REPORT FROM THE COMMISSION Monitoring of the implementation of Directive 2003/87/EC in relation to maritime transport
Date: 2025-03-18
Institutions: Directorate-General for Climate Action, European Commission
Subjects: EU emission allowance, Red Sea, application of EU law, environmental monitoring, greenhouse gas, marine fuel, maritime transport, pollution from ships, reduction of gas emissions, tradeable emission permit

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 18.3.2025  COM(2025) 110 final  REPORT FROM THE COMMISSION Monitoring of the implementation of Directive 2003/87/EC in relation to maritime transport  
 
 
REPORT FROM THE COMMISSION 

Monitoring of the implementation of Directive 2003/87/EC in relation to maritime 
transport 

1.  Introduction 

The extension of the EU Emissions Trading System (EU ETS) to maritime transport  came into 
effect in January 2024, marking a significant milestone in the EU’s efforts to reduce greenhouse 
gas emissions from shipping. 

This extension brings new obligations for shipping companies. Each year, they have to purchase 
and surrender emission allowances to cover the amount of greenhouse gas emissions released into 
the atmosphere, linked to their activities under the ETS scope.  

This also brings significant environmental benefits. Indeed, by capping the amount of greenhouse 
gases that can be emitted under the system, the EU ETS1￼ ensures that all the sectors covered 
under its scope, including maritime transport, contribute to the EU’s climate objectives and to the 
objectives of the Paris Agreement. Furthermore, the EU ETS provides a carbon price signal which, 
together with other EU policies such as the FuelEU Maritime Regulation￼, makes investments in 
energy efficiency and low-carbon solutions more financially attractive for shipping companies. It 
also reduces the price difference between alternative fuels and traditional fuels. In addition, the 
revenues generated by the sale of EU allowances are important enablers to encourage innovation 
and the shift to cleaner technologies. 

As it is the first time that such a system is put in place in the shipping sector, careful monitoring 
of its implementation and effectiveness is essential to ensure it delivers on its objectives, while 
avoiding unintended economic, environmental and operational risks. This is the reason why the 
EU ETS Directive requires the Commission to monitor the implementation of the ETS extension 
to maritime transport and report its findings every two years. 

One of the objectives of this monitoring clause is to detect possible changes in shipping companies’ 
behaviours at an early stage, notably the ones trying to evade the requirements of the EU ETS 
Directive. If appropriate, the EU ETS Directive requires the Commission to propose measures to 
ensure  an  effective  implementation  of  the  ETS  in  shipping,  in  particular  measures  to  address 
possible risks of evasion.  

In  addition,  the  monitoring  clause  covers  other  possible  impacts  of  the  EU  ETS  extension  to 
maritime  transport,  such  as  possible  transport  cost  increases,  implications  in  terms  of 
competitiveness  or  impacts  on  those  shipping  services  that  constitute  essential  services  of 
territorial continuity, including giving consideration to the EU outermost regions, which represent 
the most remote parts of the EU. 

1 Directive 2003/87/EC of the European Parliament and of the Council of 13 October 2003 establishing a scheme for 
greenhouse gas emission allowance trading within the Community and amending Council Directive 96/61/EC (OJ L 
275, 25.10.2003, p. 32). 

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This report describes the work undertaken so far to monitor the impacts of the extension of the EU 
ETS to maritime transport, with a focus on the potential evasive behaviours. The analysis presented 
in this report builds on a study carried out by a consortium of contractors.2 

2.  Implementation of ETS to maritime transport 

2.1. State of play of implementation 

Text box 1: Functioning of the EU ETS for maritime transport 

The extension of the EU ETS to maritime transport took effect in January 2024. It applies, from 
2024, to vessels over 5 000 gross tonnage (GT) transporting cargo and passenger for commercial 
purposes,  and  from  2027,  also  to  offshore  ships  over  5  000  GT.  The  inclusion  of  maritime 
transport  into  the  EU  ETS  follows  a  transitional  phase,  where,  during  the  first  two  years, 
emission  allowances  are  to  be  surrendered  for  a  portion  of  the  verified  emissions  (40%  of 
verified emissions to be covered in 2024, 70% in 2025, and 100% as from 2026).  
From  2026  onwards,  the  EU  ETS  for  maritime  transport  will  also  cover  greenhouse  gases 
beyond CO2, namely methane (CH4) and nitrous oxide (N2O). The geographical scope of the 
EU ETS for maritime emissions includes 100% of emissions from voyages between EU ports 
and within EU ports, and 50% of emissions from voyages between an EU port and a port outside 
the EU jurisdiction, allowing third countries to decide how to address the remaining 50% in the 
absence of any equivalent pricing measure at global level. 
The system builds on the monitoring, reporting and verification requirements of the EU MRV 
Maritime Regulation3, which were first introduced in 2018. In 2023, almost 12 000 vessels of 
over 5 000 GT reported their verified emissions under the THETIS-MRV system4, representing 
127 million tonnes of CO2.  

