

𝑥

where:  

GHIGIT  stands  for  the  maximum  limit  on  the  GHG  content  of  energy  used  by 
ships; 

‘x’ means the fuel and energy types falling within the scope of this initiative;  

‘kWhx’ means the total energy use of fuel ‘x’ expressed in kWh; 

‘GHGix’ is the GHG intensity of fuel or energy ‘x’ expressed in gCO2eq/kWh; 

‘Mx’ represents the adjustment factor attributed to zero-emission technologies that 
should stimulate the introduction of zero-emissions energy solutions.  

In  the  modelling,  the  adjustment  factor  is  derived  in  such  a  way  that  it  increases  the 
competitiveness  of  zero-emission  technologies  (i.e.  e-fuels,  hydrogen,  electricity  used  in 
electric vessels) relative to that of advanced biofuels, when deciding in an endogenous way 
the contribution of the various technologies/fuels for achieving the GHG intensity targets 
in PO3. The cost competitiveness is measured in €/tCO2 mitigated (the numerator reflects 
the  additional  cost  of  each  pathway  relative  to  the  fossil  fuel  counterpart  and  the 
denominator the respective CO2 mitigated). In particular for hydrogen and electricity, the 
cost  competitiveness  numerator  also  includes  the  additional  capital  costs  related  to  the 
hydrogen fuel  cell and  electric vessels  compared to  the internal  combustion engine ones. 
Modelling results show that an adjustment factor of 1.5 would be needed for the uptake of 
synthetic liquids (in the 2030-2040 time horizon), while in the case of electric and fuel cell 
vessels,  adjustment factors in  the order of 3-4 are necessary.  It  should however be noted 

124 

 
 
 
that  these  adjustment  factors  would  also  depend  on  the  actual  evolution  of  the  costs  of 
zero-emission  technologies  over  time  (RLF  costs  and  capital  costs).  In  addition,  other 
measures  like  the  ETS  for  the  maritime  sector  may  also  have  an  impact  on  the  cost 
competitiveness of the zero-emission technologies.   

In terms of time horizon, the assessment has been undertaken for the 2025-2050 period (in 
five-year steps). The measures that are part of all policy options are assumed to start being 
implemented from 2025 onwards.  

The  price  projections  of  the  renewable  and  low  carbon  fuels  are  fully  embedded  in  the 
2030  Climate  Target  Plan  policy  context,  where  the  EU  economy  is  moving  towards 
carbon  neutrality  by  2050.  This  leads  to  strong  competition  for  biomass  feedstock  with 
other energy and transport sectors.  Feedstock and renewable  electricity  are considered to 
be  sourced  predominantly  in  the  EU,  in  order  to  support  the  reduction  in  energy 
dependence.  The  projected  prices  of  the  renewable  and  low  carbon  fuels  used  in  the 
international maritime sector for the purpose of this analysis are provided in Table 30. 

Table 30 Projected prices of the renewable and low carbon fuels used in the international maritime sector 

Fuel prices (€/toe) 

liquid fossil fuels 
LNG 
biofuels 
bio-LNG 
e-liquids 
e-gas 
electricity 
liquid hydrogen 
ammonia 

Source: PRIMES model, E3Modelling  

2030 

627 
608 
1301 
868 
2285 
2220 
1698 

2050 

861 
715 
1252 
978 
1658 
1238 
1665 
1467 
1467 

The price of biofuels used in international maritime remains relatively stable between 2030 
and 2050. Biofuels comprise of bioheavy and biodiesel and the price is weighted based on 
the relative shares of the biofuel quantities.191  

This assessment takes into account the current knowledge related to the possible evolution 
of  technology  costs  and  feedstock  costs.  If  higher  decrease  in  the  costs  of  e-fuels  would 
take place than assumed in this assessment, their uptake could be higher especially in PO2 
and PO3 due to their increased competitiveness relative to biofuels and bio-LNG. This is 

191   With respect to costs, the production costs of biofuels used in international maritime are lower compared to biofuel production costs 
used in other transport modes like aviation (by about 35% in 2030 and 25% in 2050, respectively). One explanation lies within the 
technology  portfolio,  that  for  international  maritime  biofuels  is  broader  than  that  of  biokerosene,  which  includes  only  ASTM 
certified  technologies.  For  international  maritime,  technologies  such  as  hydrothermal  liquefaction  and  upgrading  are  deployed 
which display lower production costs than, for instance, the Alcohol-to-Jet route. Secondly, fungible biodiesel and bioheavy are also 
used by sectors other than maritime, and therefore technologies are deployed driven by a broader demand than that of international 
maritime. The model exploits the learning-by-doing effects driven by the combined fuel deployment across all sectors, the benefits 
of which are indicated by lower capital and fixed costs, compared to the biokerosene routes. 

125 

 
 
 
 
 
                                                           
because PO2 and PO3 provides flexibility in terms of choice of the fuel mix. On the other 
hand, if the availability of biofuels and bio-LNG for the maritime sector would be lower, 
due  to  higher  demand  by  other  sectors,  a  higher  share  of  e-fuels  would  be  needed  to 
compensate for achieving the mandates in PO2 and PO3. In case the technology costs and 
feedstock costs would be higher than assumed in this assessment, this may results in higher 
fuel costs and subsequently freight rates.   

In modelling, the assumption was made that the RFNBOs only can fulfil the maritime e-
fuels  and  hydrogen  obligations  in  2030  and  afterwards,  which  is  in  line  with  the 
Renewable Energy Directive currently in force. Low-carbon electricity for production of e-
fuels could be considered in line with Energy System Integration Strategy. This may have 
impacts on some modelling results. 

The  well-to-wake  emission  factors  used  in  this  impact  assessment  are  provided  in  Table 
31.  

Table 31 Well-to-wake emission factors for fossil fuels and biofuels used in the analysis 

Well-to-wake emission factors (gCO2eq/MJ) 
Fossil fuels 
Diesel 
Fuel oil 
Natural gas 

Biofuels 

Biodiesel 

Bioheavy 

Biomethane 

Source: PRIMES model, E3Modelling  

2030 

2050 

88.4 
86.1 
75.1 

26.3 
26.3 

9.6 

88.4 
86.1 
75.1 

26.3 
26.3 

9.1 

4. 

IMPACT ON BIOMASS FEEDSTOCK AND RENEWABLE ELECTRICITY NEEDS 

Biofuels  supplied  to  international  maritime  include  biodiesel  and  bio-HFO.  Bio-LNG  is 
also included. Biofuels and bio-LNG are further classified into Annex IX Part A and Part 
B, depending to the type of feedstock used for their production in line with the definitions 
of Directive (EU) 2018/2001 Annex IX. Synthetic liquids refer to e-ammonia, e-methanol, 
synthetic diesel, synthetic fuel oil and clean gas.  

The volume and share of deployed biofuel and bio-LNG production pathways draw on the 
MIX scenario projections context of the PRIMES Biomass supply model, underpinning the 
analysis accompanying the 2030 Climate Target Plan. Results are presented for EU27, for 
2030 and 2050. 

Biofuels and bio-LNG consumption 

Biofuels and bio-LNG consumption, together, is projected to increase almost by a factor of 
10  between  2030  and  2050,  from  around  3  Mtoe  in  2030  up  to  32  Mtoe  in  2050.  The 
highest  supply is  projected in  PO2 (close to  32 Mtoe) and the lowest  in  PO1 (around 26 
Mtoe)  with  PO3  falling  in  between  (28  Mtoe).  In  their  vast  majority,  Annex  IX  Part A 

126 

 
 
 
 
  
  
(advanced  biofuels  and  bio-LNG)  would  be  supplied  to  the  maritime  sector  (more  than 
three-quarters of supply to the maritime sector in 2030 and 90% in 2050, similarly across 
policy  options).  Annex  IX  Part  B  biofuels  would  cover  the  remainder  of  the  biofuel 
demand.  Notably,  biofuels  imports  for  the  maritime  sector  are  projected  to  account  for 
around 1.5% in 2030 to 4% in 2050 of the total biofuel demand in the sector. These would 
be  biodiesel  imports  that  are  assumed  to  be  exclusively  Part  B  biofuels.  This  can  be 
regarded as a conservative assumption as Part A biofuels may also be imported instead.  

Table 32 Share of biofuels and bio-LNG consumption by type of feedstock (Annex IX Part A and Part B) 

Biofuels and bio-LNG consumption share  

PO1 

PO2 

PO3 

(%) 
Part A 
Part B 

imports (as part of total) 

Source: PRIMES Biomass model, E3Modelling 

Biomass feedstock consumption 

2030 
77% 
23% 

1.5% 

2050 
90% 
10% 

3.8% 

2030 
76% 
24% 

1.5% 

2050 
90% 
10% 

3.7% 

2030 
77% 
23% 

1.5% 

2050 
90% 
10% 

3.8% 

Annex  IX Part A type of feedstock (i.e. mainly lignocellulosic biomass) would represent 
more than 90% of feedstock used for maritime biofuel and bio-LNG production in EU27 
by  2030,  and  almost  99%  by  2050,  whilst  the  remainder  would  be  Part  B  types  of 
feedstock (mainly waste lipids such as used cooking oils). These shares do not consider the 
feedstock used outside the EU to produce the imported quantities of biofuels. It should also 
be noted that the conversion efficiency of Part B feedstock to Part B biofuels is higher than 
that  of  Part  A  feedstock  to  Part  A  biofuels  and  bio-LNG,  thereby  explaining  the  lower 
share  of  Part  A  biofuels  in  terms  of  final  product  (i.e.  90%  in  2050)  when  compared  to 
their share in terms of feedstock (i.e. 98.5% in 2050). 

Table 33 Biomass feedstock consumption by type of feedstock (Annex IX Part A and Part B) 

Feedstock consumption share 

PO1 

PO2 

PO3 

% 
Part A 

Part B 
Source: PRIMES Biomass model, E3Modelling 

2030 
92.1% 

7.9% 

2050 
98.5% 

1.5% 

2030 
92.0% 

8.0% 

2050 
98.4% 

1.6% 

2030 
92.0% 

8.0% 

2050 
98.4% 

1.6% 

By 2030, the vast majority of the feedstock used is projected to originate from forestry and 
from biomass waste flows, whether agricultural residues, wood waste or manure. By 2050, 
energy  crops  and  notably  dedicated  energy  crops  (annual  lignocellulosic  crops)  provide 
more  than  one-third  of  the  feedstock  required  to  produce  Part  A  biofuels.  Substantial 
growth  is  also  projected  in  agricultural  residues  used  for  biofuels  production  in 
international maritime that increase by more than a factor of 10 between 2030 and 2050. 

Table 34 Biomass feedstock consumption by type (in Mtonnes) 

Feedstock consumption 

PO1 

PO2 

PO3 

Mtonnes 
Part A 

2030 

2050 

2030 

2050 

2030 

2050 

127 

 
 
  
  
  
  
  
  
Perennial crops 
Annual crops 
Forestry products 
Forestry residues 
Wood waste 
Agricultural residues 
Manure 

Part B 

               0.0  
               0.3  
               3.1  
               1.4  
               1.8  
               1.5  
               1.2  

               6.3  
             33.6  
             14.4  
             11.7  
               6.7  
             15.4  
               2.8  

          0.0  
          0.3  
          3.2  
          1.5  
          1.8  
          1.5  
          1.2  

              7.7  
            40.8  
            18.4  
            14.7  
              8.0  
            18.6  
              3.3  

          0.0  
          0.3  
          3.1  
          1.5  
          1.8  
          1.5  
          1.2  

              6.9  
            36.4  
            15.9  
            12.8  
              7.2  
            16.8  
              3.0  

Non-agricultural oils 

             0.80  

               1.4  

        0.83  

              1.8  

        0.82  

              1.6  

Source: PRIMES Biomass model, E3Modelling 

Model projections show that EU has sufficient biomass available domestically to produce 
biofuels  and  bio-LNG  for  EU  international  maritime  sector.  By  2030,  there  is  sufficient 
supply of waste lipids (non-agricultural oils, such as used cooking oil), as the demand from 
international  maritime  requires  about  20%  of  the  feedstock  available  in  the  EU.  The 
remaining  feedstock  is  consumed  in  other  transport  sectors  such  as  road  transport  and 
aviation.  By  2050,  the  need  for  waste  lipids  to  produce  Part  B  biofuels  for  international 
maritime  increases,  and  as  a  result  the  sector  requires  higher  shares  of  the  available 
feedstock.  Part  A  biofuels  from  lignocellulosic  feedstock  consume  6  to  20%  of  the 
available feedstock potential  in  the EU by 2050, depending on the type  of feedstock  and 
policy option. Manure used for bio-LNG for international maritime increases from around 
2% in 2030 to 5-6% in 2050. 

Table 35 Used potential for the EU maritime sector as % of domestic potential in EU27 

Used potential 

POA 

POB 

POC 

(% of domestic potential in the EU27)  
Part A 

2030 

2050 

2030 

2050 

2030 

2050 

Perennial crops 
Annual crops 
Forestry products 
Forestry residues 
Wood waste 
Agricultural residues 
Manure 

Part B 

0.2% 
0.2% 
2.8% 
2.3% 
1.7% 
1.4% 
2.4% 

10.9% 
10.6% 
15.4% 
15.9% 
6.4% 
16.1% 
5.3% 

0.2% 
0.2% 
2.9% 
2.4% 
1.8% 
1.5% 
2.4% 

13.3% 
12.8% 
19.7% 
20.0% 
7.7% 
19.4% 
6.4% 

0.2% 
0.2% 
2.9% 
2.3% 
1.8% 
1.5% 
2.4% 

11.8% 
11.4% 
16.9% 
17.4% 
6.9% 
17.5% 
5.8% 

Non-agricultural oils 

20.6% 

27.4% 

21.3% 

34.4% 

21.1% 

29.9% 

Source: PRIMES Biomass model, E3Modelling 

E-fuels 

E-fuels include e-ammonia, e-methanol, synthetic diesel, synthetic fuel oil and e-gas. The 
electricity to produce e-fuels is projected to be the highest in PO1 (almost 2 TWh in 2030 
and  246  TWh  in  2050).  This  would  represent  around  0.1%  of  renewable  electricity 
generation in 2030 and 4.7% by 2050. In PO3 the electricity to produce e-fuels is projected 
at around 0.6 TWh in 2030 and 230 by 2050 (i.e. less than 0.1% of renewable electricity 
generation in 2030 and 4.4% in 2050). PO2 shows the lowest share of e-fuels in the energy 

128 

 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
mix and thus the lowest electricity needs to produce them (0.1 TWh in 2030 and 198 TWh 
in 2050). The electricity is primarily used to produce synthetic diesel blends and e-gas.   

Table 36 Electricity consumption for producing e-fuels for the maritime sector (in TWh and %) 

Electricity consumption for synthetic fuels 

PO1 

PO2 

PO3 

(TWh and %) 
Electricity consumption, TWh 
Share of gross electricity generation, % 

Share of renewable electricity generation, % 
Source: PRIMES model, E3Modelling 

2030 
1.8 
0.0% 

0.1% 

2050 
246 
2.0% 

4.7% 

2030 
0.1 
0.0% 

0.0% 

2050 
198 
1.6% 

3.8% 

2030 
0.59 
0.0% 

0.0% 

2050 
230 
1.9% 

4.4% 

5.  METHODOLOGICAL  APPROACH  FOR  REGULATORY  AND  ADMINISTRATIVE  COSTS 

RELATED TO BUSINESSES, AND FOR ENFORCEMENT COSTS 

Regulatory and administrative costs 

Administrative  costs  for  ship-owners  are  estimated  based  on  the  fact  that  each  vessel 
would have to comply with the following information obligations: 

  Annual energy compliance plan: Each vessel has to prepare an annual compliance plan, 
which  describes  which  fuels  and  technologies  the  ship  is  planning  to  use.  This  plan 
builds  on  the  EU  MRV  Monitoring  plan  and  includes  additional  emissions  as  well  as 
energy sources. To model the worst-case scenario, same assumptions could be used as 
in the EU MRV Impact Assessment192 for the preparation of the entire Monitoring plan 
(i.e.  40  hours  per  ship).  This  will  lead  to  total  annual  administrative  costs  of  around 
€18.9  million  (40  hours  *  12,114  ships  *  €39.1  labour  costs  per  hour).  Based  on  the 
experience with the implementation of EU MRV Regulation, it is likely that such cost 
would be the highest in the first year and significantly decrease afterwards. 

Annual energy report: The annual energy report is the calculation of the annual energy 
consumption of the vessel, broken down to different energy sources/types of fuel and to 
navigation and at berth. This report builds on the EU MRV Emission report, but is more 
extensive  as  well-to-tank,  non-CO2  emissions  and  OPS/electricity  consumption  are 
included as well. The question on the corresponding administrative cost has been asked 
in the targeted survey, where 8 out of 9 respondents indicated that for ship owners, the 
reporting time would increase by two hours at most, per voyage. However, it could not 
be verified to what extent such reply may already include the existing requirements of 
EU MRV Regulation (i.e. part of the baseline) or whether only additional elements are 
included.  

It  can  be  therefore  assumed  that  specific  information  on  the  use  of  OPS  is  already 
included in such reporting (as they would, at least partly, replace the fuel use currently 

192   DG CLIMA, MOVE  (2013) – Impact assessment part 2 Accompanying the document Proposal for a Regulation of the European 
Parliament and of the Council on the monitoring, reporting and verification of carbon dioxide emissions from maritime transport 
and amending Regulation (EU) N° 525/2013 

129 

 
 
                                                           
reported  at  berth),  based  on  information  supplied  by  the  electricity  supplier  (i.e. 
electricity  bills).  This  is  similar  for  the  use  of  THETIS-MRV  system,  which  the  ship 
owners  and  operators  are  already  using  and  the  adaptation  of  which  will  necessitate 
incremental  familiarisation cost  (however it is  not  expected that a new account  would 
need to be created by the system users for the purpose of this initiative).  

To model the worst case cost-scenario, and assuming that indeed the reported 2 hours 
would  be  truly  additional,  the  total  annual  administrative  costs  in  the  policy  options 
relative to the baseline are derived by multiplying the addition time spent for the annual 
energy report (i.e. 2 hours) by the number of voyages per year and by the labour costs 
per  hour.  This  amount  is  also  comparable  with  the  preparation  of  the  EU  MRV 
Emission  report,  as  estimated  in  the  EU  MRV  Impact  assessment  (i.e.  40  hours  per 
ship).  The assumptions used for estimating the annual costs are provided in  Table 37. 
The evolution of the total number of voyages per year for each policy option is linked to 
the evolution of transport activity, drawing on the PRIMES model results. 

  Proof of compliance: Each ship has to carry a document of compliance and cooperate 
during  Port  State  Control  inspections.  The  first  requirement  will  not  impose  any 
additional  administrative  costs,  as  the  document  is  supplied  by  the  Recognized 
Organisation, and thus only has to be stored. As regards cooperation during Port State 
Control  Inspections,  the only action needed is  to  retrieve the document of compliance 
and  show  it  to  the  inspector.  The  additional  administrative  costs  of  this  will  be  a 
maximum of 15 minutes per inspected ship. Assuming that each ship that falls under the 
scope  of  the  initiative  will  be  inspected  every  year,  the  maximum  amount  of  annual 
administrative  costs  are  approximately  €75,000  per  year  (which  is  the  upper  bound 
based  on  a  conservative  assumption  that  each  vessel  currently  under  EU  MRV 
Regulation  is  inspected  every  year).  The  assumptions  used  for  estimating  the  annual 
costs are provided in Table 37. 

  The  administrative  costs  incurred  by  operators  will  also  cover  the  training  needs  to 
ensure the safe switch to RLF on-board ships. Furthermore it is  assumed that training 
for renewable and low carbon fuels will become standard in training programs for new 
seafarers  in  2035.  This  means  that  only  the  ships  which  switch  to  RLF  before  2035 
would need to invest in additional training. The costs would be spread over the period 
2025-2035  and  are  calculated  assuming  3  days  of  training  of  8  hours  each.  Their 
evolution  over  time  is  linked  to  the  share  of  RLF  in  each  policy  option.  The 
assumptions used for estimating the annual costs are provided in Table 37.  

Administrative  cost  for  bunker  suppliers  will  primarily  consist  of  certification  of  fuel 
and upstream emissions/sustainability criteria. The certification requirements will build on 
existing  provisions  and  sustainability  criteria  in  the  Renewable  Energy  Directive  (RED). 
Fuel producers already have experience with certification of biofuels under RED. When a 
new  (bio)fuel  needs  to  be  certified,  for  instance  under  the  International  Sustainability  & 

130 

 
 
Carbon  Certification  (ISCC)  Scheme,  the  entire  supply  chain  has  to  be  certified.  This 
means that either all supplier and other stakeholders need to cooperate in the certification, 
or  are  already  ISCC  certified  themselves.  Certification  schemes  mostly  have  one-time 
registration fees that vary between €50 and €500, so these are one-off costs. Annual fees 
per certificate vary from €50 to €500 as well. Finally, fees have to be paid per quantity of 
material declared as sustainable. These fees range between €0.03 and €0.10 per metric ton. 
The  costs  of  an  external  audit  can  range  from  €800  to  €2,000  per  day.  It  has  not  been 
possible  to  estimate  how  many  certification  schemes  would  be  established  or  what  the 
exact impact of certifying upstream emissions would be (several fuel producers have been 
interviewed, but none were able to make an estimate of the effort needed for certification). 
However,  based  on  the  illustrative  costs  listed  above,  it  can  be  assumed  that  the  overall 
certification costs will not have significant impact on the price of alternative fuels.  

Administrative  costs  for  ports  are  much  more  modest  and  related  to  the  publication  of 
guidelines and the revision of ports regulations to cover the safe handling, bunkering and 
use of RLF. It is also expected that not all ports will be affected by a significant increase in 
new safety guidelines. In the analysis, 34% of the EU ports were assumed affected by the 
policy  intervention.  The  new  guidelines  would  have  to  be  established  for  six  fuel 
categories  (e.g.  bio-LNG,  e-liquids,  e-gas,  hydrogen,  ammonia  and  methanol)  in  the  160 
medium and large sized ports (470 ports x 34%) in Europe. The total annual administrative 
costs  would  be  spread  over  25  years  and  be  derived  by  multiplying  the  number  of 
additional  hours  by  the  labour  costs  per  hour  and  the  number  of  ports  affected.  The 
assumptions used for estimating the annual costs are provided in Table 37.  

Enforcement costs 

As  the  reporting  and  verification  system  is  similar  in  all  options,  the  annual  verification 
costs are similar for all policy options. They are calculated by assuming in a conservative 
way that 5 additional hours would be needed to verify the additional elements in both the 
annual energy report as well as the energy compliance plan relative to the baseline.193 The 
additional number of hours are multiplied with the labour costs and the number of vessels 
subject to the initiative. The assumptions used for estimating the annual costs are provided 
in Table 37. The evolution of the total number of ships for each policy option is linked to 
the evolution of the stock of vessels, drawing on the PRIMES-TREMOVE model results. 

On  the  side  of  the  public  administrations,  a  Port  State  Control  Officer  will  have  to 
determine whether the Document of Compliance is on board (similar assumption as above 
is made of 15 minutes per inspection and the cost of €75,000 on an annual basis, which is 
the upper bound based on a conservative assumption that each vessel currently under EU 

193  According to the IA on the revision of the EU MRV Regulation, p. 51 (overview of administrative burden), 

verification costs turned out to be significantly lower than estimated in the 2013 EU MRV impact assessment: 
https://ec.europa.eu/clima/sites/clima/files/transport/shipping/docs/swd_2019_10_en.pdf  

131 

 
 
                                                           
MRV Regulation is inspected every year). At the same time, it is proposed to allow for the 
use  of  electronic  certificates,  which  can  remove  the  need  for  a  physical  check  in  its 
entirety.  

Furthermore, additional one-off cost for adapting the EU MRV IT system (THETIS-MRV) 
should be foreseen for the EU budget to accommodate the additional information as well as 
additional  functionalities  related  to  the  RLF  obligations.  In  addition,  a  new  module  in 
THETIS-EU should support port state control officers as well as EU flag state inspectors in 
their work. Based on the cost of THETIS-MRV194 and experience with existing THETIS-
EU  modules  support  various  pieces  of  EU  legislation,  such  IT-developments  cost  are 
estimated at €300,000. For PO3, an additional tool would need to be developed to support 
the  tool  to  trace,  and  when  necessary  balance  over-  or  under-compliance.  This  tool  is 
estimated to cost €200,000. 

Table  37  summarises  the  input  used  for  quantifying  the  regulatory,  administrative  and 
enforcement costs. 

Table 37 Input assumptions for quantifying the regulatory, administrative and enforcement costs 

Information 

Administrative 

Frequency 

Time 

Tariff 

Number of 

Entities 

obligation 

action 

(per year) 

(hours) 

(per 

entities  

affected per 

hour) 

policy option 

Administrative costs of ship owners 

Annual energy 

Prepare and submit 

0,1 (to spread 

40195 

39.1196 

Vessels under 

PO1, PO2, 

compliance plan 

annual energy 

costs over 10 

EU MRV 

PO3: 100% 

(1) 

(2) 

(3) 

(4) 

(5) 

compliance plan 

years) 

Regulation: 

12,114 (in 

2019); linked 

to the 

evolution of 

the stock of 

vessels in the 

policy options 

Annual energy 

Collecting additional 

1 

2 

24.5 

Number of 

PO1, PO2, 

report 

information (per 

voyage) 

voyages under 

PO3: 100% 

EU MRV 

Regulation: 

317,900 (in 

2019); linked 

194 Source: EMSA 2020 
195  DG CLIMA, MOVE (2013) – Impact assessment part 2 Accompanying the document Proposal for a Regulation of 

the European Parliament and of the Council on the monitoring, reporting and verification of carbon dioxide emissions 
from maritime transport and amending Regulation (EU) N° 525/2013 

196  Eurostat (LC_LCI_LEV) Labour costs index EU27, Professional, scientific and technical activities (M)  

132 

 
 
 
 
                                                           
Information 

Administrative 

Frequency 

Time 

Tariff 

Number of 

Entities 

obligation 

action 

(per year) 

(hours) 

(per 

entities  

affected per 

hour) 

policy option 

to  the 

evolution of 

transport 

activity over 

time in the 

policy options 

Proof of 

Cooperate during PSC 

1 

0.25 

24.5197 

Vessels under 

compliance 

inspection 

EU MRV 

Regulation: 

12,114 (in 
2019)198 

PO1, PO2, 
PO3: 100%199 

Safety 

procedures 

Crew training 

4.5200 (to 
spread costs 

over 10 years) 

24201 

24.5 

Vessels under 

PO1, PO2, 

(wages) + 

EU MRV 

PO3: linked 

50 (fee) 

Regulation: 

to the uptake 

12,114 (in 

of RLF in 

2019); linked 

each option 

to the 

evolution of 

the stock of 

vessels in the 

policy options 

Administrative costs for port authorities 

Guidelines in 

Set up guidelines in 

ports 

ports 

Enforcement costs 

0.18202 (to 
spread costs 

over 25 years) 

160 

28.1 

Number of 

ports in the 
EU: 470203 

PO1, PO2, 
PO3: 34%204 

197  Eurostat (LC_LCI_LEV) Labour costs index EU27, Transportation and storage (H) 
198  Upper bound based on a conservative assumption that each vessel currently under EU MRV Regulation is  inspected 

every year. 

199  Assuming that each vessels under EU MRV Regulation is inspected every year 
200  Per vessel two entire crews (40-50 people) that need to be trained once between 2025 and 2035 
201  Based on duration of IGF Code training for LNG (RelyOnNutec: IGF Basic Training (2 days, fee: €800), STC 

Training & Consultancy IGF Training (Advanced 4 days, fee: €1,765 – Basic 2 days, fee: €730) 

202  Assuming that guidelines only need to be set-up once between 2025 and 2050, for each of the following six fuel 

categories (bio-LNG, e-liquids, e-gas, hydrogen, ammonia and methanol) 

203  470 European ports have registered throughput statistics, see section 5.2.4 (impact on ports) 
204  Assuming the ports classified as large and medium (see section 5.2.4 (impact on ports)) will set up guidelines and the 

small ports will use those guidelines  

133 

 
 
                                                           
Information 

Administrative 

Frequency 

Time 

Tariff 

Number of 

Entities 

obligation 

action 

(per year) 

(hours) 

(per 

entities  

affected per 

hour) 

policy option 

Annual energy 

Approve annual 

1 

5 

39.1205 

Vessels under 

PO1, PO2, 

compliance plan 

energy compliance 

EU MRV 

PO3: 100% 

plan 

Regulation: 

12,114 (in 

2019); linked 

to the 

evolution of 

the stock of 

vessels in the 

policy options 

Annual energy 

Verify annual energy 

1 

5 

39.1 

Vessels under 

PO1, PO2, 

report 

report 

EU MRV 

PO3: 100% 

Regulation: 

12,114 (in 

2019); linked 

to the 

evolution of 

the stock of 

vessles in the 

policy options 

Proof of 

Additional time 

1 

0.25 

39.1 

Vessels under 

PO1, PO2, 

compliance 

during 

audits/inspections 

EU MRV 

PO3: 

Regulation: 

Unknown % 

12,114 (in 
2019) 206 

of vessels 

inspected that 

fall under 

scope of EU-

MRV 

regulation 

6.  METHODOLOGICAL APPROACH FOR PORT INVESTMENTS 

The  estimated  investment  costs  on  hydrogen  and  OPS  installations  should  be  taken  as 
indicative of the scale of investments expected by ports under the conditions of the policy 
options. The large variations in energy demands by maritime vessels (type, size) as well as 
the geographical and operational conditions of the ports (port layout, existence of sufficient 
energy  link  to  the  grid,  etc)  limit  the  level  of  accuracy.  The  underlying  assumptions  are 
coherent with real life examples and thus have value in providing a general estimate. 

205  Eurostat (LC_LCI_LEV) Labour costs index EU27, Professional, scientific and technical activities (M)  
206  Upper bound based on a conservative assumption that each vessel currently under EU MRV Regulation is inspected 

every year. 

134 

 
 
 
                                                           
Hydrogen installations 

The estimation is based on the range of identified investments between €35 million to more 
than €100 million207. Given the size of the investments needed, it is assumed that only the 
25  largest  cargo  ports  will  undertake  such  investments.  The  highest  range  is  used  in  the 
estimation. 

OPS installations 

The estimation is based on calculations by EMSA on the average power demand needs at 
berth.  SafeSeaNet  data  on  number  of  individual  ships  at  ports  have  been  used,  and  a 
multiplying factor has been used to calculate the effective power average and peak demand 
per ship at berth based on existing literature208. The demand has been calculated for ports 
in  the  TEN-T  network,  with  at  least  one  vessel  above  5000  GT  at  berth  in  2019.  Even 
though traffic volumes are expected to increase in the following years, the number of port 
calls is assumed to remain relatively stable, as vessel capacity is expected to increase. This 
is  in  line  with  the  considerations  of  the  estimates  for  the  European  Maritime  Single 
Window  environment209.  The  energy  investment  needed  is  estimated  at:  262MW  for 
container, 2084MW for ro-pax and 3297MW for cruise vessels. 

The architecture of OPS installations is characterized by a variety of port-specific elements 
that  dictate  the  final  figure  for  capital  cost.  The  specific  port  spatial  layout,  number  of 
berths  to  be  provided  with  shore  power  connections,  individual  terminal  characteristics, 
power  demand,  ship  types  calling  the  port,  frequency  conversion  and  cable  management 
system options are amongst the most relevant drivers for OPS configuration and, therefore, 
affecting  directly  investment  cost.  Indicative  values  are  used  for  the  cost  of  investing  in 
OPS infrastructure per each type of vessel (€1.0m/MW for containerships, €1.2m/MW for 
ro-pax and €1.5m/MW for cruise vessels), using publicly available studies210.  

Baseline estimation 

With  regard  to  the  baseline  investments,  EAFO211  ,  provides  an  overview  of  the  OPS 
installations  in  Europe.  According  to  this  information,  maritime  ports  in  the  EU  have 
installed more than 90MW of power capacity for container, ro-pax and cruise vessels since 
2000.  The  introduced  capacity  varies  per  year,  between  zero  and  approximately  18MW. 

207 Source: North Sea Port (2020), https://en.northseaport.com/volth2-signs-cooperation-agreement-with-north-sea-port-
for-the-development-of-a-green-hydrogen-plant. In the absence of proper reference points for the development of 
infrastructure of hydrogen as marine fuel, this investment bandwidth is estimated on the basis of costs for the deployment 
of hydrogen plants in ports. 
208 Shore Power Technology Assessment at U.S. Ports, 2017; Energy analysis and costs estimation of 
an On-shore Power Supply system in the Port of Gävle, 2019 
209 https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52018SC0181&from=EN  
210 For example: Rotterdam: https://sustainableworldports.org/wp-content/uploads/Port-of-Rotterdam-Onshore-power-
supply-let-stay-connected-2010.pdf , North and Baltic ports: 
http://www.greencruiseport.eu/files/public/download/studies/Opportunities%20and%20Limitations%20for%20Connectin
g%20Cruise%20Vessels%20to%20Shore%20Power_04.01.2018_Bergen.pdf , Malta: 
https://electromobility.gov.mt/en/Documents/PORT-PVEV%20Feasibility%20Study.pdf , Hamburg: 
https://www.hamburg.de/contentblob/3613158/9dbe23fb1cbaf9bcaac9969d7550f4a1/data/landstrom-untersuchung-
2012.pdf  
211 https://www.eafo.eu/shipping-transport/port-infrastructure/ops/data 

135 

 
 
                                                           
There is also a steady increase with some 20MW being installed between 2006 and 2010, 
30MW between 2011 and 2015 and 39MW between 2016 and 2020. Given the above, it 
can  be  expected  that  EU  ports  will  continue  to  bring  OPS  capacity  in  service  in  the 
following  years.  In  the  absence  of  other  indications,  it  is  assumed  that  10MW  of  OPS 
power  capacity  will  be  introduced  each  year  until  between  2025  and  2050.  Baseline 
investment costs are estimated at €0.3 bn. 

7.  METHODOLOGICAL  APPROACH  AND  RESULTS  OF  THE  RISK  OF  CARBON  LEAKAGE 

ANALYSIS  

The potential for ships re-routing to reduce the amount of traffic that falls in scope of the 
initiative is analysed by comparing the situation without re-routing in 2030 (i.e. direct link 
from port A to port B, where port A is non-EU/EEA port and Port  B is a EU/EEA port) 
with the situation including an intermediate stop to a non-EU/EEA port (port C) closer (or 
the closest) to the EU/EEA port (port B). The analysis takes into account the costs by ship 
type  along  different  routes.  The  analysis  has  been  performed  with  the  TRUST  model  by 
TRT for PO1 and PO3 (PO2 was assumed to likely react similarly to PO2 as their design is 
similar). 

Cost types 

The  analysis  considers  the  costs  incurred  by  ships  from  the  origin  port  (port  A)  to  the 
destination  port  (port  B).  In  case  of  a  direct  route  (no  leakage  case)  between  port  A  and 
port B these costs include:  

  Costs at port A: the costs for the ports’ call (i.e. port dues, pilotage, towage, mooring, 

other costs) and the cost of operation time at port. 

  Fuel costs from port A to port B: in this case the whole navigation shall be performed 
with  the  mix  of  RLFs  required,  having  a  higher  cost  than  the  conventional  maritime 
fuels. 

  Other navigation costs from port A to port B: these are the costs for the operation of the 

ship covered by the ships’ time charter rates212. 

  Costs at port B: these costs include the costs for the ports’ call (i.e. port dues, pilotage, 
towage, mooring, other costs) the cost of waiting time to access the port and the cost of 
operation time at port. 

In case of an intermediate stop (leakage case) the costs include: 

  Costs at port A: these costs are the same as in the case of a direct route. 
  Fuel costs from port A to port C: This leg of the trip is assumed to be performed with 
conventional  maritime  fuels  as  it  falls  outside  the  scope  of  the  policy  measure  (leg 
between two non-EU/EEA ports). 

212  Time  Charter  Rates  cover  ship  operating  costs  such  as  crewing,  lubricants,  planned  maintenance,  insurance  and 

general administration expenses. 

136 

 
 
 
                                                           
  Other navigation costs from port A to port C: these costs are the same as in the case of 

a direct route. 

  Costs at port C: These costs include the costs for the ports’ call (i.e. port dues, pilotage, 
towage, mooring, other costs) the cost of waiting time to access the port and the cost of 
operation time at port.  

  Fuel costs from port C to port B: This leg of the trip is assumed to be performed with 

RLFs as it falls within the scope of the policy measure. 

  Other navigation costs from port C to port B: these costs are the same as in the case of 

a direct route. 

  Costs at port B: these costs are the same as in the case of a direct route. 

Ship types 

The analysis covers three freight ship types of the most relevant ship categories operating 
in the scope of the initiative: 

  Bulk carriers which represent respectively 32% of all ships and 37% of the total fleet 

deadweight falling into the scope of the initiative. 

  Container ships representing 15% of all ships and 18% of the total fleet deadweight. 
  Oil tankers representing 15% of all ships and 18% of the total fleet deadweight. 

Route types 

The  analysis  covers  different  routes  and  potential  intermediate  stops  for  the  above 
mentioned different ship types213. These are presented in Table 38, Table 39, and Table 40. 

Table 38: Routes and ship types considered for container ships 

Origin region 

Origin port 

Destination 
region 

Destination port 

China 

Shanghai  

North Europe 

China 

Shanghai  

Mediterranean 

US East coast 

US East coast 

New York 
Savannah 

New York 
Savannah 

North Europe 

Mediterranean 

South America 

Santos 

North Europe 

South America 

Santos 

Mediterranean 

Antwerp 
Rotterdam 
Hamburg 

Genoa 
Marseille 
Barcelona 
Antwerp 
Rotterdam 
Hamburg 
Genoa 
Marseille 
Barcelona 
Antwerp 
Rotterdam 
Hamburg 
Genoa 

Ship 
size 
[TEU] 
14,000 

21,000 

14,000 

Port of intermediate stop 

Port Said (Egypt) 
Mersin (Turkey) 
Tangier (Morocco) 
Felixstowe (UK) 
Port Said (Egypt) 
Mersin (Turkey) 

12,000 

Felixstowe (UK) 

8,000 

Tangier (Morocco) 

4,000 

Felixstowe (UK) 

4,500 

Tangier (Morocco) 

213  The routes were selected among those more likely providing an advantage of leakage. With respect to EU ports and 
concerned maritime areas this is deemed significant in the Mediterranean area for ships sailing through Suez Canal 
and through the Gibraltar straits, and in the Northern Europe for ships arriving for the Atlantic Ocean. Routes in other 
areas have not been considered: for example, routes calling at Baltic ports are normally stopping earlier in other EU 
ports and the relative advantage gained by introducing a stop in an extra EU port such as a Russian port would bring a 
very limited advantage. 

137 

 
 
 
 
                                                           
Origin region 

Origin port 

Destination 
region 

Destination port 

Ship 
size 
[TEU] 

Port of intermediate stop 

US West Coast 

Long Beach 

North Europe 

US West Coast 

Long Beach 

Mediterranean 

Source: TRUST model, TRT 

Table 39: Routes and ship types considered for dry bulk ships 

Marseille 
Barcelona 
Antwerp 
Rotterdam 
Hamburg 
Genoa 
Marseille 
Barcelona 

4,000 

Felixstowe (UK) 

4,500 

Tangier (Morocco) 

Origin region 

Origin port 

Destination 
region 

Destination 
port 

Ship size [DWT] - 
Goods 

US  
East coast 

US  
East coast 

New Orleans 

North Europe 

New Orleans 

Mediterranean 

US  
East coast 
South America  Santos 

New Orleans 

Mediterranean 

North Europe 

South America  Santos 

Mediterranean 

South America  Tubarao 

North Europe 

South America  Ponta Da 
Madeira 
South America  Ponta Da 
Madeira 

Source: TRUST model, TRT 

North Europe 

Mediterranean 

Antwerp 
Rotterdam 
Hamburg 
Marseille 
Livorno 
Naples 
Taranto 

Antwerp 
Rotterdam 
Hamburg 
Marseille 
Livorno 
Naples 
Rotterdam 
Hamburg 
Rotterdam 
Hamburg 
Taranto 

Table 40: Routes and ship types considered for liquid bulk ships 

Port of 
intermediate 
stop 

Grimsby (UK) 

Oran (Algeria) 

65,000-grain 
35,000-grain 

35,000-grain 
28,000-grain 

70,000-coal 

Oran (Algeria) 

65,000-grain 
35,000-grain 

35,000-grain 
28,000-grain 

Grimsby (UK) 

Oran (Algeria) 

200,000-iron ore 
300,000-iron ore 
165,000-coal 

Grimsby (UK) 

Grimsby (UK) 

200,000-iron ore 

Oran (Algeria) 

Origin region 

US Gulf 

Origin 
port 
Corpus 
Christi 

Destination 
region 
North Europe 

West Africa 

Lagos 

North Europe 

Arabian Gulf 

Ju’aymah 

North Europe 

North Africa 

Arzew 

North Europe 

US Gulf 

Corpus 
Christi 

Mediterranean 

West Africa 

Lagos 

Mediterranean 

Destination 
port 

Antwerp 
Rotterdam 

Antwerp 
Rotterdam 

Antwerp 
Rotterdam 

Antwerp 
Rotterdam 
Augusta 
Cartagena  
Agioi Theodoroi 
Savona 
Cartagena  
Leixoes 

Ship size [DWT] - 
Goods 
70,000-dirty products-
crude oil 
130,000-dirty products 
135,000-dirty products 

Port of 
intermediate stop 
Milford Haven 
(UK) 

Jorf-Lasfar 
(Morocco) 
Medway (UK) 

90,000-clean products  Alexandria 

(Egypt) 
Milford Haven 
(UK) 
Medway (UK) 

80,000 

70,000-dirty products-
crude oil 
130,000-dirty products 
130,000-dirty products 

Jorf-Lasfar 
(Morocco) 

Jorf-Lasfar 
(Morocco) 

138 

 
 
 
 
 
 
 
 
Origin region 

Origin 
port 

Destination 
region 

Destination 
port 

Ship size [DWT] - 
Goods 

Port of 
intermediate stop 

Arabian Gulf 

Ju’aymah 

Mediterranean 

Savona 
Cartagena  
Leixoes 

90,000-clean products  Alexandria 

(Egypt) 

Source: TRUST model, TRT 

Underlying assumptions 

The approach described above implies the following underlying assumptions: 

  The analysis considers ‘ship’ costs and not ‘cargo’ costs (i.e. cargo handling costs are 

not considered);  

  The  analysis  considers  (i)  the  existing  costs  for  ports  and  charter  rates,  which  are 
assumed to be kept constant over time in real terms, and (ii) assumptions on maritime 
gas  oil  fuel  costs  for  2030  for  both  conventional  and  blended  fuel  as  estimated  by 
PRIMES model. 

  Consistently  with  PRIMES  projections,  fuel  efficiency  is  the  same  in  the  case  of 

blended maritime gas oil and conventional maritime gas oil. 

  The ‘value of time’ for ports’ operation and waiting times is derived from ships’ time 

charter rate. 

  Ports’ costs used in the analysis are average values of the TRUST model and are not 

 

representative of specific cases (i.e. port / ship size / cargo). 
In case of re-routing to reduce the amount of traffic that falls in scope of the initiative, 
the  cargo  continues  to  be  carried  on  the  same  vessel  (and  not  distributed  to  smaller 
vessels at  intermediate port) and the port of destination is  preserved  (i.e.  the cargo is 
not delivered to multiple EU/EEA ports instead). 

Speed: The following speeds have been considered for the different ship types: containers - 
14 knots; dry bulkers and tankers - 11 knots. These speeds are in line with those indicated 
in  the  2019  Annual  Report  on  CO2  Emissions  from  Maritime  Transport214  for  the  above 
mentioned ship types. 

Time  at  ports:  Given  the  lack  of  specific  information  at  individual  ports,  the  following 
average values of the TRUST model are considered: waiting time (time to access the port) 
at  intermediate  and  destination  ports  is  10  hours;  operation  time  (time  to  load/unload 
cargo) at all ports is 24 hours. 

Fuel consumption: Table 41 lists the fuel consumption factors, expressed in tonnes of fuel 
per day used in the TRUST model.  

Table 41: Fuel consumption factors by speed and ship type 

Ship type 

Ship size  

Speed [knots] 

Container 

214  SWD(2020) 82 final 

21,000 TEU 
18,000 TEU 
14,000 TEU 
12,000 TEU 
8,000 TEU 

14 
14 
14 
14 
14 

Fuel consumption 
[Tonnes/day] 
126 
112 
94 
76 
49 

139 

 
 
 
                                                           
Ship type 

Ship size  

Speed [knots] 

Dry bulker 

Liquid bulker 

Source: TRUST model, TRT 

4,500 TEU 
4,000 TEU 
28,000 DWT 
35,000 DWT 
65,000 DWT 
70,000 DWT 
165,000 DWT 
200,000 DWT 
300,000 DWT 
70,000 DWT 
80,000 DWT 
90,000 DWT 
130,000 DWT 
135,000 DWT 

14 
14 
11 
11 
11 
11 
11 
11 
11 
11 
11 
11 
11 
11 

Fuel consumption 
[Tonnes/day] 
31 
31 
12 
16 
23 
23 
31 
32 
38 
24 
24 
25 
30 
30 

Fuel  cost:  the  cost  in  2030  of  conventional  MGO  is  assumed  at  €906  per  tonne  in  both 
PO1 and PO3. This is an average of the costs estimated by PRIMES at  country level for 
EU27  Member  States  and  United  Kingdom.  Consistently  with  PRIMES  projections,  the 
cost of blended MGO in PO1 is assumed at € 971 per tonne (i.e. 7.2% higher than the cost 
of  conventional  MGO)  in  2030.  In  PO3  the  cost  for  blended  MGO  in  2030  is  €  970  per 
tonne (i.e. 7.1% higher than the cost of conventional MGO).215 

Time charter rates: TRUST values for Time Charter Rates (expressed in $/day) are based 
on  data  provided  by  Drewry’s  publication  ‘Shipping  Insight’  (December  2019). 
Interpolation on published data was performed to fill in data gaps for missing ship sizes. 
Time  Charter  Rates  cover  ship  operating  costs  such  as  crewing,  lubricants,  planned 
maintenance,  insurance  and  general  administration  expenses.  These  values  are  used  to 
compute other navigation costs and the cost of time at ports (waiting and operation). 

Table 42: Time charter rates by ship type 

Ship type 

Ship size  

Time charter rates [€/day] 

Container 

Dry bulker 

Liquid bulker 

21,000 TEU 
18,000 TEU 
14,000 TEU 
12,000 TEU 
8,000 TEU 
4,500 TEU 
4,000 TEU 
28,000 DWT 
35,000 DWT 
65,000 DWT 
70,000 DWT 
165,000 DWT 
200,000 DWT 
300,000 DWT 
70,000 DWT 
80,000 DWT 
90,000 DWT 
130,000 DWT 
135,000 DWT 

39,000 
34,000 
28,000 
25,000 
20,000 
13,800 
8,700 
7,055 
7,400 
9,430 
9,650 
14,260 
15,960 
20,815 
13,600 
15,300 
18,020 
24,650 
25,500 

215  It is worth to consider that the price of maritime fuel is quite variable over time and fluctuations of prices over one 

year might be higher than the estimated increase in fuel cost due to the analysed policy options. 

140 

 
 
                                                           
Source: TRUST model, TRT 

Costs  at  ports:  The  costs  incurred  by  ships  at  ports  (i.e.  port  dues,  pilotage,  towage, 
mooring,  other  costs)  depend  on  the  type  and  size  of  the  ship  and  on  the  type  of  cargo. 
These costs are highly variable from case to case as they may be dependent on commercial 
agreements  between  the  port  terminals  /  port  authorities  and  the  ship  owners  /  shippers. 
Given its commercial sensitivity, this kind of information is hardly disclosed by maritime 
operators and very little evidence on these costs exist in literature. 

As part of this analysis an attempt to collect specific information on the costs of some non-
EU/EEA ports was performed. A dedicated questionnaire covering different cost types by 
type  of  ship  was  sent  to  all  ports’  authorities/operators  considered  in  this  analysis. 
Unfortunately,  the  survey  response  rate  was  extremely  low  and  very  little  evidence  was 
collected. 

Ports’  costs  used  for  the  calculations  (expressed  in  €  per  DWT)  are  therefore  not 
representative of the specific case (i.e. port / ship size / cargo), but are the average values 
of the TRUST model estimated by TRT on the basis of in-house data. 

Table 43: Cost at ports by ship type 

Ship type 

Ship size  

Container 

Dry bulker 

Liquid bulker 

21,000 TEU (198,500 DWT) 
18,000 TEU (185,200 DWT) 
14,000 TEU (165,500DWT) 
12,000 TEU (153,500 DWT) 
8,000 TEU (105,450 DWT) 
4,500 TEU (60,900 DWT) 
4,000 TEU (49,200 DWT) 
28,000 DWT 
35,000 DWT 
65,000 DWT 
70,000 DWT 
165,000 DWT 
200,000 DWT 
300,000 DWT 
70,000 DWT 
80,000 DWT 
90,000 DWT 
130,000 DWT 
135,000 DWT 

Cost of ship at ports 
[€/DWT] 
0.720 
0.730 
0.740 
0.748 
0.953 
0.962 
0.964 
0.956 
0.869 
0.882 
0.847 
0.608 
0.612 
0.542 
0.876 
0.876 
0.779 
0.719 
0.719 

Source: TRUST model, TRT 

Results for PO1 

Analysis for container ship routes 

In  case  of  an  intermediate  stop  to  a  non-EU/EEA  port,  total  travel  time  increases  in  the 
range of 4% to 13% relative to the Baseline in 2030 depending on the routes (i.e. 34 to 63 
additional  hours  relative  to  the  direct  route).  The  lowest  relative  increases  of  about  4% 
apply  to  the  routes  from  South  East  Asia  (Shanghai)  to  North  Europe  (Antwerp, 
Rotterdam,  Hamburg)  with  an  intermediate  stop  in  Egypt  (Port  Said)  (equivalent  to  34 
hours),  Morocco  (Tangier)  (equivalent  to  35  hours)  and  United  Kingdom  (Felixstowe) 
(equivalent  to  37  hours).  The  highest  relative  increase  of  13%  occurs  for  the  route  from 

141 

 
 
North  America  (New  York)  to  North  Europe  (Antwerp  and  Rotterdam)  with  an 
intermediate  stop  in  United  Kingdom  (Felixstowe)  (equivalent  respectively  to  39  and  38 
hours).  The  highest  absolute  increase  of  63  hours  applies  to  the  route  from  Shanghai  to 
North Europe (Antwerp, Rotterdam, Hamburg) and to the Mediterranean port of Barcelona 
with an intermediate stop in Turkey (Mersin). It corresponds to an increase of 8% in total 
travel time relative to the Baseline. 

Increases in sailing time are relatively small and in the range of 0% to 5% relative to the 
Baseline  in  2030,  as  intermediate  ports  are  conveniently  located  along  the  routes  and 
require  small  detours  to  be  reached,  while  time  at  ports  increases  by  59%  due  to  the 
additional stop216.   

The  analysis  of  costs  shows  that  for  the  vast  majority  of  the  routes  total  travel  costs 
increase  in  the  case  of  an  intermediate  stop  to  a  non-EU/EEA  port.  The  cost  increase 
ranges  from  0.3%  for  a  21,000  TEU  ship  travelling  from  Shanghai  to  North  Europe 
(Antwerp,  Rotterdam,  Hamburg)  and  stopping  in  Egypt  (Port  Said)  to  9.9%  for  a  8,000 
TEU  ship  travelling  from  New  York  to  Barcelona  and  stopping  in  Morocco  (Tangier). 
More  specifically,  for  a  21,000  TEU  ship  travelling  from  Shanghai  to  North  Europe 
(Antwerp, Rotterdam, Hamburg), the additional total travel cost ranges from about €14,500 
in  case  of  an  intermediate  stop  in  Egypt  (Port  Said)  to  near  €  199,000  in  the  case  of  an 
intermediate stop in Turkey (Mersin).  

Total  travel  costs  slightly  decrease  only  for  few  routes  due  to  the  lower  fuel  costs,  as 
shown in Table 44. This decrease is in the range of 0.1% to 0.8%, depending on the ship 
type,  for  the  routes  from  Shanghai  to  Northern  Europe  (Antwerp,  Rotterdam,  Hamburg) 
with an intermediate stop in Morocco (Tangier) and in United Kingdom (Felixstowe). 

Table 44: Container routes with decreasing total travel costs in PO1 relative to the Baseline (% change of travel costs 
components) 

Ship size 
TEU 

Origin Port 

Destination 
Port 

Intermediate  
Port 

Fuel cost  
[%] 

Time cost  
[%] 

Ports cost  
[%] 

TOTAL  
[%] 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

21,000 

21,000 

21,000 

21,000 

21,000 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

21,000 
Source: TRUST model, TRT 

Shanghai 

Antwerp 

Tangier (Morocco) 

Rotterdam 

Tangier (Morocco) 

Hamburg 

Antwerp 

Tangier (Morocco) 

Felixstowe (UK) 

Rotterdam 

Felixstowe (UK) 

Hamburg 

Antwerp 

Felixstowe (UK) 

Tangier (Morocco) 

Rotterdam 

Tangier (Morocco) 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

-5.8% 

-5.8% 

-5.7% 

-6.1% 

-6.2% 

-6.2% 

-5.8% 

-5.8% 

-5.7% 

-6.1% 

-6.2% 

-6.2% 

4.3% 

4.3% 

4.2% 

4.8% 

4.7% 

4.4% 

4.3% 

4.3% 

4.2% 

4.8% 

4.7% 

4.4% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

-0.1% 

-0.1% 

-0.1% 

-0.2% 

-0.3% 

-0.4% 

-0.5% 

-0.5% 

-0.5% 

-0.6% 

-0.7% 

-0.8% 

In such cases the total cost saving ranges from a minimum of about € 5,300 for a 14,000 
TEU  ship  stopping  in  Tangier  to  a  maximum  of  near  €  45,900  for  a  21,000  TEU  ship 
stopping in Felixstowe.  

216   Waiting time (time to access the port) at intermediate and destination ports is assumed at 10 hours; operation time 

(time to load/unload cargo) at all ports is assumed at 24 hours. 

142 

 
 
                                                           
Table 45: Container routes with decreasing total travel costs in PO1 relative to the Baseline (change in travel costs 
components) 

Ship size 
TEU 

Origin Port 

Destination 
Port 

Intermediate  
Port 

Fuel cost 
[€]  

Time 
cost [€] 

Ports cost 
[€] 

TOTAL 
[€]   

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

21,000 

21,000 

21,000 

21,000 

21,000 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

21,000 
Source: TRUST model, TRT 

Shanghai 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

-166,526 

-166,526 

-166,526 

-173,975 

-178,058 

-181,868 

-222,034 

-222,034 

-222,034 

-231,967 

-237,410 

-242,491 

40,417 

40,417 

40,417 

45,250 

44,000 

42,833 

56,295 

56,295 

56,295 

63,027 

61,286 

59,661 

120,827 

120,827 

120,827 

120,827 

120,827 

120,827 

136,955 

136,955 

136,955 

136,955 

136,955 

136,955 

-5,282 

-5,282 

-5,282 

-7,898 

-13,230 

-18,208 

-28,785 

-28,785 

-28,785 

-31,985 

-39,170 

-45,876 

For  all the other analysed combinations for ships departing  from  Shanghai  (18 out  of 54 
total routes analysed) and directed (i) to Northern Europe (Antwerp, Rotterdam, Hamburg) 
or  (ii)  to  the  Mediterranean  region  (Genova,  Marseille,  Barcelona)  and  performing  an 
intermediate stop in  Egypt (Port Said) or in Turkey (Mersin), no reduction in total travel 
costs occurs. 

Table 46: Other container routes departing from Shanghai (% change of travel costs components in PO1 relative to the 
Baseline) 

Ship size 
TEU 

Origin Port 

Destination 
Port 

Intermediate Port 

Fuel cost  
[%] 

Time cost  
[%] 

Ports cost  
[%] 

TOTAL  
[%] 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

14,000 

14,000 

14,000 

14,000 

14,000 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

14,000 
Source: TRUST model, TRT 

Shanghai 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Genova 

Marseille 

Barcelona 

Genova 

Marseille 

Barcelona 

Port Said (Egypt) 

Port Said (Egypt) 

Port Said (Egypt) 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

Port Said (Egypt) 

Port Said (Egypt) 

Port Said (Egypt) 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

Port Said (Egypt) 

Port Said (Egypt) 

Port Said (Egypt) 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

-4.7% 

-4.7% 

-4.5% 

-1.1% 

-1.1% 

-1.0% 

-4.7% 

-4.7% 

-4.5% 

-1.1% 

-1.1% 

-1.0% 

-5.6% 

-5.6% 

-5.5% 

-1.4% 

-1.4% 

-1.3% 

4.2% 

4.2% 

4.1% 

7.7% 

7.8% 

7.6% 

4.2% 

4.2% 

4.1% 

7.7% 

7.8% 

7.6% 

5.0% 

5.0% 

4.9% 

9.1% 

9.0% 

9.1% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

0.7% 

0.7% 

0.7% 

4.0% 

4.0% 

4.0% 

0.3% 

0.3% 

0.3% 

3.7% 

3.7% 

3.6% 

0.8% 

0.8% 

0.8% 

4.7% 

4.6% 

4.7% 

More  specifically,  in  such  cases  total  travel  costs  increase  from  a  minimum  of  about  € 
14,500  for  a  21,000  TEU  ship  directed  to  Northern  Europe  and  stopping  in  Egypt  (Port 
Said) to a maximum of near € 199,000 for a 21,000  TEU ship directed  as well to Northern 
Europe but stopping in Turkey (Mersin). 

143 

 
 
 
 
Table 47: Other container routes departing from Shanghai (change of travel costs components in PO1 relative to the 
Baseline) 

Ship size 
TEU 

Origin Port 

Destination 
Port 

Intermediate Port 

Fuel cost  

Time cost  

Ports cost  

TOTAL  

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

14,000 

14,000 

14,000 

14,000 

14,000 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Antwerp 

Port Said (Egypt) 

Rotterdam 

Port Said (Egypt) 

Hamburg 

Port Said (Egypt) 

Antwerp 

Mersin (Turkey) 

Rotterdam  Mersin (Turkey) 

Hamburg 

Mersin (Turkey) 

Antwerp 

Port Said (Egypt) 

Rotterdam 

Port Said (Egypt) 

Hamburg 

Port Said (Egypt) 

Antwerp 

Mersin (Turkey) 

Rotterdam  Mersin (Turkey) 

Hamburg 

Mersin (Turkey) 

Genova 

Port Said (Egypt) 

Marseille 

Port Said (Egypt) 

Barcelona 

Port Said (Egypt) 

Genova 

Mersin (Turkey) 

Marseille 

Mersin (Turkey) 

14,000 
Source: TRUST model, TRT 

Shanghai 

Barcelona 

Mersin (Turkey) 

-133,294 

-133,294 

-133,294 

-30,130 

-30,130 

-30,130 

-177,726 

-177,726 

-177,726 

-40,174 

-40,174 

-40,174 

-133,294 

-133,294 

-133,294 

-34,213 

-34,213 

-30,130 

39,667 

39,667 

39,667 

73,250 

73,250 

73,250 

55,250 

55,250 

55,250 

102,027 

102,027 

102,027 

39,667 

39,667 

39,667 

72,000 

72,000 

73,250 

120,827 

120,827 

120,827 

120,827 

120,827 

120,827 

136,955 

136,955 

136,955 

136,955 

136,955 

136,955 

120,827 

120,827 

120,827 

120,827 

120,827 

120,827 

27,200 

27,200 

27,200 

163,947 

163,947 

163,947 

14,479 

14,479 

14,479 

198,808 

198,808 

198,808 

27,200 

27,200 

27,200 

158,614 

158,614 

163,947 

It should however be noted that these calculations do not consider increases in ports costs 
and in charter rates over time. These costs are kept constant in real terms (in 2020 prices); 
this implies that an increase in these costs by 2030 may reduce or even offset the estimated 
costs savings. Table 48 shows for each route the percentage increase in charter rates that 
would  offset  the  cost  savings.  Similarly,  Table  49  shows  for  each  route  the  percentage 
increase in port costs that would offset the cost savings217.  

Table 48: Percentage increase in charter rates that would offset the cost savings in PO1 

Ship size TEU 

Origin Port 

Destination Port 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

21,000 

21,000 

21,000 

21,000 

21,000 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Intermediate  
Port 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Charter rates 
increase 
[%]  

13% 

13% 

13% 

18% 

30% 

43% 

51% 

51% 

51% 

51% 

64% 

217  The  tables  provide  the  increase  in  only  one  cost  component,  but  increases  in  both  components  are  more  likely  to 
occur. Their different combinations however generate countless possibilities for cost increases that would offset the 
costs savings. As an example, a combined increase of 20% in charter rates and of 25% in ports’ costs would offset 
costs savings of all routes. A similar result is achieved with a combined increase of 31% in charter rates and of 20% 
in port costs. 

144 

 
 
 
 
 
 
                                                           
Ship size TEU 

Origin Port 

Destination Port 

Intermediate  
Port 

21,000 
Shanghai 
Source: TRUST model, TRT 

Hamburg 

Felixstowe (UK) 

Table 49: Percentage increase in port costs that would offset the cost savings in PO1 

Ship size TEU 

Origin Port 

Destination Port 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

21,000 

21,000 

21,000 

21,000 

21,000 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

21,000 
Shanghai 
Source: TRUST model, TRT 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Intermediate  
Port 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Charter rates 
increase 
[%]  

77% 

Port costs 
increase 
[%]  

5% 

5% 

5% 

7% 

11% 

15% 

21% 

21% 

21% 

24% 

29% 

34% 

The  analysis  of  the  different  cost  components  shows  that,  for  the  vast  majority  of  the 
routes, total travel costs increase in the case of an intermediate stop to a non-EU/EEA port. 
Indeed, although fuel costs in the case of route diversion (i.e. with an intermediate stop to a 
non-EU/EEA  port)  are  expected  to  reduce  in  the  range  of  1%  to  6%  (i.e.  €26,000  to 
€242,000 depending on the route and the ship type) in 2030 relative to the Baseline, travel 
time costs are expected to increase in the range of 4% to 13% (i.e. €13,300 to €102,000) 
and costs at ports are expected to increase by 50% (i.e. €47,500 to €137,000 according to 
the  ship  type).  These  results  suggest  that  the  risk  of  leakage  resulting  from  containers 
ships’ route diversion to reduce the amount of traffic that falls in scope of the requirements 
is low. 

Furthermore,  it  is  worth  to  consider  that  container  ships  usually  perform  several  stops 
along the route to load/unload cargo and therefore the whole journey from the Origin port 
to the Destination port would not fall under the scope of the regulation. It might be the case 
that  container  ships  find  a  convenience  in  relocating  one  of  the  stops  to  the  closest  non-
EU/EEA  port  (rather  than  performing  an  additional  stop).  In  such  a  case  however,  the 
leakage would be limited only to the final leg of the trip with limited impacts on the overall 
effectiveness of the initiative. 

Analysis for dry bulker routes 

In case of an additional stop performed to a non-EU/EEA port, total travel time (navigation 
and  time  at  ports)  of  dry  bulkers  for  all  considered  routes  is  expected  to  increase  in  the 
range of 6% to 13% relative to the Baseline in 2030 (i.e. 36 to 62 additional hours relative 
to  the  direct  route).  The  lowest  relative  increase  of  near  6%  occurs  on  the  routes  from 
North  America  (New  Orleans)  to  the  Mediterranean  ports  of  Italy  (Naples  and  Taranto) 
with an intermediate stop in Algeria (Oran). The highest relative increase of 13% occurs on 

145 

 
 
the route from South  America (Ponta  Da Madeira) to  North Europe  (Rotterdam) with  an 
intermediate stop in United Kingdom (Grimsby). 

Similarly to the routes for container ships, the increase in sailing time is relatively limited 
(up to 6%) due to the strategic position of intermediate ports. The increase of time at ports 
is estimated at 59%. 

For  all  considered  routes  total  travel  costs  are  expected  to  go  up  by  5%  to  14%  (i.e. 
€25,000 to €202,000 depending on the route and the ship type) in case of an additional stop 
performed to a non-EU/EEA port. 

More specifically, the analysis of the different  cost  components shows that  although fuel 
costs in the case of an intermediate stop are expected to reduce by up to 5% (i.e. €2,700 to 
€33,500),  travel  time  costs  are  expected  to  increase  in  the  range  of  6%  to  13%  (i.e.  € 
11,000  to  €  50,000)  and  costs  at  ports  are  expected  to  increase  by  50%  (i.e.  €27,000  to 
€163,000).  On  the  basis  of  this  analysis  it  can  be  concluded  that  the  risk  of  leakage 
resulting  from  dry  bulkers’  route  diversion  to  reduce  the  amount  of  traffic  that  falls  in 
scope of the requirements is very low. 

Analysis for tankers routes 

The increase of total travel time (navigation and time at ports) of tankers for all considered 
routes in case of an additional stop performed to a non-EU/EEA port is in the range of 6% 
to  20%  (i.e.  35  to  61  additional  hours  depending  on  the  route).  More  specifically,  the 
increase  in  sailing  time  ranges  between  0%  and  5%  and  the  increase  of  time  at  ports  is 
around 59%. 

The  lowest  relative  increase  of  near  6%  occurs  on  the  routes  from  the  Arabian  Gulf 
(Ju’aymah)  to  the  Northern  Europe  ports  (Antwerp  and  Rotterdam)  with  an  intermediate 
stop in Egypt (Alexandria). The highest relative increase of 20% occurs on the route from 
North Africa (Arzew) to North Europe (Antwerp and Rotterdam) with an intermediate stop 
in United Kingdom (Medway).  

For all considered routes total travel costs are expected to increase in case of an additional 
stop  performed  to  a  non-EU/EEA.  This  increase  is  estimated  in  the  range  of  7%  to  23% 
(i.e.  €71,000  to  €133,000)  depending  on  the  route  and  the  ship  type.  The  analysis  of  the 
different  cost  components  shows  that,  although  fuel  costs  are  expected  to  reduce  in  the 
case of an intermediate stop to a non-EU/EEA ports by up to 6% (i.e. €1,900 to €21,600), 
travel  time  costs  are  expected  to  increase  in  the  range  of  6%  to  20%  (i.e.  €26,000  and 
€50,000) and costs at ports are expected to increase by 50% (i.e. €61,000 to €97,000). On 
the basis of this analysis it can be concluded that the risk of leakage resulting from tankers’ 
route diversion  to  reduce the amount of traffic that  falls in  scope of the initiative is  very 
low. 

Results for PO3 

Analysis for container ship routes 

Table 56 and Source: TRUST model, TRT 

146 

 
 
 
Table 57 provide the comparison of travel times and related components for the analysed 
container ships along the different routes in two cases (a direct route from the origin non-
EU/EEA  port  to  the  destination  EU/EEA  port  and  a  route  with  a  stop  to  an  intermediate 
non-EU/EEA port). Due to  the additional stop,  total travel  time increases in  the range of 
4% to 13% depending on the routes218. 

As  far  as  travel  costs  are  concerned,  it  is  to  be  noted  that  the  increase  in  the  costs  of 
blended MGO relative to conventional MGO in PO3 is relatively similar to the increase in 
PO1.  Therefore,  there  are  small  differences  between  the  results  of  PO1  and  PO3.    The 
analysis  of  travel  costs  reported  in  Table  58  shows  that,  also  in  this  case  for  the  vast 
majority of analysed routes total travel costs increase in the case of an intermediate stop to 
a  non-EU/EEA  port  and  that  the  increase  ranges  from  0.3%  for  a  21,000  TEU  ship 
travelling from Shanghai to North Europe (Antwerp, Rotterdam, Hamburg) and stopping in 
Egypt (Port Said) to 10% for a 8000 TEU ship travelling from New York to Barcelona and 
stopping in Morocco (Tangier). 

The  increase  in  total  travel  costs  ranges  from  €17,000  for  a  21,000  TEU  ship  travelling 
from  Shanghai  to  North  Europe  (Antwerp,  Rotterdam,  Hamburg)  and  performing  an 
intermediate  stop  in  Egypt  (Port  Said)  to  near  €201,000  if  the  intermediate  stop  is 
performed in Turkey (Mersin).  

In  PO3  total  travel  costs  slightly  decrease  only  for  few  routes,  similarly  to  PO1.  More 
specifically a decrease is observed for 12 out of 54 total analysed combinations of routes 
and ship types (i.e. 22% of analysed combinations). This decrease, in the range of 0.1% to 
0.8% depending on the ship type, occurs only for the routes departing from Shanghai and 
directed to Northern Europe (Antwerp, Rotterdam, Hamburg) with an intermediate stop in 
Morocco (Tangier) and in United Kingdom (Felixstowe).  

Table 50: Container routes with decreasing total travel costs in PO3 relative to the Baseline (% change of travel costs 
components) 

Ship size 
TEU 

Origin Port 

Destination 
Port 

Intermediate Port 

Fuel cost  
[%] 

Time cost  
[%] 

Ports cost  
[%] 

TOTAL  
[%] 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

21,000 

21,000 

21,000 

21,000 

21,000 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

21,000 
Source: TRUST model, TRT 

Shanghai 

Antwerp 

Tangier (Morocco) 

Rotterdam 

Tangier (Morocco) 

Hamburg 

Antwerp 

Tangier (Morocco) 

Felixstowe (UK) 

Rotterdam 

Felixstowe (UK) 

Hamburg 

Antwerp 

Felixstowe (UK) 

Tangier (Morocco) 

Rotterdam 

Tangier (Morocco) 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

-5.7% 

-5.7% 

-5.6% 

-6.0% 

-6.1% 

-6.1% 

-5.7% 

-5.7% 

-5.6% 

-6.0% 

-6.1% 

-6.1% 

4.3% 

4.3% 

4.2% 

4.8% 

4.7% 

4.4% 

4.3% 

4.3% 

4.2% 

4.8% 

4.7% 

4.4% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

-0.1% 

-0.1% 

-0.1% 

-0.1% 

-0.3% 

-0.4% 

-0.5% 

-0.5% 

-0.5% 

-0.5% 

-0.7% 

-0.8% 

In such cases the total cost saving ranges from €2,700 for a 14,000 TEU ship stopping in 
Tangier to near €42,000 for a 21,000 TEU ship stopping in Felixstowe (see Table 51). 

218  As no changes apply to the underlying assumptions on navigation speed, time spent at ports and on analysed routes, 

time changes observed in PO1 apply also to PO3. 

147 

 
 
                                                           
Table 51: Container routes with decreasing total travel costs in PO3 relative to the Baseline (change of travel costs 
components)  

Ship size 
TEU 

Origin Port 

Destination 
Port 

Intermediate  
Port 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

21,000 

21,000 

21,000 

21,000 

21,000 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

21,000 
Source: TRUST model, TRT 

Shanghai 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Fuel cost 
[€]   

Time 
cost  
[€] 

Ports cost  
[€] 

TOTAL 
[€]   

-163,957 

-163,957 

-163,957 

-171,069 

-175,148 

-178,955 

-218,610 

-218,610 

-218,610 

-228,092 

-233,531 

-238,606 

40,417 

40,417 

40,417 

45,250 

44,000 

42,833 

56,295 

56,295 

56,295 

63,027 

61,286 

59,661 

120,827 

120,827 

120,827 

120,827 

120,827 

120,827 

136,955 

136,955 

136,955 

136,955 

136,955 

136,955 

-2,713 

-2,713 

-2,713 

-4,992 

-10,320 

-15,294 

-25,360 

-25,360 

-25,360 

-28,111 

-35,290 

-41,991 

For  all the other analysed combinations for ships departing  from  Shanghai  (18 out  of 54 
total routes analysed) and directed (i) to Northern Europe (Antwerp, Rotterdam, Hamburg) 
or  (ii)  to  the  Mediterranean  region  (Genova,  Marseille,  Barcelona)  and  performing  an 
intermediate stop in  Egypt (Port Said) or in Turkey (Mersin), no reduction in total travel 
costs occurs (see Table 52). 

Table 52: Other container routes departing from Shanghai (% change of travel costs components in PO3 relative to the 
Baseline) 

Ship size 
TEU 

Origin Port 

Destination 
Port 

Intermediate Port 

Fuel cost  
[%] 

Time cost  
[%] 

Ports cost  
[%] 

TOTAL  
[%] 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

14,000 

14,000 

14,000 

14,000 

14,000 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

14,000 
Source: TRUST model, TRT 

Shanghai 

Antwerp 

Port Said (Egypt) 

Rotterdam 

Port Said (Egypt) 

Hamburg 

Antwerp 

Port Said (Egypt) 

Mersin (Turkey) 

Rotterdam 

Mersin (Turkey) 

Hamburg 

Antwerp 

Mersin (Turkey) 

Port Said (Egypt) 

Rotterdam 

Port Said (Egypt) 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Genova 

Marseille 

Barcelona 

Genova 

Marseille 

Barcelona 

Port Said (Egypt) 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

Port Said (Egypt) 

Port Said (Egypt) 

Port Said (Egypt) 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

-4.6% 

-4.6% 

-4.5% 

-1.0% 

-1.0% 

-1.0% 

-4.6% 

-4.6% 

-4.5% 

-1.0% 

-1.0% 

-1.0% 

-5.6% 

-5.5% 

-5.5% 

-1.4% 

-1.4% 

-1.2% 

4.2% 

4.2% 

4.1% 

7.7% 

7.8% 

7.6% 

4.2% 

4.2% 

4.1% 

7.7% 

7.8% 

7.6% 

5.0% 

5.0% 

4.9% 

9.1% 

9.0% 

9.1% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

0.7% 

0.7% 

0.7% 

4.1% 

4.1% 

4.0% 

0.3% 

0.3% 

0.3% 

3.7% 

3.7% 

3.6% 

0.9% 

0.9% 

0.8% 

4.7% 

4.7% 

4.8% 

More  specifically,  in  such  cases  total  travel  costs  increase  from  around  €17,200  for  a 
21,000  TEU  ship  directed  to  Northern  Europe  and  stopping  in  Egypt  (Port  Said)  to  near 

148 

 
 
 
 
 
 
€201,500  for  a  21,000  TEU  ship  directed    as  well  to  Northern  Europe  but  stopping  in 
Turkey (Mersin) (see Table 53). 

Table 53: Other container routes departing from Shanghai (change of travel costs components in PO3 relative to the 
Baseline) 

Ship size 
TEU 

Origin Port 

Destination 
Port 

Intermediate Port 

Fuel cost  

Time cost  

Ports cost  

TOTAL  

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

14,000 

14,000 

14,000 

14,000 

14,000 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

14,000 
Source: TRUST model, TRT 

Shanghai 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Genova 

Marseille 

Barcelona 

Genova 

Marseille 

Barcelona 

Port Said (Egypt) 

Port Said (Egypt) 

Port Said (Egypt) 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

Port Said (Egypt) 

Port Said (Egypt) 

Port Said (Egypt) 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

Port Said (Egypt) 

Port Said (Egypt) 

Port Said (Egypt) 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

-131,266 

-131,266 

-131,266 

-28,116 

-28,116 

-28,116 

-175,022 

-175,022 

-175,022 

-37,488 

-37,488 

-37,488 

-131,266 

-131,266 

-131,266 

-32,194 

-32,194 

-28,116 

39,667 

39,667 

39,667 

73,250 

73,250 

73,250 

55,250 

55,250 

55,250 

102,027 

102,027 

102,027 

39,667 

39,667 

39,667 

72,000 

72,000 

73,250 

120,827 

120,827 

120,827 

120,827 

120,827 

120,827 

136,955 

136,955 

136,955 

136,955 

136,955 

136,955 

120,827 

120,827 

120,827 

120,827 

120,827 

120,827 

29,228 

29,228 

29,228 

165,962 

165,962 

165,962 

17,183 

17,183 

17,183 

201,494 

201,494 

201,494 

29,228 

29,228 

29,228 

160,633 

160,633 

165,962 

As  in  PO1,  it  should  be  noted  that  these  calculations  do  not  consider  increases  in  ports 
costs and in  charter rates over time. These  costs are kept  constant  in  real  terms  (in 2020 
prices). This implies that an increase in these costs by 2030 may reduce or even offset the 
estimated  costs  saving.  Table  54  shows  for  each  route  the  percentage  increase  in  charter 
rates  that  would  offset  the  cost  savings.  Similarly,  Table  55  shows  for  each  route  the 
percentage increase in port costs that would offset the cost savings219.  

219   As  already  mentioned  for  PO1,  tables  provide  the  increase  in  only  one  cost  component,  but  increases  in  both 
components are more likely to occur. Their different combinations however generate countless possibilities for cost 
increases that would neutralise the costs savings. As an example, a combined increase of 18% in charter rates and of 
23% in ports’ costs would neutralise costs savings of all routes. A similar result is achieved with a combined increase 
of 29% in charter rates and of 18% in port costs. 

149 

 
 
 
 
 
 
                                                           
Table 54: Percentage increase in charter rates that would offset the cost savings in PO3 

Ship size TEU 

Origin Port 

Destination Port 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

21,000 

21,000 

21,000 

21,000 

21,000 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

21,000 
Shanghai 
Source: TRUST model, TRT 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Intermediate  
Port 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Table 55: Percentage increase in port costs that would offset the cost savings in PO3 

Ship size TEU 

Origin Port 

Destination Port 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

21,000 

21,000 

21,000 

21,000 

21,000 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

21,000 
Shanghai 
Source: TRUST model, TRT 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Intermediate  
Port 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Charter rates 
increase 
[%]  

7% 

7% 

7% 

11% 

24% 

36% 

45% 

45% 

45% 

45% 

58% 

70% 

Port costs 
increase 
[%]  

3% 
3% 

3% 

4% 

9% 

13% 

19% 
19% 

19% 

21% 

26% 

31% 

The  analysis  of  the  different  cost  components    reported  in  Table  59  shows  that  although 
fuel costs in the case of an intermediate stop to a non-EU/EEA port are expected to reduce 
in  the range of 1% to 6% (i.e. €26,000 to  €238,600 depending on the route and the ship 
type), travel time costs are projected to increase in the range of 4% to 13% (i.e. €13,300 to 
€102,000)  and  costs  at  ports  are  expected  to  increase  by  50%  (i.e.  €  47,500  to  €137,000 
according to the ship type).  As already mentioned above, this results in an increase of total 
travel costs ranging from about €17,000 for a 21,000 TEU ship travelling from Shanghai to 
North  Europe  (Antwerp,  Rotterdam,  Hamburg)  and  performing  an  intermediate  stop  in 
Egypt  (Port  Said)  to  near  €201,000  if  the  intermediate  stop  is  performed  in  Turkey 
(Mersin). 

These results suggest that also in PO3 the risk of leakage resulting from  containers ships 
route diversion to reduce the amount of traffic that falls in scope of the initiative is low. 

Analysis for dry bulker routes 

150 

 
 
Table 60 and Table 61 provide the analysis of travel time changes and related components 
for  the  analysed  dry  bulker  ships  along  the  direct  route  and  the  route  with  a  stop  to  an 
intermediate non-EU/EEA port). In case of an additional stop, total travel time (navigation 
and time at ports) of dry bulkers is expected to increase in the range of 6% to 13%.  

Looking at the costs reported in Source: TRUST model, TRT 

Table  62,  it  can  be  seen  that  for  all  considered  routes  total  travel  costs  are  expected  to 
increase in case of an additional stop. This increase is estimated in the range of 5% to 14%. 
The  lowest  relative  increase  of  5%  occurs  on  the  routes  from  North  America  (New 
Orleans) to the Mediterranean ports (Marseille, Livorno and Naples) with an intermediate 
stop  in  Algeria  (Oran).  The  highest  relative  increase  of  14%  occurs  on  the  route  from 
South  America  (Ponta  Da  Madeira,  Tubarao)  to  North  Europe  (Rotterdam)  with  an 
intermediate stop in United Kingdom (Grimsby). Overall, total travel costs increase in the 
range of €25,000 to €202,000 depending on the route and the ship type. 

The  analysis  of  the  different  cost  components  reported  in  Table  63  shows  that  although 
fuel costs in the case of an intermediate stop to a non-EU/EEA ports are expected to reduce 
by  up  to  5%  (i.e.  the  overall  reduction  ranges  between  €2,200  and  €32,600),  travel  time 
costs would increase in the range of 6% to 13% (i.e. €11,000 to €50,000) and costs at ports 
are projected to increase by 50% (i.e. €27,000 to €163,000).  

Similarly to PO1, also for PO3 it can be concluded that the risk of leakage resulting from 
dry  bulkers’  route  diversion  to  reduce  the  amount  of  traffic  that  falls  in  scope  of  the 
initiative is very low. 

Analysis for tankers routes 

In case of an additional stop performed to a non-EU/EEA port, total travel time (navigation 
and time at ports) of tankers for all considered routes is expected to grow in the range of 
6%  to  20%  (see  Table  64).  The  same  applies  to  total  travel  costs  (Table  66)  that  are 
expected to  increase for  all considered routes. Depending on the route and the ship  type, 
this increase is estimated in the range of 7% to 23% (i.e. €71,000 to €133,000). The lowest 
relative  increase  of  7%  occurs  on  the  routes  from  the  Arabian  Gulf  (Ju’aymah)  to  the 
Northern  Europe  ports  (Antwerp,  Rotterdam)  with  an  intermediate  stop  in  Egypt 
(Alexandria). The highest relative increase of 23% occurs on the route from North Africa 
(Arzew)  to  North  Europe  (Antwerp  and  Rotterdam)  with  an  intermediate  stop  in  United 
Kingdom (Medway). 

Looking at the different cost components (Table 67) it can be seen that although fuel costs 
are  expected  to  reduce  in  the  case  of  an  intermediate  stop  by  up  to  5%  (i.e.  €1,800  to 
€21,200),  travel  time  costs  are  projected  to  increase  in  the  range  of  6%  to  20%  (i.e. 
€26,000 to €50,000) and costs at ports would increase by 50% (i.e. €61,000 to €97,000).  

On  the  basis  of  this  analysis  it  can  be  concluded  that  also  for  PO3  the  risk  of  leakage 
resulting from tankers route diversion to reduce the amount of traffic that falls in scope of 
the requirements is very low. 

The detailed results for PO3 for all ship types are provided in the tables below. 

151 

 
 
Container ship routes – detailed results for PO3 

Table 56: Container ship routes - Travel times 

Ship size 
 TEU 

Origin Region 

Origin Port 

Destination 
Region 

Destination Port 

Total travel time 
direct route 

Days 

Hours 

Total [h] 

Intermediate Port 

Total travel time 
intermediate stop 

Diff. Travel 
time 

Days  Hours 

Total 
[h] 

[h] 

[%] 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

14,000 

14,000 

14,000 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

North Europe 

Antwerp 

North Europe 

Rotterdam 

North Europe 

North Europe 

Hamburg 

Antwerp 

North Europe 

Rotterdam 

North Europe 

North Europe 

Hamburg 

Antwerp 

North Europe 

Rotterdam 

North Europe 

North Europe 

Hamburg 

Antwerp 

North Europe 

Rotterdam 

North Europe 

North Europe 

Hamburg 

Antwerp 

North Europe 

Rotterdam 

North Europe 

North Europe 

Hamburg 

Antwerp 

North Europe 

Rotterdam 

North Europe 

North Europe 

Hamburg 

Antwerp 

North Europe 

Rotterdam 

North Europe 

North Europe 

Hamburg 

Antwerp 

North Europe 

Rotterdam 

North Europe 

Hamburg 

Mediterranean 

Genova 

Mediterranean 

Marseille 

Mediterranean 

Barcelona 

33 

33 

34 

33 

33 

34 

33 

33 

34 

33 

33 

34 

33 

33 

34 

33 

33 

34 

33 

33 

34 

33 

33 

34 

28 

28 

28 

18 

18 

12 

18 

18 

12 

18 

18 

12 

18 

18 

12 

18 

18 

12 

18 

18 

12 

18 

18 

12 

18 

18 

12 

5 

12 

17 

810 

810 

828 

810 

810 

828 

810 

810 

828 

810 

810 

828 

810 

810 

828 

810 

810 

828 

810 

810 

828 

810 

810 

828 

677 

684 

689 

Port Said (Egypt) 

Port Said (Egypt) 

Port Said (Egypt) 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Port Said (Egypt) 

Port Said (Egypt) 

Port Said (Egypt) 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Port Said (Egypt) 

Port Said (Egypt) 

Port Said (Egypt) 

35 

35 

35 

36 

36 

37 

35 

35 

35 

35 

35 

36 

35 

35 

35 

36 

36 

37 

35 

35 

35 

35 

35 

36 

29 

29 

30 

4 

4 

22 

9 

9 

3 

5 

4 

23 

9 

8 

1 

4 

4 

22 

9 

9 

3 

5 

4 

23 

9 

8 

1 

15 

22 

3 

844 

844 

862 

873 

873 

891 

845 

844 

863 

849 

848 

865 

844 

844 

862 

873 

873 

891 

845 

844 

863 

849 

848 

865 

711 

718 

723 

34 

34 

34 

63 

63 

63 

35 

35 

35 

39 

38 

37 

34 

34 

34 

63 

63 

63 

35 

35 

35 

39 

38 

37 

34 

34 

34 

4% 

4% 

4% 

8% 

8% 

8% 

4% 

4% 

4% 

5% 

5% 

4% 

4% 

4% 

4% 

8% 

8% 

8% 

4% 

4% 

4% 

5% 

5% 

4% 

5% 

5% 

5% 

152 

 
 
Ship size 
 TEU 

Origin Region 

Origin Port 

Destination 
Region 

Destination Port 

Total travel time 
direct route 

Days 

Hours 

Total [h] 

Intermediate Port 

Total travel time 
intermediate stop 

Diff. Travel 
time 

Days  Hours 

Total 
[h] 

[h] 

[%] 

14,000 

14,000 

14,000 

12,000 

12,000 

12,000 

12,000 

12,000 

12,000 

8,000 

8,000 

8,000 

8,000 

8,000 

8,000 

4,500 

4,500 

4,500 

4,500 

4,500 

4,500 

4,000 

4,000 

4,000 

4,000 

4,000 

South East Asia 

South East Asia 

South East Asia 

North America 

North America 

North America 

North America 

North America 

North America 

North America 

North America 

North America 

North America 

North America 

North America 

South America 

South America 

South America 

North America 

North America 

North America 

South America 

South America 

South America 

North America 

North America 

4,000 
North America 
Source: TRUST model, TRT 

Shanghai 

Shanghai 

Shanghai 

New York 

New York 

New York 

Savannah 

Savannah 

Savannah 

New York 

New York 

New York 

Savannah 

Savannah 

Savannah 

Santos 

Santos 

Santos 

Long Beach 

Long Beach 

Long Beach 

Santos 

Santos 

Santos 

Long Beach 

Long Beach 

Long Beach 

Mediterranean 

Genova 

Mediterranean 

Marseille 

Mediterranean 

Barcelona 

North Europe 

Antwerp 

North Europe 

Rotterdam 

North Europe 

North Europe 

Hamburg 

Antwerp 

North Europe 

Rotterdam 

North Europe 

Hamburg 

Mediterranean 

Genova 

Mediterranean 

Marseille 

Mediterranean 

Barcelona 

Mediterranean 

Genova 

Mediterranean 

Marseille 

Mediterranean 

Barcelona 

Mediterranean 

Genova 

Mediterranean 

Marseille 

Mediterranean 

Barcelona 

Mediterranean 

Genova 

Mediterranean 

Marseille 

Mediterranean 

Barcelona 

North Europe 

Antwerp 

North Europe 

Rotterdam 

North Europe 

North Europe 

Hamburg 

Antwerp 

North Europe 

Rotterdam 

North Europe 

Hamburg 

28 

28 

28 

12 

12 

13 

14 

14 

14 

14 

14 

13 

15 

15 

14 

17 

17 

16 

26 

26 

25 

18 

18 

19 

25 

25 

26 

5 

12 

17 

12 

12 

5 

4 

3 

17 

12 

0 

12 

22 

10 

22 

23 

12 

23 

14 

3 

15 

14 

14 

8 

12 

12 

6 

677 

684 

689 

300 

300 

317 

340 

339 

353 

348 

336 

324 

382 

370 

358 

431 

420 

407 

638 

627 

615 

446 

446 

464 

612 

612 

630 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

30 

31 

31 

14 

14 

14 

15 

15 

16 

15 

15 

14 

17 

16 

16 

19 

18 

18 

28 

27 

27 

20 

20 

20 

27 

27 

27 

19 

2 

8 

3 

1 

18 

18 

17 

10 

22 

11 

22 

8 

21 

8 

9 

22 

10 

1 

13 

1 

5 

4 

21 

3 

1 

19 

739 

746 

752 

339 

337 

354 

378 

377 

394 

382 

371 

358 

416 

405 

392 

466 

454 

442 

673 

661 

649 

485 

484 

501 

651 

649 

667 

62 

62 

63 

39 

38 

38 

39 

38 

41 

34 

34 

34 

34 

34 

34 

34 

34 

34 

34 

34 

34 

39 

38 

37 

39 

38 

37 

9% 

9% 

9% 

13% 

13% 

12% 

11% 

11% 

12% 

10% 

10% 

11% 

9% 

9% 

10% 

8% 

8% 

8% 

5% 

5% 

6% 

9% 

8% 

8% 

6% 

6% 

6% 

153 

 
 
 
Table 57: Container ship routes – Time comparison of the route with an intermediate stop relative to the direct route (% change in travel time components) 

Ship size 
TEU 

Origin Port 

Destination 
Port 

Total travel time  
direct route 

Sailing 
time [h] 

Time at 
ports [h] 

Total [h] 

Intermediate Port 

Total travel time  
intermediate stop 

Sailing 
time [h] 

Time at 
ports [h] 

Total [h] 

Sailing 
time [%] 

Time at 
ports [%] 

Total [%] 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Genova 

Marseille 

Barcelona 

Genova 

Marseille 

Barcelona 

752 

752 

770 

752 

752 

770 

752 

752 

770 

752 

752 

770 

752 

752 

770 

752 

752 

770 

752 

752 

770 

752 

752 

770 

619 

626 

631 

619 

626 

631 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

810 

810 

828 

810 

810 

828 

810 

810 

828 

810 

810 

828 

810 

810 

828 

810 

810 

828 

810 

810 

828 

810 

810 

828 

677 

684 

689 

677 

684 

689 

Port Said (Egypt) 

Port Said (Egypt) 

Port Said (Egypt) 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Port Said (Egypt) 

Port Said (Egypt) 

Port Said (Egypt) 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Port Said (Egypt) 

Port Said (Egypt) 

Port Said (Egypt) 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

752 

752 

770 

781 

781 

799 

753 

752 

771 

757 

756 

773 

752 

752 

770 

781 

781 

799 

753 

752 

771 

757 

756 

773 

619 

626 

631 

647 

654 

660 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

844 

844 

862 

873 

873 

891 

845 

844 

863 

849 

848 

865 

844 

844 

862 

873 

873 

891 

845 

844 

863 

849 

848 

865 

711 

718 

723 

739 

746 

752 

0% 

0% 

0% 

4% 

4% 

4% 

0% 

0% 

0% 

1% 

0% 

0% 

0% 

0% 

0% 

4% 

4% 

4% 

0% 

0% 

0% 

1% 

0% 

0% 

0% 

0% 

0% 

4% 

4% 

5% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

4% 

4% 

4% 

8% 

8% 

8% 

4% 

4% 

4% 

5% 

5% 

4% 

4% 

4% 

4% 

8% 

8% 

8% 

4% 

4% 

4% 

5% 

5% 

4% 

5% 

5% 

5% 

9% 

9% 

9% 

154 

 
 
Ship size 
TEU 

Origin Port 

Destination 
Port 

Total travel time  
direct route 

Sailing 
time [h] 

Time at 
ports [h] 

Total [h] 

Intermediate Port 

Total travel time  
intermediate stop 

Sailing 
time [h] 

Time at 
ports [h] 

Total [h] 

Sailing 
time [%] 

Time at 
ports [%] 

Total [%] 

12,000 

12,000 

12,000 

12,000 

12,000 

12,000 

8,000 

8,000 

8,000 

8,000 

8,000 

8,000 

4,500 

4,500 

4,500 

4,500 

4,500 

4,500 

4,000 

4,000 

4,000 

4,000 

4,000 

New York 

New York 

New York 

Savannah 

Savannah 

Savannah 

New York 

New York 

New York 

Savannah 

Savannah 

Savannah 

Santos 

Santos 

Santos 

Long Beach 

Long Beach 

Long Beach 

Santos 

Santos 

Santos 

Long Beach 

Long Beach 

4,000 
Source: TRUST model, TRT 

Long Beach 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Genova 

Marseille 

Barcelona 

Genova 

Marseille 

Barcelona 

Genova 

Marseille 

Barcelona 

Genova 

Marseille 

Barcelona 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Table 58: Container ship routes - Travel costs 

Ship size 
TEU 

Origin Port 

Destination 
Port 

242 

242 

259 

282 

281 

295 

290 

278 

266 

324 

312 

300 

373 

362 

349 

580 

569 

557 

388 

388 

406 

554 

554 

572 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

58 

300 

300 

317 

340 

339 

353 

348 

336 

324 

382 

370 

358 

431 

420 

407 

638 

627 

615 

446 

446 

464 

612 

612 

630 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

247 

245 

262 

286 

285 

302 

290 

279 

266 

324 

313 

300 

374 

362 

350 

581 

569 

557 

393 

392 

409 

559 

557 

575 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

92 

339 

337 

354 

378 

377 

394 

382 

371 

358 

416 

405 

392 

466 

454 

442 

673 

661 

649 

485 

484 

501 

651 

649 

667 

2% 

2% 

1% 

2% 

1% 

2% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

0% 

1% 

1% 

1% 

1% 

1% 

0% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

59% 

13% 

13% 

12% 

11% 

11% 

12% 

10% 

10% 

11% 

9% 

9% 

10% 

8% 

8% 

8% 

5% 

5% 

6% 

9% 

8% 

8% 

6% 

6% 

6% 

Total travel cost 
direct route 

Fuel cost  
[€] 

Time cost  
[€] 

Ports cost  
[€] 

TOTAL  
[€] 

Intermediate Port 

Total travel cost 
intermediate stop 

Fuel cost  
[€] 

Time cost  
[€] 

Ports cost  
[€] 

TOTAL  
[€] 

Diff. 
Travel 
cost [%] 

155 

 
 
Ship size 
TEU 

Origin Port 

Destination 
Port 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

12,000 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

New York 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Genova 

Marseille 

Barcelona 

Genova 

Marseille 

Barcelona 

Antwerp 

Total travel cost 
direct route 

Fuel cost  
[€] 
2,863,144 

Time cost  
[€] 
945,167 

Ports cost  
[€] 
241,655 

Intermediate Port 

TOTAL  
[€] 

4,049,966  Port Said (Egypt) 

Total travel cost 
intermediate stop 

Fuel cost  
[€] 
2,731,878 

Time cost  
[€] 
984,833 

Ports cost  
[€] 
362,482 

2,861,785 

2,930,576 

2,863,144 

2,861,785 

2,930,576 

2,863,144 

2,861,785 

2,930,576 

2,863,144 

2,861,785 

2,930,576 

944,750 

965,833 

945,167 

944,750 

965,833 

945,167 

944,750 

965,833 

945,167 

944,750 

965,833 

3,817,526 

1,316,482 

3,815,713 

1,315,902 

3,907,435 

1,345,268 

3,817,526 

1,316,482 

3,815,713 

1,315,902 

3,907,435 

1,345,268 

3,817,526 

1,316,482 

3,815,713 

1,315,902 

3,907,435 

1,345,268 

3,817,526 

1,316,482 

3,815,713 

1,315,902 

3,907,435 

1,345,268 

2,357,404 

2,382,691 

2,403,355 

2,357,404 

2,382,691 

2,403,355 

745,741 

790,167 

797,917 

804,250 

790,167 

797,917 

804,250 

312,500 

241,655 

241,655 

241,655 

241,655 

241,655 

241,655 

241,655 

241,655 

241,655 

241,655 

241,655 

273,909 

273,909 

273,909 

273,909 

273,909 

273,909 

273,909 

273,909 

273,909 

273,909 

273,909 

273,909 

241,655 

241,655 

241,655 

241,655 

241,655 

241,655 

229,553 

4,048,189  Port Said (Egypt) 

2,730,518 

984,417 

4,138,064  Port Said (Egypt) 

2,799,310 

1,005,500 

4,049,966  Mersin (Turkey) 

2,835,028 

1,018,417 

4,048,189  Mersin (Turkey) 

2,833,669 

1,018,000 

4,138,064  Mersin (Turkey) 

2,902,461 

1,039,083 

4,049,966  Tangier (Morocco) 

4,048,189  Tangier (Morocco) 

2,699,187 

2,697,827 

985,583 

985,167 

4,138,064  Tangier (Morocco) 

2,766,619 

1,006,250 

4,049,966  Felixstowe (UK) 

4,048,189  Felixstowe (UK) 

2,692,075 

2,686,637 

990,417 

988,750 

4,138,064  Felixstowe (UK) 

2,751,622 

1,008,667 

5,407,917  Port Said (Egypt) 

3,642,504 

1,371,732 

5,405,524  Port Said (Egypt) 

3,640,691 

1,371,152 

5,526,612  Port Said (Egypt) 

3,732,413 

1,400,518 

5,407,917  Mersin (Turkey) 

3,780,038 

1,418,509 

5,405,524  Mersin (Turkey) 

3,778,225 

1,417,929 

5,526,612  Mersin (Turkey) 

3,869,947 

1,447,295 

5,407,917  Tangier (Morocco) 

3,598,916 

1,372,777 

5,405,524  Tangier (Morocco) 

3,597,103 

1,372,196 

5,526,612  Tangier (Morocco) 

3,688,825 

1,401,563 

5,407,917  Felixstowe (UK) 

3,589,433 

1,379,509 

5,405,524  Felixstowe (UK) 

3,582,182 

1,377,188 

5,526,612  Felixstowe (UK) 

3,668,829 

1,404,929 

3,389,225  Port Said (Egypt) 

3,422,262  Port Said (Egypt) 

3,449,260  Port Said (Egypt) 

3,389,225  Mersin (Turkey) 

3,422,262  Mersin (Turkey) 

3,449,260  Mersin (Turkey) 

1,287,793  Felixstowe (UK) 

2,226,137 

2,251,424 

2,272,089 

2,325,209 

2,350,496 

2,375,240 

711,922 

829,833 

837,583 

843,917 

862,167 

869,917 

877,500 

352,902 

362,482 

362,482 

362,482 

362,482 

362,482 

362,482 

362,482 

362,482 

362,482 

362,482 

362,482 

410,864 

410,864 

410,864 

410,864 

410,864 

410,864 

410,864 

410,864 

410,864 

410,864 

410,864 

410,864 

362,482 

362,482 

362,482 

362,482 

362,482 

362,482 

344,329 

Diff. 
Travel 
cost [%] 

TOTAL  
[€] 

4,079,194 

4,077,417 

4,167,292 

4,215,927 

4,214,151 

4,304,026 

4,047,252 

4,045,476 

4,135,351 

4,044,974 

4,037,869 

4,122,771 

5,425,100 

5,422,707 

5,543,795 

5,609,411 

5,607,018 

5,728,106 

5,382,557 

5,380,163 

5,501,252 

5,379,806 

5,370,234 

5,484,621 

3,418,453 

3,451,490 

3,478,488 

3,549,858 

3,582,895 

3,615,222 

1,409,152 

0.7% 

0.7% 

0.7% 

4.1% 

4.1% 

4.0% 

-0.1% 

-0.1% 

-0.1% 

-0.1% 

-0.3% 

-0.4% 

0.3% 

0.3% 

0.3% 

3.7% 

3.7% 

3.6% 

-0.5% 

-0.5% 

-0.5% 

-0.5% 

-0.7% 

-0.8% 

0.9% 

0.9% 

0.8% 

4.7% 

4.7% 

4.8% 

9.4% 

156 

 
 
Ship size 
TEU 

Origin Port 

Destination 
Port 

12,000 

12,000 

12,000 

12,000 

12,000 

8,000 

8,000 

8,000 

8,000 

8,000 

8,000 

4,500 

4,500 

4,500 

4,500 

4,500 

4,500 

4,000 

4,000 

4,000 

4,000 

4,000 

New York 

New York 

Savannah 

Savannah 

Savannah 

New York 

New York 

New York 

Savannah 

Savannah 

Savannah 

Santos 

Santos 

Santos 

Long Beach 

Long Beach 

Long Beach 

Santos 

Santos 

Santos 

Long Beach 

Long Beach 

4,000 
Source: TRUST model, TRT 

Long Beach 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Genova 

Marseille 

Barcelona 

Genova 

Marseille 

Barcelona 

Genova 

Marseille 

Barcelona 

Genova 

Marseille 

Barcelona 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Total travel cost 
direct route 

Fuel cost  
[€] 
744,640 

Time cost  
[€] 
312,128 

Ports cost  
[€] 
229,553 

796,807 

867,683 

866,582 

908,404 

577,251 

554,890 

529,966 

645,331 

622,970 

598,045 

473,475 

459,245 

443,384 

736,224 

721,995 

706,133 

492,599 

492,145 

515,076 

703,052 

702,599 

725,529 

329,762 

353,720 

353,348 

367,485 

289,583 

280,238 

269,821 

318,036 

308,690 

298,274 

247,907 

241,459 

234,271 

366,973 

360,525 

353,338 

161,753 

161,623 

168,174 

221,876 

221,746 

228,297 

229,553 

229,553 

229,553 

229,553 

200,971 

200,971 

200,971 

200,971 

200,971 

200,971 

117,399 

117,399 

117,399 

117,399 

117,399 

117,399 

94,893 

94,893 

94,893 

94,893 

94,893 

94,893 

Intermediate Port 

TOTAL  
[€] 

1,286,321  Felixstowe (UK) 

1,356,121  Felixstowe (UK) 

1,450,956  Felixstowe (UK) 

1,449,483  Felixstowe (UK) 

1,505,441  Felixstowe (UK) 

1,067,805  Tangier (Morocco) 

1,036,099  Tangier (Morocco) 

1,000,758  Tangier (Morocco) 

1,164,337  Tangier (Morocco) 

1,132,631  Tangier (Morocco) 

1,097,290  Tangier (Morocco) 

838,781  Tangier (Morocco) 

818,103  Tangier (Morocco) 

795,054  Tangier (Morocco) 

1,220,596  Tangier (Morocco) 

1,199,918  Tangier (Morocco) 

1,176,870  Tangier (Morocco) 

749,244  Felixstowe (UK) 

748,661  Felixstowe (UK) 

778,143  Felixstowe (UK) 

1,019,820  Felixstowe (UK) 

1,019,238  Felixstowe (UK) 

1,048,719  Felixstowe (UK) 

Total travel cost 
intermediate stop 

Fuel cost  
[€] 
707,520 

Time cost  
[€] 
351,414 

Ports cost  
[€] 
344,329 

760,126 

825,745 

821,343 

873,950 

547,742 

525,381 

500,457 

611,289 

588,928 

564,004 

447,630 

433,400 

417,539 

692,886 

678,656 

662,795 

466,321 

464,508 

486,170 

662,762 

660,949 

682,611 

369,196 

394,122 

392,634 

410,417 

318,214 

308,869 

298,452 

346,667 

337,321 

326,905 

267,663 

261,214 

254,027 

386,729 

380,280 

373,093 

175,813 

175,295 

181,483 

235,936 

235,418 

241,606 

344,329 

344,329 

344,329 

344,329 

301,456 

301,456 

301,456 

301,456 

301,456 

301,456 

176,098 

176,098 

176,098 

176,098 

176,098 

176,098 

142,339 

142,339 

142,339 

142,339 

142,339 

142,339 

Diff. 
Travel 
cost [%] 

9.1% 

8.7% 

7.8% 

7.5% 

8.2% 

9.3% 

9.6% 

TOTAL  
[€] 

1,403,262 

1,473,652 

1,564,196 

1,558,306 

1,628,695 

1,167,413 

1,135,707 

1,100,366 

10.0% 

1,259,412 

1,227,706 

1,192,365 

891,391 

870,713 

847,664 

1,255,713 

1,235,035 

1,211,986 

784,472 

782,142 

809,992 

1,041,037 

1,038,706 

1,066,556 

8.2% 

8.4% 

8.7% 

6.3% 

6.4% 

6.6% 

2.9% 

2.9% 

3.0% 

4.7% 

4.5% 

4.1% 

2.1% 

1.9% 

1.7% 

Table 59: Containers routes – Costs comparison of the route with an intermediate stop relative to the direct route (% change in travel costs components) 

Ship size TEU 

Origin Region 

Origin Port 

Destination Region 

Destination Port 

Intermediate Port 

Fuel cost  
[%] 

Time cost  
[%] 

Ports cost  
[%] 

TOTAL  
[%] 

14,000 

14,000 

South East Asia 

South East Asia 

Shanghai 

Shanghai 

North Europe 

North Europe 

Antwerp 

Rotterdam 

Port Said (Egypt) 

Port Said (Egypt) 

-4.6% 

-4.6% 

4.2% 

4.2% 

50% 

50% 

0.7% 

0.7% 

157 

 
 
Ship size TEU 

Origin Region 

Origin Port 

Destination Region 

Destination Port 

Intermediate Port 

Fuel cost  
[%] 

Time cost  
[%] 

Ports cost  
[%] 

TOTAL  
[%] 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

21,000 

14,000 

14,000 

14,000 

14,000 

14,000 

14,000 

12,000 

12,000 

12,000 

12,000 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

South East Asia 

North America 

North America 

North America 

North America 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

Shanghai 

New York 

New York 

New York 

Savannah 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

Mediterranean 

Mediterranean 

Mediterranean 

Mediterranean 

Mediterranean 

Mediterranean 

North Europe 

North Europe 

North Europe 

North Europe 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Genova 

Marseille 

Barcelona 

Genova 

Marseille 

Barcelona 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Port Said (Egypt) 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Port Said (Egypt) 

Port Said (Egypt) 

Port Said (Egypt) 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Port Said (Egypt) 

Port Said (Egypt) 

Port Said (Egypt) 

Mersin (Turkey) 

Mersin (Turkey) 

Mersin (Turkey) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

-4.5% 

-1.0% 

-1.0% 

-1.0% 

-5.7% 

-5.7% 

-5.6% 

-6.0% 

-6.1% 

-6.1% 

-4.6% 

-4.6% 

-4.5% 

-1.0% 

-1.0% 

-1.0% 

-5.7% 

-5.7% 

-5.6% 

-6.0% 

-6.1% 

-6.1% 

-5.6% 

-5.5% 

-5.5% 

-1.4% 

-1.4% 

-1.2% 

-4.5% 

-5.0% 

-4.6% 

-4.8% 

4.1% 

7.7% 

7.8% 

7.6% 

4.3% 

4.3% 

4.2% 

4.8% 

4.7% 

4.4% 

4.2% 

4.2% 

4.1% 

7.7% 

7.8% 

7.6% 

4.3% 

4.3% 

4.2% 

4.8% 

4.7% 

4.4% 

5.0% 

5.0% 

4.9% 

9.1% 

9.0% 

9.1% 

12.9% 

12.6% 

12.0% 

11.4% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

0.7% 

4.1% 

4.1% 

4.0% 

-0.1% 

-0.1% 

-0.1% 

-0.1% 

-0.3% 

-0.4% 

0.3% 

0.3% 

0.3% 

3.7% 

3.7% 

3.6% 

-0.5% 

-0.5% 

-0.5% 

-0.5% 

-0.7% 

-0.8% 

0.9% 

0.9% 

0.8% 

4.7% 

4.7% 

4.8% 

9.4% 

9.1% 

8.7% 

7.8% 

158 

 
 
Ship size TEU 

Origin Region 

Origin Port 

Destination Region 

Destination Port 

Intermediate Port 

Fuel cost  
[%] 

Time cost  
[%] 

Ports cost  
[%] 

TOTAL  
[%] 

12,000 

12,000 

8,000 

8,000 

8,000 

8,000 

8,000 

8,000 

4,500 

4,500 

4,500 

4,500 

4,500 

4,500 

4,000 

4,000 

4,000 

4,000 

4,000 

North America 

North America 

North America 

North America 

North America 

North America 

North America 

North America 

South America 

South America 

South America 

North America 

North America 

North America 

South America 

South America 

South America 

North America 

North America 

4,000 
Source: TRUST model, TRT 

North America 

Savannah 

Savannah 

New York 

New York 

New York 

Savannah 

Savannah 

Savannah 

Santos 

Santos 

Santos 

Long Beach 

Long Beach 

Long Beach 

Santos 

Santos 

Santos 

Long Beach 

Long Beach 

Long Beach 

North Europe 

North Europe 

Mediterranean 

Mediterranean 

Mediterranean 

Mediterranean 

Mediterranean 

Mediterranean 

Mediterranean 

Mediterranean 

Mediterranean 

Mediterranean 

Mediterranean 

Mediterranean 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

North Europe 

Rotterdam 

Hamburg 

Genova 

Marseille 

Barcelona 

Genova 

Marseille 

Barcelona 

Genova 

Marseille 

Barcelona 

Genova 

Marseille 

Barcelona 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Felixstowe (UK) 

Felixstowe (UK) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Tangier (Morocco) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

Felixstowe (UK) 

-5.2% 

-3.8% 

-5.1% 

-5.3% 

-5.6% 

-5.3% 

-5.5% 

-5.7% 

-5.5% 

-5.6% 

-5.8% 

-5.9% 

-6.0% 

-6.1% 

-5.3% 

-5.6% 

-5.6% 

-5.7% 

-5.9% 

-5.9% 

11.1% 

11.7% 

9.9% 

10.2% 

10.6% 

9.0% 

9.3% 

9.6% 

8.0% 

8.2% 

8.4% 

5.4% 

5.5% 

5.6% 

8.7% 

8.5% 

7.9% 

6.3% 

6.2% 

5.8% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

50% 

7.5% 

8.2% 

9.3% 

9.6% 

10.0% 

8.2% 

8.4% 

8.7% 

6.3% 

6.4% 

6.6% 

2.9% 

2.9% 

3.0% 

4.7% 

4.5% 

4.1% 

2.1% 

1.9% 

1.7% 

Dry bulker ships routes – detailed results for PO3 

Table 60: Dry bulkers routes - Travel times 

Ship size [DWT]- 
Goods 

Origin Region 

Origin Port 

Destination 
Region 

Destination 
Port 

65,000-grain 
65,000-grain 
65,000-grain 

North America 
North America 
North America 

New Orleans 
New Orleans 
New Orleans 

North Europe 
North Europe 
North Europe 

Antwerp 
Rotterdam 
Hamburg 

Total travel time 
direct route 

Days  Hours 

20 
20 
21 

20 
19 
14 

Total 
[h] 

500 
499 
518 

Total travel time 
intermediate stop 

Diff. Travel time 

Intermediate 
Port 

Days  Hours 

Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 

23 
23 
23 

6 
1 
17 

Total 
[h] 

558 
553 
569 

[h] 

58 
54 
50 

[%] 

12% 
11% 
10% 

159 

 
 
Ship size [DWT]- 
Goods 

Origin Region 

Origin Port 

Destination 
Region 

Destination 
Port 

65,000-grain 
65,000-grain 
65,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
28,000-grain 
28,000-grain 
28,000-grain 
28,000-grain 
28,000-grain 
28,000-grain 
200,000-iron ore 
200,000-iron ore 
300,000-iron ore 
300,000-iron ore 
165,000-coal 
165,000-coal 
70,000-coal 
165,000-coal 
165,000-coal 
165,000-coal 
165,000-coal 
200,000-iron ore 
Source: TRUST model, TRT 

South America 
South America 
South America 
North America 
North America 
North America 
South America 
South America 
South America 
North America 
North America 
South America 
South America 
North America 
North America 
North America 
South America 
South America 
South America 
South America 
South America 
South America 
South America 
South Africa 
South Africa 
North America 
South America 
South America 
South America 
South America 
South America 

Santos 
Santos 
Santos 
New Orleans 
New Orleans 
New Orleans 
Santos 
Santos 
Santos 
New Orleans 
New Orleans 
Santos 
Santos 
New Orleans 
New Orleans 
New Orleans 
Santos 
Santos 
Santos 
Tubarao 
Tubarao 
Tubarao 
Tubarao 
Durban 
Durban 
New Orleans 
Buenaventura 
Buenaventura 
Ponta Da Madeira 
Ponta Da Madeira 
Tubarao 

Livorno 

Livorno 

Antwerp 
North Europe 
Rotterdam 
North Europe 
Hamburg 
North Europe 
Antwerp 
North Europe 
Rotterdam 
North Europe 
Hamburg 
North Europe 
Antwerp 
North Europe 
Rotterdam 
North Europe 
North Europe 
Hamburg 
Mediterranean   Marseille 
Mediterranean  
Mediterranean   Marseille 
Mediterranean  
Mediterranean   Marseille 
Mediterranean  
Mediterranean  
Mediterranean   Marseille 
Mediterranean  
Mediterranean  
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
Mediterranean  
North Europe 
North Europe 
North Europe 
North Europe 
Mediterranean  

Livorno 
Naples 
Rotterdam 
Hamburg 
Rotterdam 
Hamburg 
Rotterdam 
Hamburg 
Taranto 
Rotterdam 
Hamburg 
Rotterdam 
Hamburg 
Taranto 

Livorno 
Naples 

Total travel time 
direct route 

Days  Hours 

Total 
[h] 

23 
22 
23 
20 
20 
21 
23 
22 
23 
22 
22 
21 
22 
22 
22 
23 
21 
22 
22 
21 
22 
21 
22 
28 
29 
24 
22 
23 
17 
18 
21 

0 
24 
23 
20 
19 
14 
0 
24 
23 
8 
24 
15 
6 
8 
24 
10 
15 
6 
17 
6 
5 
6 
5 
17 
16 
10 
2 
1 
23 
22 
23 

552 
552 
575 
500 
499 
518 
552 
552 
575 
536 
552 
519 
534 
536 
552 
562 
519 
534 
545 
510 
533 
510 
533 
689 
712 
586 
530 
553 
431 
454 
527 

Intermediate 
Port 

Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Oran (Algeria) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Oran (Algeria) 

Total travel time 
intermediate stop 

Diff. Travel time 

Days  Hours 

Total 
[h] 

[h] 

25 
25 
26 
23 
23 
23 
25 
25 
26 
24 
24 
23 
23 
24 
24 
24 
23 
23 
24 
23 
24 
23 
24 
31 
31 
25 
24 
25 
20 
21 
23 

14 
9 
1 
6 
1 
17 
14 
9 
1 
1 
16 
8 
22 
1 
16 
23 
8 
22 
5 
16 
7 
16 
7 
3 
19 
22 
12 
3 
9 
1 
11 

614 
609 
625 
558 
553 
569 
614 
609 
625 
577 
592 
560 
574 
577 
592 
599 
560 
574 
581 
568 
583 
568 
583 
747 
763 
622 
588 
603 
489 
505 
563 

62 
57 
50 
58 
54 
50 
62 
57 
50 
41 
40 
41 
40 
41 
40 
37 
41 
40 
37 
57 
50 
57 
50 
57 
50 
36 
57 
50 
57 
50 
36 

[%] 

11% 
10% 
9% 
12% 
11% 
10% 
11% 
10% 
9% 
8% 
7% 
8% 
7% 
8% 
7% 
6% 
8% 
7% 
7% 
11% 
9% 
11% 
9% 
8% 
7% 
6% 
11% 
9% 
13% 
11% 
7% 

160 

 
 
Table 61: Dry bulkers routes – Time comparison of the route with an intermediate stop relative to the direct route (% change in travel time components) 

Ship size [DWT]- 
Goods 

Origin Port 

Destination 
Port 

65,000-grain 
65,000-grain 
65,000-grain 
65,000-grain 
65,000-grain 
65,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
28,000-grain 
28,000-grain 
28,000-grain 
28,000-grain 
28,000-grain 
28,000-grain 
200,000-iron ore 
200,000-iron ore 
300,000-iron ore 
300,000-iron ore 
165,000-coal 
165,000-coal 
70,000-coal 

New Orleans 
New Orleans 
New Orleans 
Santos 
Santos 
Santos 
New Orleans 
New Orleans 
New Orleans 
Santos 
Santos 
Santos 
New Orleans 
New Orleans 
Santos 
Santos 
New Orleans 
New Orleans 
New Orleans 
Santos 
Santos 
Santos 
Tubarao 
Tubarao 
Tubarao 
Tubarao 
Durban 
Durban 
New Orleans 

Antwerp 
Rotterdam 
Hamburg 
Antwerp 
Rotterdam 
Hamburg 
Antwerp 
Rotterdam 
Hamburg 
Antwerp 
Rotterdam 
Hamburg 
Marseille 
Livorno 
Marseille 
Livorno 
Marseille 
Livorno 
Naples 
Marseille 
Livorno 
Naples 
Rotterdam 
Hamburg 
Rotterdam 
Hamburg 
Rotterdam 
Hamburg 
Taranto 

Total travel time direct route 

Sailing 
time [h] 
442 
441 
460 
494 
494 
517 
442 
441 
460 
494 
494 
517 
478 
494 
461 
476 
478 
494 
504 
461 
476 
487 
452 
475 
452 
475 
631 
654 
528 

Time at 
ports [h] 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 

Intermediate Port 

Total [h] 

500 
499 
518 
552 
552 
575 
500 
499 
518 
552 
552 
575 
536 
552 
519 
534 
536 
552 
562 
519 
534 
545 
510 
533 
510 
533 
689 
712 
586 

Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Oran (Algeria) 

Total [h] 

Total travel time intermediate 
stop 
Time at 
ports [h] 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 

Sailing 
time [h] 
466 
461 
477 
522 
517 
533 
466 
461 
477 
522 
517 
533 
485 
500 
468 
482 
485 
500 
507 
468 
482 
489 
476 
491 
476 
491 
655 
671 
530 

558 
553 
569 
614 
609 
625 
558 
553 
569 
614 
609 
625 
577 
592 
560 
574 
577 
592 
599 
560 
574 
581 
568 
583 
568 
583 
747 
763 
622 

Sailing 
time [%] 

Time at 
ports [%] 

Total 
[%] 

6% 
4% 
4% 
6% 
5% 
3% 
6% 
4% 
4% 
6% 
5% 
3% 
2% 
1% 
2% 
1% 
2% 
1% 
1% 
2% 
1% 
1% 
5% 
3% 
5% 
3% 
4% 
2% 
0% 

59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 

12% 
11% 
10% 
11% 
10% 
9% 
12% 
11% 
10% 
11% 
10% 
9% 
8% 
7% 
8% 
7% 
8% 
7% 
6% 
8% 
7% 
7% 
11% 
9% 
11% 
9% 
8% 
7% 
6% 

161 

 
 
 
Ship size [DWT]- 
Goods 

Origin Port 

Destination 
Port 

165,000-coal 
165,000-coal 
165,000-coal 
165,000-coal 
200,000-iron ore 
Source: TRUST model, TRT 

Buenaventura 
Buenaventura 
Ponta Da Madeira 
Ponta Da Madeira 
Tubarao 

Rotterdam 
Hamburg 
Rotterdam 
Hamburg 
Taranto 

Table 62: Dry bulkers routes - Travel costs 

Total travel time direct route 

Sailing 
time [h] 
472 
495 
373 
396 
469 

Time at 
ports [h] 
58 
58 
58 
58 
58 

Intermediate Port 

Total [h] 

530 
553 
431 
454 
527 

Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Oran (Algeria) 

Total [h] 

Total travel time intermediate 
stop 
Time at 
ports [h] 
92 
92 
92 
92 
92 

Sailing 
time [h] 
496 
511 
397 
413 
471 

588 
603 
489 
505 
563 

Sailing 
time [%] 

Time at 
ports [%] 

Total 
[%] 

5% 
3% 
6% 
4% 
0% 

59% 
59% 
59% 
59% 
59% 

11% 
9% 
13% 
11% 
7% 

Ship size [DWT]- 
Goods 

Origin Port 

Destination 
Port 

Total travel cost 
direct route 

Total travel cost 
intermediate stop 

Fuel cost  
[€] 

Time cost  
[€] 

Intermediate Port 

TOTAL  
[€] 

Fuel cost  
[€] 

Time cost  
[€] 

Ports cost  
[€] 

TOTAL  
[€] 

Diff. 
Travel 
cost 
[%] 

65,000-grain 

65,000-grain 

65,000-grain 

65,000-grain 

65,000-grain 

65,000-grain 

35,000-grain 

35,000-grain 

35,000-grain 

35,000-grain 

35,000-grain 

35,000-grain 

35,000-grain 

35,000-grain 

35,000-grain 

35,000-grain 

28,000-grain 

28,000-grain 

New Orleans 

New Orleans 

New Orleans 

Santos 

Santos 

Santos 

New Orleans 

New Orleans 

New Orleans 

Santos 

Santos 

Santos 

New Orleans 

New Orleans 

Santos 

Santos 

New Orleans 

New Orleans 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Antwerp 

Rotterdam 

Hamburg 

Marseille 

Livorno 

Marseille 

Livorno 

Marseille 

Livorno 

415,020 

414,593 

432,529 

464,218 

463,791 

485,400 

292,189 

291,888 

304,516 

326,826 

326,525 

341,739 

316,302 

326,706 

304,697 

315,100 

227,626 

235,113 

Ports 
cost  
[€] 
116,099 

196,351 

196,173 

116,099 

203,674 

116,099 

216,926 

116,099 

216,747 

116,099 

225,784 

116,099 

154,083 

153,942 

159,829 

170,228 

170,088 

177,180 

165,323 

170,172 

159,913 

164,762 

157,615 

162,238 

61,436 

61,436 

61,436 

61,436 

61,436 

61,436 

61,436 

61,436 

61,436 

61,436 

53,700 

53,700 

727,470 

726,864 

752,302 

797,242 

796,636 

827,283 

507,707 

507,266 

525,781 

558,490 

558,049 

580,354 

543,061 

558,313 

526,045 

541,298 

438,941 

451,051 

Grimsby (UK) 

Grimsby (UK) 

Grimsby (UK) 

Grimsby (UK) 

Grimsby (UK) 

Grimsby (UK) 

Grimsby (UK) 

Grimsby (UK) 

Grimsby (UK) 

Grimsby (UK) 

Grimsby (UK) 

Grimsby (UK) 

Oran (Algeria) 

Oran (Algeria) 

Oran (Algeria) 

Oran (Algeria) 

Oran (Algeria) 

Oran (Algeria) 

410,290 

405,336 

420,198 

459,561 

454,607 

469,469 

288,859 

285,371 

295,835 

323,547 

320,060 

330,523 

301,815 

311,437 

290,982 

300,604 

217,201 

224,125 

219,319 

217,247 

223,462 

241,394 

239,322 

245,537 

172,106 

170,480 

175,358 

189,429 

187,803 

192,680 

178,020 

182,505 

172,611 

177,095 

169,721 

173,997 

174,148 

174,148 

174,148 

174,148 

174,148 

174,148 

92,154 

92,154 

92,154 

92,154 

92,154 

92,154 

92,154 

92,154 

92,154 

92,154 

80,550 

80,550 

803,757 

796,731 

817,808 

10% 

10% 

9% 

875,102 

10% 

868,077 

889,154 

553,119 

548,005 

563,346 

605,130 

600,016 

615,357 

571,990 

586,096 

555,747 

569,853 

467,471 

478,671 

9% 

7% 

9% 

8% 

7% 

8% 

8% 

6% 

5% 

5% 

6% 

5% 

6% 

6% 

162 

 
 
Ship size [DWT]- 
Goods 

Origin Port 

Destination 
Port 

Total travel cost 
direct route 

Fuel cost  
[€] 

Time cost  
[€] 

28,000-grain 

28,000-grain 

28,000-grain 

28,000-grain 

200,000-iron ore 

200,000-iron ore 

300,000-iron ore 

300,000-iron ore 

165,000-coal 

165,000-coal 

70,000-coal 

165,000-coal 

165,000-coal 

165,000-coal 

165,000-coal 

New Orleans 

Santos 

Santos 

Santos 

Tubarao 

Tubarao 

Tubarao 

Tubarao 

Durban 

Durban 

New Orleans 

Buenaventura 

Buenaventura 

Naples 

Marseille 

Livorno 

Naples 

Rotterdam 

Hamburg 

Rotterdam 

Hamburg 

Rotterdam 

Hamburg 

Taranto 

Rotterdam 

Hamburg 

Ponta Da Madeira 

Rotterdam 

Ponta Da Madeira 

Hamburg 

Tubarao 
200,000-iron ore 
Source: TRUST model, TRT 

Taranto 

240,133 

219,274 

226,761 

231,781 

590,347 

620,375 

688,311 

723,322 

788,789 

817,528 

495,649 

590,002 

618,741 

466,640 

495,379 

611,711 

Ports 
cost  
[€] 
53,700 

53,700 

53,700 

53,700 

TOTAL  
[€] 

459,171 

425,432 

437,541 

445,661 

Intermediate Port 

Oran (Algeria) 

Oran (Algeria) 

Oran (Algeria) 

Oran (Algeria) 

165,338 

152,457 

157,081 

160,181 

339,271 

244,599 

1,174,217 

Grimsby (UK) 

354,566 

244,599 

1,219,540 

Grimsby (UK) 

442,476 

325,884 

1,456,672 

Grimsby (UK) 

462,424 

325,884 

1,511,630 

Grimsby (UK) 

409,543 

199,705 

1,398,037 

Grimsby (UK) 

423,209 

199,705 

1,440,442 

Grimsby (UK) 

235,438 

118,037 

849,125 

Oran (Algeria) 

315,016 

199,705 

1,104,723 

Grimsby (UK) 

328,682 

199,705 

1,147,128 

Grimsby (UK) 

256,356 

199,705 

270,022 

199,705 

922,701 

965,106 

Grimsby (UK) 

Grimsby (UK) 

350,153 

244,599 

1,206,463 

Oran (Algeria) 

Total travel cost 
intermediate stop 

Fuel cost  
[€] 

Time cost  
[€] 

Ports cost  
[€] 

TOTAL  
[€] 

227,500 

209,405 

216,329 

219,704 

581,189 

601,841 

677,634 

701,712 

765,125 

784,890 

470,289 

579,573 

599,338 

464,424 

484,189 

581,600 

176,081 

164,563 

168,839 

170,923 

377,478 

387,997 

492,306 

506,025 

443,680 

453,079 

249,950 

349,154 

358,553 

290,493 

299,892 

374,153 

80,550 

80,550 

80,550 

80,550 

484,131 

454,518 

465,717 

471,177 

366,898 

1,325,566 

366,898 

1,356,736 

488,826 

1,658,766 

488,826 

1,696,563 

299,558 

1,508,364 

299,558 

1,537,527 

177,056 

897,295 

299,558 

1,228,285 

299,558 

1,257,448 

299,558 

1,054,476 

299,558 

1,083,639 

366,898 

1,322,651 

Diff. 
Travel 
cost 
[%] 

5% 

7% 

6% 

6% 

13% 

11% 

14% 

12% 

8% 

7% 

6% 

11% 

10% 

14% 

12% 

10% 

Table 63: Dry bulkers routes – Costs comparison of the route with an intermediate stop relative to the direct route (% change in travel costs components) 

Ship size [DWT]- Goods  Origin Region 

Origin Port 

Destination Region 

Destination Port 

Intermediate Port 

65,000-grain 
65,000-grain 
65,000-grain 
65,000-grain 
65,000-grain 
65,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 

North America 
North America 
North America 
South America 
South America 
South America 
North America 
North America 
North America 

New Orleans 
New Orleans 
New Orleans 
Santos 
Santos 
Santos 
New Orleans 
New Orleans 
New Orleans 

North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 

Antwerp 
Rotterdam 
Hamburg 
Antwerp 
Rotterdam 
Hamburg 
Antwerp 
Rotterdam 
Hamburg 

Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 

Fuel cost  
[€] 
-1% 
-2% 
-3% 
-1% 
-2% 
-3% 
-1% 
-2% 
-3% 

Time cost  
[€] 
12% 
11% 
10% 
11% 
10% 
9% 
12% 
11% 
10% 

Ports cost  
[€] 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 

TOTAL  
[€] 
10% 
10% 
9% 
10% 
9% 
7% 
9% 
8% 
7% 

163 

 
 
Ship size [DWT]- Goods  Origin Region 

Origin Port 

Destination Region 

Destination Port 

Intermediate Port 

35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
35,000-grain 
28,000-grain 
28,000-grain 
28,000-grain 
28,000-grain 
28,000-grain 
28,000-grain 
200,000-iron ore 
200,000-iron ore 
300,000-iron ore 
300,000-iron ore 
165,000-coal 
165,000-coal 
70,000-coal 
165,000-coal 
165,000-coal 
165,000-coal 
165,000-coal 
200,000-iron ore 
Source: TRUST model, TRT 

South America 
South America 
South America 
North America 
North America 
South America 
South America 
North America 
North America 
North America 
South America 
South America 
South America 
South America 
South America 
South America 
South America 
South Africa 
South Africa 
North America 
South America 
South America 
South America 
South America 
South America 

Santos 
Santos 
Santos 
New Orleans 
New Orleans 
Santos 
Santos 
New Orleans 
New Orleans 
New Orleans 
Santos 
Santos 
Santos 
Tubarao 
Tubarao 
Tubarao 
Tubarao 
Durban 
Durban 
New Orleans 
Buenaventura 
Buenaventura 
Ponta Da Madeira 
Ponta Da Madeira 
Tubarao 

North Europe 
North Europe 
North Europe 
Mediterranean  
Mediterranean  
Mediterranean  
Mediterranean  
Mediterranean  
Mediterranean  
Mediterranean  
Mediterranean  
Mediterranean  
Mediterranean  
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
Mediterranean  
North Europe 
North Europe 
North Europe 
North Europe 
Mediterranean  

Liquid bulker ships routes – detailed results for PO3 

Table 64: Tankers routes - Travel times 

Antwerp 
Rotterdam 
Hamburg 
Marseille 
Livorno 
Marseille 
Livorno 
Marseille 
Livorno 
Naples 
Marseille 
Livorno 
Naples 
Rotterdam 
Hamburg 
Rotterdam 
Hamburg 
Rotterdam 
Hamburg 
Taranto 
Rotterdam 
Hamburg 
Rotterdam 
Hamburg 
Taranto 

Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Oran (Algeria) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Oran (Algeria) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Grimsby (UK) 
Oran (Algeria) 

Fuel cost  
[€] 
-1% 
-2% 
-3% 
-5% 
-5% 
-5% 
-5% 
-5% 
-5% 
-5% 
-5% 
-5% 
-5% 
-2% 
-3% 
-2% 
-3% 
-3% 
-4% 
-5% 
-2% 
-3% 
0% 
-2% 
-5% 

Time cost  
[€] 
11% 
10% 
9% 
8% 
7% 
8% 
7% 
8% 
7% 
6% 
8% 
7% 
7% 
11% 
9% 
11% 
9% 
8% 
7% 
6% 
11% 
9% 
13% 
11% 
7% 

Ports cost  
[€] 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 

TOTAL  
[€] 
8% 
8% 
6% 
5% 
5% 
6% 
5% 
6% 
6% 
5% 
7% 
6% 
6% 
13% 
11% 
14% 
12% 
8% 
7% 
6% 
11% 
10% 
14% 
12% 
10% 

Ship size [DWT]- 
Goods 

Origin Region 

Origin Port 

Destination 
Region 

Destination Port 

Total travel time 

Days 

Hours 

Total 
[h] 

Intermediate Port 

Total travel time 

Days  Hours 

Total 
[h] 

Diff. Travel 
time 

[h] 

[%] 

164 

 
 
Ship size [DWT]- 
Goods 

Origin Region 

Origin Port 

Destination 
Region 

Destination Port 

Total travel time 

Days 

Hours 

Total 
[h] 

Intermediate Port 

Total travel time 

Days  Hours 

Total 
[h] 

Diff. Travel 
time 

[h] 

[%] 

70,000-dirty 
70,000-dirty 
130,000-dirty 
130,000-dirty 
135,000-dirty 
135,000-dirty 
135,000-dirty 
135,000-dirty 
90,000-clean 
90,000-clean 
90,000-clean 
90,000-clean 
80,000 
80,000 
70,000-dirty 
70,000-dirty 
70,000-dirty 
130,000-dirty 
130,000-dirty 
130,000-dirty 
130,000-dirty 
130,000-dirty 
130,000-dirty 
90,000-clean 
90,000-clean 
90,000-clean 
Source: TRUST model, TRT 

US Gulf 
US Gulf 
US Gulf 
US Gulf 
West Africa 
West Africa 
West Africa 
West Africa 
Arabian Gulf 
Arabian Gulf 
Arabian Gulf 
Arabian Gulf 
North Africa 
North Africa 
US Gulf 
US Gulf 
US Gulf 
US Gulf 
US Gulf 
US Gulf 
West Africa 
West Africa 
West Africa 
Arabian Gulf 
Arabian Gulf 
Arabian Gulf 

Corpus Christi 
Corpus Christi 
Corpus Christi 
Corpus Christi 
Lagos 
Lagos 
Lagos 
Lagos 
Ju’aymah 
Ju’aymah 
Ju’aymah 
Ju’aymah 
Arzew 
Arzew 
Corpus Christi 
Corpus Christi 
Corpus Christi 
Corpus Christi 
Corpus Christi 
Corpus Christi 
Lagos 
Lagos 
Lagos 
Ju’aymah 
Ju’aymah 
Ju’aymah 

North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
Mediterranean 
Mediterranean 
Mediterranean 
Mediterranean 
Mediterranean 
Mediterranean 
Mediterranean 
Mediterranean 
Mediterranean 
Mediterranean 
Mediterranean 
Mediterranean 

Antwerp 
Rotterdam 
Antwerp 
Rotterdam 
Antwerp 
Rotterdam 
Antwerp 
Rotterdam 
Antwerp 
Rotterdam 
Antwerp 
Rotterdam 
Antwerp 
Rotterdam 
Augusta 
Cartagena  
Agioi Theodoroi 
Augusta 
Cartagena  
Agioi Theodoroi 
Savona 
Cartagena  
Leixoes 
Augusta 
Cartagena  
Agioi Theodoroi 

21 
21 
21 
21 
18 
18 
18 
18 
27 
27 
26 
26 
8 
8 
24 
21 
26 
24 
21 
26 
17 
14 
14 
18 
20 
16 

13 
13 
13 
13 
4 
3 
6 
5 
2 
2 
22 
22 
14 
13 
13 
12 
6 
13 
12 
6 
6 
23 
18 
0 
22 
20 

Alexandria (Egypt) 
Alexandria (Egypt) 

Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 

517  Milford Haven (UK) 
517  Milford Haven (UK) 
517  Milford Haven (UK) 
517  Milford Haven (UK) 
436 
435 
438  Medway (UK) 
437  Medway (UK) 
650 
650 
646  Milford Haven (UK) 
646  Milford Haven (UK) 
206  Medway (UK) 
205  Medway (UK) 
589 
516 
630 
589 
516 
630 
414 
359 
354 
432 
502 
404 

Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Alexandria (Egypt) 
Alexandria (Egypt) 
Alexandria (Egypt) 

23 
23 
23 
23 
19 
19 
19 
19 
28 
28 
29 
29 
10 
10 
26 
23 
28 
26 
23 
28 
18 
16 
16 
19 
22 
18 

13 
13 
13 
13 
23 
22 
23 
22 
16 
16 
11 
11 
7 
6 
11 
10 
4 
11 
10 
4 
16 
10 
12 
15 
12 
14 

565 
565 
565 
565 
479 
478 
479 
478 
688 
688 
707 
707 
247 
246 
635 
562 
676 
635 
562 
676 
448 
394 
396 
471 
540 
446 

48 
48 
48 
48 
43 
43 
42 
41 
38 
38 
61 
61 
42 
41 
46 
46 
46 
46 
46 
46 
35 
35 
42 
38 
38 
42 

9% 
9% 
9% 
9% 
10% 
10% 
9% 
9% 
6% 
6% 
9% 
9% 
20% 
20% 
8% 
9% 
7% 
8% 
9% 
7% 
8% 
10% 
12% 
9% 
8% 
10% 

Table 65: Tankers routes – Time comparison of the route with an intermediate stop relative to the direct route (% change in travel time components) 

Ship size [DWT]-  
Goods 

Origin Port 

Destination Port 

Total travel time  
direct route 

Intermediate Port 

Total travel time intermediate 
stop 

Sailing 
time 

Time at 
ports 

Total 
[%] 

165 

 
 
Sailing 
time [h] 

Time at 
ports 
[h] 

Total 
[h] 

Sailing 
time [h] 

Time at 
ports 
[h] 

Total 
[h] 

[%] 

[%] 

70,000-dirty 
70,000-dirty 

130,000-dirty 
130,000-dirty 
135,000-dirty 
135,000-dirty 
135,000-dirty 
135,000-dirty 
90,000-clean 
90,000-clean 
90,000-clean 
90,000-clean 
80,000 
80,000 

70,000-dirty 

70,000-dirty 

70,000-dirty 

130,000-dirty 
130,000-dirty 
130,000-dirty 
130,000-dirty 
130,000-dirty 
130,000-dirty 
90,000-clean 
90,000-clean 
90,000-clean 
Source: TRUST model, TRT 

Corpus Christi 

Antwerp 

Corpus Christi 

Rotterdam 

Corpus Christi 
Corpus Christi 
Lagos 
Lagos 
Lagos 
Lagos 
Ju’aymah 
Ju’aymah 
Ju’aymah 
Ju’aymah 
Arzew 
Arzew 

Antwerp 
Rotterdam 
Antwerp 
Rotterdam 
Antwerp 
Rotterdam 
Antwerp 
Rotterdam 
Antwerp 
Rotterdam 
Antwerp 
Rotterdam 

Corpus Christi 

Augusta 

Corpus Christi 

Cartagena  

Corpus Christi 

Agioi Theodoroi 

Corpus Christi 
Corpus Christi 
Corpus Christi 
Lagos 
Lagos 
Lagos 
Ju’aymah 
Ju’aymah 
Ju’aymah 

Augusta 
Cartagena  
Agioi Theodoroi 
Savona 
Cartagena  
Leixoes 
Augusta 
Cartagena  
Agioi Theodoroi 

459 

459 

459 
459 
378 
377 
380 
379 
592 
592 
588 
588 
148 
147 

531 

458 

572 

531 
458 
572 
356 
301 
296 
374 
444 
346 

58 

58 

58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 
58 

58 

58 

58 

58 
58 
58 
58 
58 
58 
58 
58 
58 

517  Milford Haven (UK) 

517  Milford Haven (UK) 

Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 

517  Milford Haven (UK) 
517  Milford Haven (UK) 
436 
435 
438  Medway (UK) 
437  Medway (UK) 
650 
650 
646  Milford Haven (UK) 
646  Milford Haven (UK) 
206  Medway (UK) 
205  Medway (UK) 

Alexandria (Egypt) 
Alexandria (Egypt) 

589 

516 

630 

589 
516 
630 
414 
359 
354 
432 
502 
404 

Jorf-Lasfar (Morocco) 

Jorf-Lasfar (Morocco) 

Jorf-Lasfar (Morocco) 

Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Alexandria (Egypt) 
Alexandria (Egypt) 
Alexandria (Egypt) 

473 

473 

473 
473 
387 
386 
387 
386 
596 
596 
615 
615 
155 
154 

543 

470 

584 

543 
470 
584 
356 
302 
304 
379 
448 
354 

92 

92 

92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 
92 

92 

92 

92 

92 
92 
92 
92 
92 
92 
92 
92 
92 

565 

565 

565 
565 
479 
478 
479 
478 
688 
688 
707 
707 
247 
246 

635 

562 

676 

635 
562 
676 
448 
394 
396 
471 
540 
446 

3% 

3% 

3% 
3% 
2% 
2% 
2% 
2% 
1% 
1% 
5% 
5% 
5% 
5% 

2% 

3% 

2% 

2% 
3% 
2% 
0% 
0% 
3% 
1% 
1% 
2% 

59% 

59% 

59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 

59% 

59% 

59% 

59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 
59% 

9% 

9% 

9% 
9% 
10% 
10% 
9% 
9% 
6% 
6% 
9% 
9% 
20% 
20% 

8% 

9% 

7% 

8% 
9% 
7% 
8% 
10% 
12% 
9% 
8% 
10% 

Table 66: Tankers routes - Travel costs 

Ship size [DWT]- 
Goods 

Origin Port 

Destination Port 

Total travel cost 
direct route 

Intermediate Port 

Total travel cost 
intermediate stop 

Diff. 
Travel 

166 

 
 
135,000-dirty 
135,000-dirty 
90,000-clean 
90,000-clean 
90,000-clean 
90,000-clean 
80,000 
80,000 
70,000-dirty 

70,000-dirty 

70,000-dirty 
70,000-dirty 

130,000-dirty 
130,000-dirty 

Corpus Christi 

Antwerp 

Corpus Christi 

Rotterdam 

Corpus Christi 
Corpus Christi 

Antwerp 
Rotterdam 

445,407 

445,407 

548,590 
548,590 

292,812 

122,675 

860,894  Milford Haven (UK) 

530,722 
530,722 

186,815 
186,815 

1,266,127  Milford Haven (UK) 
1,266,127  Milford Haven (UK) 

292,812 

860,894  Milford Haven (UK) 

320,167 

Fuel cost  
[€] 

Time cost 
[€] 

TOTAL  
[€] 

Fuel cost  
[€] 

Time cost 
[€] 

Ports 
cost  
[€] 
122,675 

Ports 
cost  
[€] 
184,013 

TOTAL  
[€] 

936,111 

935,971 

1,392,517 
1,392,315 

cost 
[%] 

9% 

9% 

10% 
10% 

431,932 

431,844 

531,993 
531,884 

320,115 

184,013 

580,302 
580,209 

280,222 
280,222 

135,000-dirty 

Lagos 

Antwerp 

451,505 

462,767 

194,000 

1,108,272 

135,000-dirty 

Lagos 

Rotterdam 

451,396 

462,670 

194,000 

1,108,067 

Jorf-Lasfar 
(Morocco) 
Jorf-Lasfar 
(Morocco) 

441,762 

508,455 

291,000 

1,241,216 

12% 

441,653 

508,358 

291,000 

1,241,011 

12% 

Lagos 
Lagos 
Ju’aymah 
Ju’aymah 
Ju’aymah 
Ju’aymah 
Arzew 
Arzew 

Antwerp 
Rotterdam 
Antwerp 
Rotterdam 
Antwerp 
Rotterdam 
Antwerp 
Rotterdam 

454,005 
453,462 
594,492 
594,492 
590,113 
590,022 
145,637 
145,189 

464,989 
464,506 
488,383 
488,383 
485,107 
485,038 
131,035 
130,745 

194,000 
194,000 
140,200 
140,200 
140,200 
140,200 
140,200 
140,200 

1,112,994  Medway (UK) 
1,111,968  Medway (UK) 
1,223,075  Alexandria (Egypt) 
1,223,075  Alexandria (Egypt) 
1,215,420  Milford Haven (UK) 
1,215,260  Milford Haven (UK) 

416,872  Medway (UK) 
416,134  Medway (UK) 

433,381 
432,294 
577,776 
577,776 
579,465 
579,374 
143,867 
142,969 

509,131 
508,165 
516,642 
516,642 
530,907 
530,839 
157,520 
156,941 

291,000 
291,000 
210,300 
210,300 
210,300 
210,300 
210,300 
210,300 

1,233,511 
1,231,458 
1,304,718 
1,304,718 
1,320,673 
1,320,513 
511,687 
510,210 

11% 
11% 
7% 
7% 
9% 
9% 
23% 
23% 

Corpus Christi 

Augusta 

515,405 

333,664 

122,675 

971,743 

Corpus Christi 

Cartagena  

444,966 

292,555 

122,675 

860,195 

70,000-dirty 

Corpus Christi 

Agioi Theodoroi 

555,832 

357,258 

122,675 

1,035,765 

130,000-dirty 

Corpus Christi 

Augusta 

634,803 

604,765 

186,815 

1,426,383 

130,000-dirty 

Corpus Christi 

Cartagena  

548,046 

530,255 

186,815 

1,265,116 

130,000-dirty 

Corpus Christi 

Agioi Theodoroi 

684,596 

647,529 

186,815 

1,518,940 

130,000-dirty 

Lagos 

Savona 

425,195 

424,746 

186,815 

1,036,756 

130,000-dirty 

Lagos 

Cartagena  

360,508 

369,190 

186,815 

916,513 

130,000-dirty 

Lagos 

Leixoes 

353,659 

363,307 

186,815 

903,781 

Jorf-Lasfar 
(Morocco) 
Jorf-Lasfar 
(Morocco) 
Jorf-Lasfar 
(Morocco) 
Jorf-Lasfar 
(Morocco) 
Jorf-Lasfar 
(Morocco) 
Jorf-Lasfar 
(Morocco) 
Jorf-Lasfar 
(Morocco) 
Jorf-Lasfar 
(Morocco) 
Jorf-Lasfar 
(Morocco) 

499,382 

359,627 

184,013 

1,043,021 

7% 

428,855 

318,467 

184,013 

931,334 

8% 

539,809 

383,221 

184,013 

1,107,043 

7% 

615,068 

651,824 

280,222 

1,547,115 

8% 

528,203 

577,221 

280,222 

1,385,646 

10% 

664,861 

694,588 

280,222 

1,639,672 

8% 

405,450 

460,320 

280,222 

1,145,992 

11% 

340,872 

404,858 

280,222 

1,025,951 

12% 

342,502 

406,258 

280,222 

1,028,983 

14% 

90,000-clean 

Ju’aymah 

Augusta 

375,560 

324,565 

140,200 

840,324  Alexandria (Egypt) 

359,574 

353,369 

210,300 

923,243 

10% 

167 

 
 
Origin Port 

Ship size [DWT]- 
Goods 
90,000-clean 
Ju’aymah 
90,000-clean 
Ju’aymah 
Source: TRUST model, TRT 

Destination Port 

Total travel cost 
direct route 

Intermediate Port 

Cartagena  
Agioi Theodoroi 

445,892 
347,281 

377,191 
303,405 

140,200 
140,200 

963,283  Alexandria (Egypt) 
790,886  Alexandria (Egypt) 

429,632 
334,579 

Total travel cost 
intermediate stop 
405,791 
334,667 

210,300 
210,300 

Diff. 
Travel 
cost 
9% 
[%] 
11% 

1,045,723 
879,546 

Table 67: Tankers routes – Costs comparison of the route with an intermediate stop relative to the direct route (% change in travel costs components) 

Ship size [DWT]- Goods 

Origin Region 

Origin Port 

Destination Region  Destination Port 

Intermediate Port 

Fuel cost  
[%] 

Time 
cost  
[%] 

Ports 
cost  
[%] 

TOTAL  
[%] 

70,000-dirty 
70,000-dirty 

130,000-dirty 
130,000-dirty 
135,000-dirty 
135,000-dirty 
135,000-dirty 
135,000-dirty 
90,000-clean 
90,000-clean 
90,000-clean 
90,000-clean 
80,000 
80,000 
70,000-dirty 

70,000-dirty 

70,000-dirty 

130,000-dirty 
130,000-dirty 
130,000-dirty 
130,000-dirty 
130,000-dirty 
130,000-dirty 
90,000-clean 

US Gulf 

US Gulf 

US Gulf 
US Gulf 
West Africa 
West Africa 
West Africa 
West Africa 
Arabian Gulf 
Arabian Gulf 
Arabian Gulf 
Arabian Gulf 
North Africa 
North Africa 

US Gulf 

US Gulf 

US Gulf 

US Gulf 
US Gulf 
US Gulf 
West Africa 
West Africa 
West Africa 
Arabian Gulf 

Corpus Christi 

North Europe 

Corpus Christi 

North Europe 

Corpus Christi 
Corpus Christi 
Lagos 
Lagos 
Lagos 
Lagos 
Ju’aymah 
Ju’aymah 
Ju’aymah 
Ju’aymah 
Arzew 
Arzew 

North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 
North Europe 

Corpus Christi 

Mediterranean 

Antwerp 

Rotterdam 

Antwerp 
Rotterdam 
Antwerp 
Rotterdam 
Antwerp 
Rotterdam 
Antwerp 
Rotterdam 
Antwerp 
Rotterdam 
Antwerp 
Rotterdam 

Augusta 

Milford Haven (UK) 

Milford Haven (UK) 

Milford Haven (UK) 
Milford Haven (UK) 
Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Medway (UK) 
Medway (UK) 
Alexandria (Egypt) 
Alexandria (Egypt) 
Milford Haven (UK) 
Milford Haven (UK) 
Medway (UK) 
Medway (UK) 

Jorf-Lasfar (Morocco) 

Corpus Christi 

Mediterranean 

Cartagena  

Jorf-Lasfar (Morocco) 

Corpus Christi 

Mediterranean 

Agioi Theodoroi 

Jorf-Lasfar (Morocco) 

Corpus Christi 
Corpus Christi 
Corpus Christi 
Lagos 
Lagos 
Lagos 
Ju’aymah 

Mediterranean 
Mediterranean 
Mediterranean 
Mediterranean 
Mediterranean 
Mediterranean 
Mediterranean 

Augusta 
Cartagena  
Agioi Theodoroi 
Savona 
Cartagena  
Leixoes 
Augusta 

Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Jorf-Lasfar (Morocco) 
Alexandria (Egypt) 

-3% 

-3% 

-3% 
-3% 
-2% 
-2% 
-5% 
-5% 
-3% 
-3% 
-2% 
-2% 
-1% 
-2% 

-3% 

-4% 

-3% 

-3% 
-4% 
-3% 
-5% 
-5% 
-3% 
-4% 

9% 

9% 

9% 
9% 
10% 
10% 
9% 
9% 
6% 
6% 
9% 
9% 
20% 
20% 

8% 

9% 

7% 

8% 
9% 
7% 
8% 
10% 
12% 
9% 

50% 

50% 

50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 
50% 

50% 

50% 

50% 

50% 
50% 
50% 
50% 
50% 
50% 
50% 

9% 

9% 

10% 
10% 
12% 
12% 
11% 
11% 
7% 
7% 
9% 
9% 
23% 
23% 

7% 

8% 

7% 

8% 
10% 
8% 
11% 
12% 
14% 
10% 

168 

 
 
Ship size [DWT]- Goods 

Origin Region 

Origin Port 

Destination Region  Destination Port 

Intermediate Port 

Fuel cost  
[%] 

Time 
cost  
[%] 

Ports 
cost  
[%] 

TOTAL  
[%] 

90,000-clean 
90,000-clean 

Arabian Gulf 
Arabian Gulf 

Ju’aymah 
Ju’aymah 

Mediterranean 
Mediterranean 

Cartagena  
Agioi Theodoroi 

Alexandria (Egypt) 
Alexandria (Egypt) 

-4% 
-4% 

8% 
10% 

50% 
50% 

9% 
11% 

169 

 
 
 
 
 
Annex 5: Current maritime fuel mix and overview of available 
alternative fuels for maritime transport and their maturity 

The purpose of this annex is to provide an overview of the current maritime fuel mix and to 
explore the range of technical possibilities to use alternative fuels in maritime transport. The 
content  of  this  annex  builds  upon  the  support  study  carried  out  for  this  impact  assessment 
(Ecorys / CE Delft forthcoming), a literature review carried out with the support of EMSA on 
ten different alternative fuels possibilities as well as the work carried out by the sub-group on 
Sustainable  Alternative  Power  for  Shipping  (SAPS  SUB-GROUP)  of  the  European 
Sustainable Shipping Forum (ESSF)220.  

Current energy usage in maritime transport 

Table  68  presents  the  fuel  mix  of  the  fleet  as  reported  under  the  2018  EU  MRV  reporting 
period.  Data  from  the  2019  MRV  reporting  period  were  not  yet  verified  at  the  time  of 
finalising  this  report.  However,  preliminary  estimates  from  the  2019  reporting  show  very 
similar shares to the ones observed in 2018. 

Table 68 Share of various fuel types 

Type of fuel 
Heavy fuel oil (HFO) 
Marine gas oil (MGO) 
Light fuel oil (LFO) 
Marine diesel oil (MDO) 
Liquefied natural gas (LNG) 
Other* 
Methanol 
Liquefied petroleum gas (LPG) -  Butane 
Total 

Share in fuel mix 
72.11% 
12.46% 
7.63% 
4.02% 
3.17% 
0.60% 
0.01% 
0.00%** 
100.00% 
* This category covers other fuels with non-standard emission factors. In 2018, the average emission factor 
of the fuels reported under this category corresponded to 3.07 t-CO2 / t-fuel.   
** While the percentage of LPG usage is at 0%, there was a very limited amount of LP volume used by the 
fleet in 2018. However, this is too small to be reflected in any percentage of fuel mix. Nevertheless, this 
category was added here to provide a complete picture of the fuel use within MRV in 2018.  

Source: MRV Data 2018 

As  already  highlighted  in  Section  2  of  this  report,  the  current  maritime  fuel  mix  almost 
entirely  relies  on  fossil  fuels,  with  the  vast  majority  of  the  fuel  mix  being  concentrated  on 
liquid fuel products such as HFO, MGO, light fuel oil and MDO. Gaseous fuels, in the form 
of LNG or liquefied petroleum gas are only a very small fraction of the energy mix.  

220  In  particular,  the  work  by  the  Maritime  Research  Institute  Netherlands  (MARIN)  in  work-stream  2  of  this  sub-group 
provides a summary of the existing scientific knowledge on the performance and potential of different alternative sustainable 
fuels, energy conversion technologies for shipping, including their environmental performance on a complete well-to-wake 
approach, complemented, where appropriate, with life cycle considerations.  
The result of this work can be consulted under: https://sustainablepower.application.marin.nl/  

171 

 
 
 
 
 
                                                           
Possible alternative fuel options 

In  order  to  analyse  the  performance  and  maturity  of  the  different  possible  alternative  fuels 
options  available  to  the  maritime  sector  (and  be  able  to  compare  them),  it  is  important  to 
consider the different stages from initial resources to energy carriers  (the fuel itself), energy 
conversion on board (type of “engines”) and ship propulsion. These elements are summarised 
graphically  in  Figure  16.  This  simplified  diagram  presents  only  an  overview  of  the  main 
elements to be taken into account, but the database developed in the framework of the ESSF 
SAPS sub-group identified already 53 solutions (possibilities of combination) between these 
elements (resources, energy carriers and energy conversion), including the options relying on 
fossil  resources.  Figure  17  summarises  a  graphic  presentation  of  the  possible  options 
(presented  as  Sankey-like  diagram  for  the  four  categories  of  resources  identified  in  Figure 
16).  

172 

 
 
Figure 16 Simplified overview of the main components of the "energy diagram" for marine fuels 

Source: MARIN (2020), ESSF SAPS SUB-GROUP. 

173 

 
 
 
 
 
 
Figure 17 Sankey diagram of the possible fuel combinations for the main resources categories 

Source: MARIN (2020), ESSF SAPS SUB-GROUP. 

174 

 
 
 
Primary energy sources / resources:  

The current maritime fuel mix relies almost entirely on fossil resources, either in the form of 
oil products or gaseous fuels. The main alternative fuels presented in this annex are options 
deriving  from  non-fossil  origins.  The  three  main  alternative  sources  of  energy  which  have 
been identified are biomass, metal or renewable energy. Given the relatively limited amount 
of options provided by metals, the analysis carried out in the context of the FuelEU Maritime 
initiative has mainly focussed on biomass and renewable energy / electricity, which have also 
been identified by the stakeholders as the most promising options.  

  Biomass is expected to lead to three main fuel types (that can be used also in blends 
with fuels of other origin, including fossil): liquid biofuels (such as biodiesel), biogas 
(that can be used as bio-LNG or bio-CNG), and alcohol products (e.g. bio-ethanol).  
  Renewable energy / electricity can be used directly for charging on-board batteries in 
vessels using fully electric propulsion systems or hybrid engines. Renewable energy 
can  also  serve  the  production  of  renewable  hydrogen  to  directly  power  fuel  cells 
(either carried as hydrogen or ammonia) or be blended for use in internal combustion 
engines. It can also be used for the production of synthetic liquid fuels (e-diesel), gas 
(e-LNG)  or  alcohols  (e.g.  e-methanol),  which  may  also  be  blended  with  similar 
products  of  other  origin,  including  fossil.  Wind-assisted  propulsion  is  today 
considered  a  means  to  reduce  a  ship’s  consumption  of  fossil  energy.  As  efforts  to 
reduce GHG emissions and climate change intensify, the commercial shipping world 
is looking at wind as an inexhaustible power source, at least in a supporting role, with 
renewed interest. 

GHG saving potential, sustainability and availability of resources221 

The consideration of the primary source of energy is important to determine the fuel’s overall 
environmental performance. As a result, a well-to-wake approach is preferable to reflect the 
overall  GHG  performance  of  fuels/technologies  as  it  takes  into  account  the  impacts  of 
production, transport, distribution and use on-board. Such an approach is also more likely to 
incentivise technology options and production pathways that provide real benefits compared 
to the existing conventional fuels. As presented in Figure 17, an energy carrier like LNG can 
be produced from fossil origin, bio-origin or synthetically using renewable energy, similarly 
hydrogen  can  be  produced  from  fossil  energy  or  renewable  electricity.  All  these  different 
production pathways will have a significant impact on the fuel’s performance. For instance, 
fossil LNG in a four stroke engine would have a GHG performance of 709.49 g-CO2e/kWh, a 
biogas  produced  from  organic  waste  of  248.39  g-CO2e/kWh,  and  a  synthetic  gas  from 
renewable sources a  value of 75.19  g-CO2e/kWh on a well-to-wake calculation  (GWP100). 
There is a factor 9.5 difference between the worst case scenario and the best case for LNG. 
The  variation  between  these  values  can  be  even  greater,  in  particular  when  considering  the 

221 Unless stated otherwise, all figures provided in this section on the GHG performance of difference energy carriers based 
on the initial energy source come from MARIN (2020) ESSF SAPS sub-group. 

175 

 
 
                                                           
production  of  the  same  energy  carriers  from  fossil  or  non-fossil  resources:  renewable 
ammonia use in fuel cells would have a value of 0 g-CO2e/kWh while its equivalent produced 
from fossil resources (natural gas) would reach 2630.08 g-CO2e/kWh on a well-to-wake basis 
(GWP100).  

Similarly,  even  within  the  same  group  of  resources,  different  production  pathways  are 
possible and would have ultimately an impact on the fuel’s GHG saving potential and overall 
sustainability  record. The most known example of this concerns the biofuels,  which can be 
produced from  different  feedstocks. While a 100% biodiesel  form  waste (crop residues and 
municipal solid waste) can achieve substantial savings, the contribution of biofuels produced 
from food and feed crops is usually lower and uncertain due to the issue of indirect and use 
change.  Biofuels  produced  from  high  ILUC-risk  feedstock  are  unlikely  to  achieve  any 
savings.222Given  that  the  contribution  of  first  generation  of  biofuels  (food  and  feed-based 
ones) towards decarbonisation is limited , it is not foreseen that they would be eligible under 
this initiative. 

From Figure 17 it is apparent that the number of truly zero-emission options is limited on a 
well-to-wake  analysis.  Additional  incentives  for  these  zero-emissions  options  are  therefore 
needed  to  make  sure  that  implementing  WTW  approach  does  not  entrench  HFO  and  MGO 
and  paves  the  way  for  gradual  transition  to  alternative  fuels  that  are  zero-emission  on  the 
well-to-wake  perspective.  Figure  18  presents  the  upstream,  operational  and  net  CO2 
emissions for selected fuel options, including produced from different initial energy resource. 
The  overall  net  CO2  impact  hence  depends  not  only  on  the  operational  (tank-to-wake) 
emissions but also on the upstream (well-to-tank) savings.  

Figure 18 Upstream, operational and net CO2 emissions for selected fuel options 

Source: LR/UMAS (2020) “Techno-economic assessment of zero-carbon fuels” 

222 COM(2019) 142 final 

176 

 
 
 
 
                                                           
In addition to the GHG saving potential, the availability of sufficient quantities of feedstocks 
is  an  important  aspect  to  determine  how  a  certain  fuel  option  can  be  sustainably  scaled-up 
and deployed in the future, ensuring sufficient production levels on the most appropriate and 
performant pathways.  

Energy carriers and energy conversion 

Different  energy carriers (fuels) are presented in  Figure 16 and Figure  17 and have already 
been presented compared to their potential primary energy source. There are however other 
criteria that can be used to group these in different categories and highlight specific attributes 
of the different fuel options or to limit the number of alternative fuel options based on certain 
technical characteristics or constraints that need to be met on the ship. In this context, it also 
worth  considering  the  interaction  with  the  energy  conversion  (engine)  system  on-board, 
which provides a set of conditions / constraints that need to be met by chose energy solution 
(compatibility  of  the  engine  and  fuel  storage  system  to  a  given  technical  option).  Another 
determining  aspect  in  the  fuel  choice  concerns  the  operating  conditions  of  the  ship  itself 
(constraints in terms of necessary range, available storage capacity, etc.).  

Compatibility with the existing infrastructure and machinery 

A first  aspect  concerns the compatibility of the fuel  with  the existing infrastructure and the 
existing  machinery  on-board.  Drop-in  fuels  are  defined  as  the  fuel  options  that  are 
functionally  equivalent  to  the  fossil  fuels  currently  in  use  and  fully  compatible  with  the 
distribution infrastructure.  

For maritime transport, the identified drop-in fuels will be bio-diesel or e-diesel, bio-gas or 
synthetic gas, bio-methanol or e-methanol.  

One  of  the  important  advantages  of  drop-in  fuels  is  to  allow  for  lower  capital  costs  on 
ramping-up of the fuel solution as the existing ship machinery is compatible with these fuels 
and  because  it  does  not  require  a  dedicated  infrastructure.  As  a  result,  the  deployment  can 
also  be  more  rapid  as  the  uptake  of  the  option  is  not  dependent  on  the  deployment  of  a 
dedicated  infrastructure  nor  on  specific  fleet  characteristics,  removing  some  of  the 
interdependency  issues  that  exist  in  developing  new  fuel  solutions  (chicken  and  egg).  In 
addition,  as  these  fuels  are  usually  similar  to  the  existing  fossil  options  they  are  meant  to 
replace,  they  can  usually  be  safely  blended  allowing  a  gradual  uptake  of  more  sustainable 
energy options, while still providing some first GHG savings.  

While  drop-in  fuels  may  be  low  or  zero-carbon  fuels  on  a  well-to-wake  perspective,  when 
used  either  100%  or  in  very  high  blends,  this  is  very  dependent  on  the  overall  production 
pathway  and  the  type  of  feedstock  used.  Furthermore,  they  have  emissions  on  the  tank-to-
wake basis, as well as air pollution such as NOx and black carbon, which require additional 
attention and after-treatment. In comparison, hydrogen or ammonia eliminate such emissions 

177 

 
 
if  used  in  fuel  cells  as  energy  converters.  When  used  in  internal  combustion  engines,  NOx 
emissions cannot be avoided and require after-treatment. 

However,  these  fuels  may  not  automatically  be  compatible  with  the  existing  infrastructure 
nor stored and used with  existing vessels without specific adaptation  of the equipment  (on-
board and/or on-shore). The type and complexity of the required modification depend on the 
current  fuel  system  and  the  alternative  carrier  to  be  used.  On  board,  they  concern 
modification  to  the  engine,  the  storage  tanks  and  the  piping  system.  Similar  compatibility 
issues  (or  possible  needs  for  modification)  can  be  observed  for  the  current  distribution 
infrastructure (either HFO-MGO bunkering or LNG infrastructure).  

These  aspects  related  to  the  compatibility  of  the  existing  infrastructure  and  the  fleet  will 
undoubtedly affect the lead time for the uptake of the different fuel options.  

In  addition  to  this,  the  maturity  of  on-board  energy  conversion  systems  has  also  to  be 
considered in looking at the different available pathways. The fleet currently consists almost 
entirely of internal combustion engines powered either by liquid of gaseous fuels. According 
to the fourth IMO greenhouse gas study, 98.4% of all engines used in the fleet in 2018 were 
oil  engines  and  0.52%  were  LNG  engines  (including  dual-fuel  engines).  Figure  17  also 
indicates  the  possibility  of  using  fuel  cells,  which  is  an  attractive  solution  to  reduce  GHG 
emissions.  

However,  while  already  available  at  commercial  scale,  this  technology  have  so  far  been 
demonstrated  in  small,  low  speed  vessels  with  relatively  low  power  needs  (of  up  to  a  few 
hundred kW), the technology has not yet reached a sufficient level of maturity to be largely 
deployed on the entire fleet, in particular when involved in deep-sea traffic. Considering the 
typical power requirements of the fleet, the technology needs to be significantly scaled-up to 
become a mature alternative for maritime transport. As an example, the average main engine 
power installed on containerships range between 5 and 60 MW depending on the size of the 
ship and its cargo capacity. Considering the data provided by the fourth IMO greenhouse gas 
study,  vessels  above  5000  GT  (corresponding  to  the  MRV  scope)  are  usually  using  multi-
megawatt  engines.  There  are  several  challenges  associated  with  scaling-up  fuel  cells  to  the 
desired  MW  scale  while  simultaneously  addressing  durability,  compatibility  with  maritime 
conditions  (saline  air,  shock,  rolling  &  vibration).  These  challenges  are  currently  being 
addressed  by  different  research  and  innovation  projects,  as  well  as  by  commercial 
demonstration projects. A similar situation can be depicted when it comes to the development 
and  deployment  of  fully  electric  propulsion  by  batteries.  Nevertheless,  ongoing  projects  on 
fleet hybridisation have allowed the sector to gain more experience and knowledge with the 
use  of  large  battery  installation  in  support  of  maritime  activities  (propulsion  or  ancillary 
power).  

The  technology  maturity  of  the  different  options,  expressed  in  technology  readiness  levels 
(TRLs), is summarised in Figure 19. 

178 

 
 
Figure 19 TRL ranking for zero-emissions technologies 

Source: LR/UMAS (2020) “Techno-economic assessment of zero-carbon fuels” 

Energy density 

The maritime sector is characterised by high power needs, which, in turn, require fuels with 
high energy density. While short-sea shipping (defined as maritime transport between ports in 
the EU and ports situated in geographical Europe, on the Mediterranean and Black Seas) is 
characterised by relatively short routes with frequent port calls and can include a number of 
fixed-schedule  routes,  deep-sea  traffic  represents  long  distance  journeys  (trans-oceanic) 
without necessarily a fixed schedule. The fuel energy density is therefore an important aspect 
affecting  the  possibility  of  ships  to  safely  carry  out  long  distance  journeys  without 
compromising on the cargo carrying capacity (in volume or weight). Presently, bulk carriers 
can sail more than 30,000 nautical miles (nm) on average on full tanks, containerships up to 
50,000  nm  and  tankers  between  10,000  nm  and  30,000  nm  on  average.  To  put  this  into 
perspective, a transatlantic journey from Europe would cover around 6,000-7,000 nm and a 
journey to South-East Asia around 10,000 nm. 

179 

 
 
 
 
the  possible  alternative  fuels, 

liquid  biofuels  and  electrically  synthesised 
Among 
hydrocarbons  have  the  highest  energy  density  followed  by  bio-gas.  In  practice,  LNG  has 
roughly  45  %  lower  volumetric  energy  density  than  diesel,  while  ammonia  and  hydrogen-
based fuels have an even lower density. Both the volumetric and gravimetric density of the 
fuels have to be considered as they will impact potentially the range of a given ship or aspects 
related to vessel’s design, including impacts on the cargo capacity (in volume or weight).  

Indeed, the adoption of  alternative fuels  that require more volume  and  mass than HFO and 
MGO  will  inevitably  lead  to  a  reduction  in  deadweight  and  available  volume  for  cargo. 
Alternatively,  the  lower  energy  density  of  alternative  fuels  may  lead  to  potentially  larger 
ships  for  similar  deadweight  capacities,  impacting  directly  on  resistance  and  power 
requirements. 

When  looking  at  energy  densities  for  alternative  fuel  options  for  ships,  in  addition  to  the 
energy density characteristic to the energy carrier, it is necessary to also consider the impact 
of  the  weight  and  volume  of  containment  system.  This  represents  an  important  addition,  in 
particular  for  options  such  as  liquefied  hydrogen,  where  the  containment  system  may 
represent a decrease in the density of the energy carried by almost half, from 9.2 to 5MJ/l. An 
important  focus  to  improve  feasibility  for  such  technology  options  will  need  to  take  into 
account the optimization of containment strategies, including materials technologies.  

Figure  20  provides  an  overview  of  the  possible  alternative  fuel  options  in  terms  of  energy 
density (volumetric and gravimetric).  

Figure 20 Overview of fuel options in terms of energy density 

Source: MARIN (2020), ESSF SAPS SUB-GROUP. 

180 

 
 
  
Any fuel alternative moving from the current fuel (MDO) towards the bottom-left corner of 
the graph would result in further constraints and potential trade-off between fuel storage and 
cargo.  

Safety and standardization aspects223 

In  addition  to  the  inherent  characteristics  of  the  different  fuel  options,  their  production 
pathways and energy conversion technology, it is also considered important to highlight the 
relevance  of  safety  and  standardization  as  important  enablers  to  ensure  the  deployment  of 
safe and operable solution within a harmonized regulatory framework. The IGF Code, having 
entered into force on 1st January 2017, established a harmonized set of goals and functional 
requirements  which  are  currently  the  regulatory  backbone  for  the  design,  installation  and 
operation of LNG fuelled ships. Work has continued to cover Ethyl/Methyl alcohols, with a 
set of Interim Guidelines approved at IMO, at MSC102. Fuel Cell installations, LPG and low 
flashpoint  diesel  fuels  are  currently  the  object  of  work  within  the  IGF  Code  development 
agenda.  Interim  Guidelines  appear  to  be  the  most  flexible  solution  to  develop  harmonized 
goal-based  requirements  for  specific  technologies.  They  take  however,  on  average,  about  5 
years  to  develop  and  this  is  a  time  pace  which  has  to  be  taken  into  consideration  in  the 
context of any alternative fuel technology deployment.  

As of today, in most of the cases, safety and technical requirements for alternative fuel and 
power  installations,  otherwise  not  covered  in  SOLAS/IGF,  will  be  established  by  IMO 
MSC.1/Circ.1455 (Guidelines for the approval of alternative and equivalents as provided for 
in various IMO instruments). The use of this important IMO instrument, despite its relevance 
in  a  context  of  less  mature  technologies  and  innovative  applications,  is  not  preferred  for 
continued  application.  Elements  such  as  containment  and  fuel  distribution,  structural 
protection,  detection  or  fire  suppression  technologies  have  to  be  designed  in  accordance  to 
technology-specific requirements. Developing this at a pace which is coherent and consistent 
with the technology development and user needs is an important challenge to address at both 
IMO and standardization organizations such as ISO, IEEE or IEC. 

Different  Classification  Societies  have  already  important  class  rules  and  guidance  covering 
design,  installation  and  safety  aspects  for  alternative  fuels  and  power  technologies.  The 
challenge  to  have  a  harmonized  framework  is  however  best  addressed  at  IMO  where  a 
consolidation  of  current  experience  can  take  place  in  the  form  of  interim  guidelines.  These 
need  to  be  sufficiently  flexible  to  allow  technology  development  whilst,  at  the  same  time, 
supported by robust goals and functional requirements. 

223 The present section is focused on the developing international framework for the safe use of alternative fuel technologies 
onboard  ships,  focused  on 
the  IGF  Code 
(http://www.imo.org/en/OurWork/Safety/SafetyTopics/Pages/IGF-Code.aspx)  

the  ongoing  development  of  amendments  and  new  sections 

to 

181 

 
 
 
                                                           
Economic aspects affecting fuel choice 

In addition to the technical aspects presented above, there are important economic elements, 
which will have the possible choice of alternative fuels.  

Costs 

An important reason behind the low uptake of zero-emission fuels and power by ships calling 
EU ports is that the costs of these fuels are generally higher than the costs of fossil fuels. This 
is  confirmed  by  stakeholders’  feedback  received  in  the  consultation  activities  on  FuelEU 
maritime.  For  instance,  in  response  to  the  public  consultation,  48.1%  of  the  respondents 
(65/136)  indicated  the  higher  price  of  RLF  as  one  of  the  most  important  barrier  to  their 
uptake.  

Figure 21 presents a comparison of the costs associated to the different fuels options per unit 
of energy (€/kWh).  

Figure 21 Costs comparison of different alternative fuel options 

Source: MARIN (2020), ESSF SAPS SUB-GROUP. 

The  production  cost  ranges  of  biofuels  and  e-fuels  are  larger  than  those  of  fossil  fuels.  To 
some  extent,  this  is  caused  by  the  fact  that  production  systems  for  biofuels  and  e-fuels  are 
newer  and  subject  of  on-going  research.  For  biofuels,  this  also  relates  to  the  variety  of 
biomass  feedstocks  and  feedstock  prices  and  the  variety  of  production  technologies  in 
existence.  For  e-fuels  the  wide  ranges  also  relate  to  the  uncertainty  about  renewable 
electricity costs, which are linked to electricity market price developments and which form a 
major part of the production costs of e-fuels.  

182 

Bio MethanolBio Compressed gas100% Hydrotreated Vegetable Oil from wasteMarine Gas Oil, 0.1% sulfur content (Reference 2-stroke ICE CI)e-Methanole-H2 comp.300 bareH2 comp 96% with 4% Diesele-DiMethylEtherElectricity Li-NMC batterye-Hydrogen liquifiede-Ammoniae-Methane liquifiede-dieselRecycled Iron powder1234567891011120.000.050.100.150.200.250.30TRL   Technology Readiness LevelOpEx  [euro/kWh]Properties of alternative sustainable powering solutions compared to Diesel MGO in 2-stroke ICE Bubble size: Contained Energy density in [MJ/kg]Selection of carriers combined with power distribution systems, meeting 2050 targets (at least 70% reduction of CO2 eq. GWP100 in [g/kWh] )From fossilFrom renewable electrictiy(and atmospheric CC when C needed)From BiomassFrom MetalFrom renewable electrictiywith pilot fossil fuel 
 
 
 
Production and fuel availability 

When reviewing the initial energy resources to be used for fuel production, the availability of 
sufficient  quantities  of  feedstocks  is  an  important  aspect  to  determine  how  a  certain  fuel 
option can be sustainably scaled-up and deployed in the future, ensuring sufficient production 
levels on the most appropriate and performant pathways. 

Another  important  dimension  for  maritime  transport  concerns  the  wide  availability  of 
alternative options, not only in different European ports but also on a global scale. Indeed, a 
transition  towards  new  sources  of  energy  can  only  be  sustained  if  these  are  deployed  on  a 
large scale allowing vessels engaged in international trade to cater for their fuel needs.  

Possible evolutions and stakeholders’ views 

The  study  carried  out  by  Ecorys  and  CE  Delft  in  support  of  this  impact  assessment  has 
provided  an  overview  of  different  pilot  projects  and  research  and  innovation  initiatives 
carried out with respect to the use of alternative fuels in maritime transport.  

The  diversity  of  the  sector  in  terms  of  ship  type,  age  distribution,  size,  power  required  or 
operating  conditions  will  result  in  different  constraints  determining  the  optimal  fuel  choice 
for  a  given  economic  actor.  After  reviewing  existing  literature  and  compiling  the  feedback 
received during the consultation activities on this initiative, it becomes apparent that a variety 
of different fuels with no dominant source of energy will be the most likely composition of 
the maritime fuel mix by 2050.  

The respondents of the targeted consultation survey have indicated their expectations on what 
fuels  are  most  likely  to  be  used  in  2030  and  2050,  both  during  navigation  and  at  berth. 
Concerning 2030, it can be concluded that biofuels are perceived as most promising for use in 
navigation,  followed  by  batteries.  Looking  at  2050,  the  expectations  focus  rather  ‘other 
decarbonised  hydrogen-derived  fuels  (including  ammonia)’  and  ‘Decarbonized  hydrogen 
(including  fuel  cells)’,  which  are  the  categories  that  received  the  highest  scores.  For 
emissions at berth, the alternative fuel option that stands out in being promising for 2030 is 
on-shore power supply (OPS). Looking at the survey results for 2050, OPS still is perceived 
as most promising compared to the alternatives. 

183 

 
 
 
 
Annex 6: Methodology followed for the definition of the policy 
options 

This  annex presents  the comprehensive list  of policy measures  that was  established for this 
initiative  after  extensive  consultations  with  stakeholders,  expert  meetings,  independent 
research and the Commission’s own analysis.  

This  also  includes  policy  measures  that  would  not  be  focussed  on  addressing  solely  the 
technology barriers related to fuel uptake but could provide comparable level of CO2 or GHG 
savings  (including  carbon  pricing  mechanisms  or  carbon  intensity  standards  of  ship 
operations).  Their  likely  effectiveness  in  increasing  the  penetration  of  RLF  was  assessed 
qualitatively.  Based  on  this  initial  screening,  a  number  of  policy  measures  were  not 
considered apt to address all the SOs or were identified as complementary measures included 
in the “basket of measures”.  

Based on this assessment, the Commission also refined the general policy approach to narrow 
down the proposed intervention to a limited number of characteristics allowing to effectively 
address the problem drivers in a coherent manner.  

Two  principal  characteristics  were  identified  for  the  policy  measure  to  fulfil  the  given 
objectives:  

  They should provide certainty on the future short to long-term policy targets  for the 
carbon  intensity  of  the  energy  used  by  ships.  Such  targets  should  preferably  be 
mandatory and enforceable, thus providing legal certainty. 

  They  should  address  the  demand  side  component,  by  incentivising  or  prescribing 
minimum performance requirements of the marine energy mix. This is necessary for 
complementing existing supply-side measures and solving the interdependency issue, 
as well as for avoiding carbon leakage. 

In the next step, the retained policy measures were classified according to their approach and 
characteristics in relation to three areas of policy intervention: i) improve the penetration rate 
of  RLF,  ii)  stimulate  the  introduction  of  zero-emissions  energy  solutions,  and  iii) 
certification, reporting and enforcement. 

The correspondence between the SOs and the areas of policy intervention are illustrated in  

Figure 22: 

184 

 
 
 
 
 
 
 
Figure 22 Correspondence between the specific objectives and the identified areas of policy interventions 

The  full  list  of  identified  policy  measures  is  presented  in  the  Table  1Table  69.  This  table 
clearly indicates if these measures have been retained or are considered as flanking measures 
or  complementary  measures.  Only  retained  measures  have  been  included  in  policy  options 
and were subject to a thorough analysis.  

It indicates if the policy measure has been retained (R), dismissed (D) or is considered to be 
only a complementary measure (C) not assessed in the framework of this impact assessment. 
The table also highlights the flanking measures (F), which are not necessarily of regulatory 
nature  nor  resulting  from  this  initiative  but  will  contribute  to  meeting  its  objectives.  To  be 
noted that only retained measures (R) have been included in policy options and were subject 
to a thorough analysis.  

185 

 
 
 
 
 
 
 
Table 69 Full list of identified policy measures 

Policy measure 

Status224 

Comments 

Field of policy intervention 1: Improve the penetration rate of already mature sustainable alternative fuels 

1  Obligation to produce minimum quantities of marine RLF for EU fuel 

C 

suppliers 

2  Obligation to distribute minimum level of distribution of marine RLF in all 

C 

EU ports 

3 

Prioritise at the IMO level discussions on the uptake of RLFs as a measure 
to implement the IMO GHG strategy 

4 

5 

Establish minimum share / volumes of selected RLF for ships in 
navigation calling EU ports (blending mandate) 
Set maximum targets on the GHG intensity (meaning the  GHG 
emissions per unit of energy) of the energy used by vessels (the fuel / 
energy emission factor per kWh). 

C 

R 

R 

While incentives on fuel suppliers, such as the ones introduced within RED II 
(multipliers for marine fuels) tend to provide positive results, they are currently limited 
to specific, contained, markets and subject to a system of incentives (remain 
voluntary). Changing this approach to mandatory target for minimum marine RLF 
production could provide a more structural trajectory. However, given the nature of the 
maritime sector and the possibility for ships to cover very large distances on a single 
bunkering, this measure could be easily circumvented by ships bunkering in third 
countries.  
The distribution of RLF through the appropriate infrastructure is an important 
condition for the success of the policy. However, the approach is not likely to be 
sufficient to result in a significant uptake of RLF. The possibility of ships to bunker in 
third countries reduces the effectiveness of such a measure. Even if RLF were the only 
marine fuel distributed in the EU, this could result in a limited uptake as ships could 
decide to bunker in third countires to avoid the costs related to RLF.  
The uptake of RLF is clearly recognised as an important measure by the IMO. 
However, the discussion on the uptake of alternative fuels as well as market-based 
measures is expected to start at IMO only in the course of 2021, among others based on 
the EU proposal on fuel lifecycle guidelines based on sustainability and GHG 
emissions saving criteria. While international measures are necessary, it is important to 
also rapidly provide the sector with the definition of the long term trajectory for RLF 
uptake.  
Retained measure. As described in the report, the measure implies that a 
technology choice is made.  
Retained measure. As described in the report, the measure implies a goal-based 
approach leaving the flexibility to the sector to identify the most appropriate 
compliance option.  

 
 
                                                           
 
6 

Set maximum targets on the GHG intensity of operations of a vessel (limit 
for GHG emissions per ton nautical mile) 

C 

7  Mandate the use of on-shore power supply (or equally performant 
alternatives such as batteries or renewable hydrogen) for the most 
polluting ships in ports, gradually extending to the entire fleet over time 

8 

9 

Increase the uptake of sustainable alternative fuels in the sector through a 
carbon price 

Facilitate access to funding on low- and zero-emission vessels as well as 
advanced fuel distribution infrastructure 

10  Differentiation of port fees 

11 

Introduce a preferential tax treatment for marine RLF 

R 

C 

F 

C 

C 

This measure is expected to provide emissions reductions that could be comparable to 
the uptake of alternative fuels. It is expected that in response to the GHG emission 
limits, the sector will focus on achieving compliance by using options with the lowest 
marginal abatement costs. However, RLF have a comparatively higher marginal 
abatement costs to other measures such as energy efficiency. In conclusion while such 
a measure will allow emission reductions in sector, it is unlikely to sufficiently address 
the identified barrier on the low uptake of RLF. Setting a specific (sub-)target of RLF 
uptake within this context would be equal to measure 5 plus an additional element on 
energy efficiency that goes beyond the objectives of this intervention and is likely to to 
overalp with other initiatives within the ‘basket of measures’.  
Retained measure. In this context OPS is considered as the main available 
compliance option (also allowing significant emissions reductions of air 
pollutants). Nevertheless, flexibility would be left to the sector to use equally 
performant alternative to OPS. In this case, specific criteria will be set to define 
what options can be considered equally performant. 
Similarly to measure 6, this measure is complementary to the proposed inteverntion but 
is unlikely to sufficiently address the technology barrier related to fuels as operators are 
likely to respond to such an instrument by implementing solutions with the lowest 
marginal abatement costs. 
As presented in Section 6 of the report, the proposed intervention will lead to increased 
investment costs for the sector. Aside from private investments, which are expected to 
play a major role, public funding from Member States and the EU budget could be put 
to contribution to support the uptake of RLF through research funding, deployment of 
the necessary infrastructure, de-risking investments on vessels through financial 
instruments, etc. 
The definition of port fees is a prerogative of port authorities / operators. 
Differentiating port fees to reward low- and zero-emission ships could be a 
complementary policy measure but it is unlikely to be sufficiently effective to break the 
chicken-and-egg situation, ensure an increasing demand for sustainable alternative 
fuels and remove the price differential, in particular or ships in navigation.  
A preferential tax treatment for marine RLF could help reducing the price gap between 
conventional fuels and RLF. The Energy Taxation Directive currently provides for a 
mandatory exemption of marine bunker fuel. The ETD is currently being revised and 
could further strenghen the objectives of FuelEU maritime. It must be noted that, in the 
same vein as for measures 1 and 2, the risk of leakage through bunkering in third 
countries needs to be fully analysed.  

 
 
12  Provide guidance to facilitate testing and uptake of technology, 

R 

including on the deployment of the necessary supply infrastructure 

Retained measure. Similarly to guidance provided in the past on LNG bunkering 
or the one on OPS currently being developed by EMSA, such non-mandatory 
document can help accelerating the provision of the necessary infrastructure and 
ultimately boost the uptake of advanced technical solutions.  

Field of policy intervention 2: Stimulate the introduction of new low- and zero-emissions energy solutions 

13  Allow shipping companies to comply by fleet averaging 

14  Allow ships to enter into pools with overachieving ships and comply on 
average within the pool by establishing a scheme of balancing for over- 
and under-compliance, in which excess compliance points can be 
exchanged between ships 

15  Provide multipliers for zero-emission technologies  

16  Distinguish standards for the new fleet (compared to the existing ships)  

D 

R 

R 

D 

This measure would in principle increase the degree of flexibility offered to the 
industry by allowing companies to average compliance at fleet level instead of ship 
level. This measure could potentially favour the uptake of more advanced / performant 
solutions to compensate the non-compliance from other ships. However, by limiting 
the averaging to company fleet, the measure could also distort the level playing field in 
the sense that larger companies will benefit a much larger flexibility compared to 
smaller entities or single-ship operators. 
Retained measure. This measure is very similar to measure 13 in its intention. It 
provides a system to reward the over-achievers and allow fleet-wide averaging. 
However, instead of limiting the averaging possibility to a single company, it 
allows through the establishment of a system to record excess compliance points to 
average compliance among a wider fleet, including from different companies, 
regardless of their size. Arrangements for transfer of the excess compliance points 
will be subject to private-law agreements between the concerned parties. This 
mechanism will mostly be used intra-company and only concern a modest number 
of transactions between companies. Those few transactions will not be capable of 
determining a transparent and uniform ‘market’ price. Also, the balances will not 
be purchasable by intermediaries. Since this mechanism is meant to provide 
additional flexibility rather than act as a primary means of compliance and is not 
expected to lead to the creation of a specific and significant market, it is not 
considered as a “market-based” measure.  
Retained measure. Multipliers (adjustment factors) for zero-emission technologies 
are designed to provide an additional incentive to reward over-achievers.  
The measure would in principle allow to establish stricter standards to the new fleet, 
taking into consideration the possibility for new ships to be equipped with new 
propulsion systems or designed specifically for more advanced fuel options (in 
particular when specific storage and piping is required). The effects of such a measure 
are very much dependent on fleet renewal. In addition, it may lead to an indirect effect 
that older fleet remains in operation (or is diverted to the regulated region) to avoid 
stricter standards. For these reasons, this measure was not retained as a policy measure 
for full assessment. 

 
 
17 

Increase awareness raising, exchange of experience, encouragement and 
promotion of industry-led programmes in support of the uptake of 
alternative fuels 

18 

Issue recommendations on zero-emission technology requirements in public 
procurement of vessels 

19 

Fund research and innovation activities in zero-emission technologies 

R 

C 

F 

Retained measure that should continue in the long term. On the one hand, it can 
rely on exchanges on technical issues organised in the context of expert groups 
such as the ESSF of the EPF. On the other hand, standalone industry alliances 
could be established between operators, ports and fuel suppliers to foster the 
deployment of specific options or in the context of on-shore power supply. 
Public procurement can be an interesting tool to support the rapid deployment of 
advanced vessels technologies, including electric propulsion or fuel-cell systems. 
While this measure would be limited to the fleet of vessels subject to public 
procurement rules, this measure can be an interesting complementary measure to 
accelerate the deployment of the most advanced solutions. 

Certain fuel solutions still need to mature to reach a sufficient techonology readiness 
level allowing market deployment (see Annex 5). Continuous focus on reseach and 
innovation is therefore critical for a successful RLF uptake. The preparation of the 
‘Zero Emissions Waterborne Transport’ partnership under Horizon Europe, proposed 
by the Waterborne Technology Platform would therefore be an important flanking 
measure to support the uptake of advanced fuel solutions in maritime transport.  

Field of policy intervention 3: Certification, reporting and enforcement 

20  Establish an EU-wide methodology to certify the well-to-wake 

R 

performance of fuels, reflecting all relevant GHG emissions and define 
the related documents to certify compliance 

21  Establish requirements for certification and acceptance of bunker 

R 

supplied in third countries 

22 

Intensify the IMO work on the Fuel LCA guidelines and the promotion of 
the RLF uptake 

F 

Retained measure. It is important that all fuels are subject to the same 
methodology to define their GHG performance. Since this initative is looking at 
emisisons on a well-to-wake basis (including emissions / savings from production, 
transport, etc.), the methodology should indicate all relevant steps to follow to 
establish and certify fuel performance and build on existing requiremens under 
REDII. It will also clarify what documents are necessary to demonstrate (and 
consequently check) compliance.  

Retained measure. Given the international nature of maritime transport, it is 
important to recall that vessels can bunker fuels in non-EU countries; Specific 
rules should be set up to provide for GHG certification of fuels bunkered in third 
countries. This methodology shuld build upon existing practice such as the fuel 
import certification under REDII.  
The intensification of the work at international level (IMO) on the development of 
lifecycle GHG/carbon intensity guidelines for all types of fuels is an important element 
to provide global coherence to the shift towards RLF and to pave the way for future 
measures at global level. 

 
 
23  Establish a set of rules to follow for monitoring, reporting and 

verification of consumption of RLF in the context of the EU MRV 

24  Establish Port State Control procedures and guidelines for the use of 

RLF (including upskilling and training of PSC officers), in view of 
enforcement 
Intensify IMO work on the IGF Code development and associated Interim 
Guidelines for the safety use of alternative fuels  

25 

R 

R 

F 

Retained measure. As the MRV reporting already relies on the reporting of fuel 
consumption and the type of fuel used, integrating the monitoring of RLF utpake 
in the framework of the EU MRV allows to greatly reduce the administrative 
burden for operators. 
Retained measure. If necessary, specific Port State procedures and guidelines may 
need to be developed to enforce the RLF requirements.  

IGF Code, associated SOLAS amendments and interim guidelines on the use of 
alternative fuels and technologies are considered to be important pillars for the 
construction of increased certainty in the adoption of RLF.  
It is important to further intensify work pertaining shaping of the IGF Code revision 
and development agenda with a view to ensure adequate close alignment of the 
regulatory and standardization framework with the development and evolution of RLF-
specific TRL. 
In parallel to the IGF work, consistently, ensure adequate confirmation of supporting 
international standards for the relevant technologies in consideration, always preferring 
ISO, IEC, IEEE or any similar relevant international-reaching standardization 
references. 

 
 
 
 
 
 
Annex 7: Overview of the monitoring and evaluation 
framework 

The  detailed  list  of  operational  objectives,  indicators  and  data  sources  is  presented  in 
Table 70. Some of these monitoring arrangements will be established more in detail only 
after thorough discussion with Member States and key stakeholders. 

 
 
 
Table 70 Proposed monitoring and evaluation framework 

General objective 

Specific objectives 

Operational objectives 

Indicators 

Data source 

Increase the uptake of 
RLF in EU maritime 
transport with a view 
to reducing emissions 
from the sector in 
navigation and at 
berth. 

Enhance predictability through 
the setting of a clear regulatory 
environment concerning the use 
of alternative fuels in maritime 
transport 
Stimulate technology 
development 

 

Provide clearly identified long-
term targets (up to 2050) on the 
minimum use of RLF in maritime 
transport 

  Encourage R&I and the 

development of new, advanced, 
types of RLF for maritime 
transport 

Stimulate production on a larger 
scale of RLF with sufficient high 
technology readiness level 
(TRLs) and reduce the price gap 
with current fuels and 
technologies 

 

Significantly increase the volumes 
of RLF produced and distributed 
to the maritime sector 

  Enhance the competitiveness of 
RLF compared to conventional 
fossil fuels 

Create demand from ship 
operators to bunker alternative 
fuels with a sufficient high TRL 
or connect to the electric grid 
while at berth. 

 

 

Provide a minimum level of RLF 
demand to sustain market 
developments 
Increase the number of OPS 
connections by ships at berth, in 
particular for highest polluters 

 

 

 

  Regulatory framework established 
 

Investment levels in RLF 
production and distribution 
Penetration of RLF in the maritime 
fuel mix 
Investment levels in RLF-related 
R&I in maritime transport 
Share of e-fuels, hydrogen, 
ammonia and electricity in the 
maritime fuel mix 
Production levels of marine RLF 

 
  RLF average prices and price 

  Evaluation (survey targeted 

at fuel suppliers) 

  EU MRV data 

  Evaluation (survey targeted 

at ship-owners and 
technology providers) 

  EU MRV data 

  Evaluation (survey targeted 

at fuel suppliers) 

differential with conventional fossil 
fuels 

  Eurostat 
  National Policy Frameworks 

  Number of RLF bunkering points in 

 

 

Europe  
Penetration of RLF in the maritime 
fuel mix 
Penetration of RLF in the maritime 
fuel mix 

 

  Number of ships and ports 
equipped with OPS 
Percentage of port calls requiring 
OPS 
Increased share of electricity in 
energy generation at berth 

 

under AFID 
  EAFO data 
  EU MRV data 

  Evaluation (survey targeted 
at ports and operators) 
  National Policy Frameworks 

under AFID 
  EAFO data 
  EU MRV data 

  EU MRV data 
  Evaluation (survey targeted 

at fuel suppliers) 

Avoid carbon leakage 

  Limit regulatory avoidance 
through traffic diversion 
  Establish a common system of 
certification cover marine RLF 
(including production in third 
countries) 

  Average distance of last journeys of 

vessel calling EU ports 

  Certification scheme established 
  Number of non-EU fuel suppliers 

certified