At the time of writing this report, the implementation of the EU ETS has made significant progress, 
with  encouraging  signs  in  terms  of  overall  compliance.  Feedback  received  from  shipping 
companies, both within and outside the EU, suggests a genuine willingness to implement the ETS 
legal obligations in a timely manner. So far, over 5 000 shipping companies have registered in 
THETIS-MRV  (accounts  with  active  ships),  and  more  than  15  000  ships  have  submitted  their 
assessed monitoring plans to their responsible administering authorities.  

These positive compliance signs are notably the outcome of several outreach activities conducted 
since end 2023, with the support of the European Maritime Safety Agency (EMSA) and with a 
view to reinforce stakeholders’ readiness. Five webinars were organised between December 2023 
and March 2024 to explain the EU ETS rules and the IT tools to shipping companies, with a high 

2 Ricardo et al., 2024 – “Supporting study for the implementation of the ETS Directive and MRV requirements for 
maritime transport”, publication upcoming  
3  Regulation  (EU)  2015/757  of  the  European  Parliament  and  of  the  Council  on  the  monitoring,  reporting  and 
verification of greenhouse gas emissions from maritime transport, and amending Directive 2009/16/EC (OJ L 123 
19.5.2015, p. 55, ELI: http://data.europa.eu/eli/reg/2015/757/2024-01-01). 
4 THETIS-MRV is the IT system to report greenhouse gas emissions from maritime transport pursuant to the MRV 
Maritime Regulation (https://mrv.emsa.europa.eu/#public/eumrv). 

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level of participation (around 500-700 attendants at each webinar). Those remain available online5. 
Additionally,  the  Commission  has  published  more  than  100  Frequently  Asked  Questions6  to 
provide clarity on the EU ETS requirements and a dedicated Helpdesk (co-managed with EMSA) 
has responded to more than 1 400 questions in less than a year. 

Furthermore, two guidance documents have been published in July 2024. The first guidance is an 
extensive  document  explaining  the  MRV  and  ETS  requirements  for  shipping  companies.7  The 
second  one  is  a  guidance  about  the  process  of  approval  of  monitoring  plans  by  administering 
authorities8.  A  third  guidance  document  is  also  under  finalisation  about  verification  and 
accreditation activities. 

2.2. Main  risks  and  concerns  related  to  the  ETS  extension  to  maritime  transport 

emissions 

As commercial agents competing in a global market, shipping companies are expected to adopt 
measures to increase their competitiveness and minimise their costs, including ETS compliance 
costs. To achieve this, companies may typically consider implementing operational solutions to 
reduce their GHG emissions, such as slow steaming, route optimisation, or using renewable and 
low-carbon fuels or investing in cleaner ships and energy efficient retrofits (e.g. wind propulsion 
assistance,  improved  hull  design,  etc.).  However,  companies  may  also  consider  implementing 
practices that could be considered as evasive behaviours. Evasive behaviours can be defined in a 
broad sense as operational adjustments that circumvent ETS rules and reduce the amount of GHG 
emissions  to  be  reported  under  ETS  scope,  without  actually  implementing  GHG  mitigation 
measures such as improvements in energy-efficiency or use of alternative fuels/cleaner ships. 

Evasive  behaviours  from  shipping  companies  are  problematic  in  three  ways.  First,  they  can 
compromise the environmental integrity of the EU ETS system, as shipping companies engaging 
in  evasive  behaviours  will  surrender  less  ETS  allowances,  without  actually  reducing  their 
emissions.  In  some  cases,  evasion  mechanisms  can  even  lead  to  increased  GHG  emissions  for 
equivalent transport activity (e.g. if they increase sailing distances to include an additional port 
call or move part of the operation to other transport modes with higher emissions). Second, some 
evasive behaviours could reduce traffic and connectivity of EU container transhipment hubs and 
lead to negative wider macroeconomic implications. A loss of connectivity resulting from evasive 
behaviours can impact businesses adversely (e.g. reduced, or more expensive access to important 
overseas markets, less opportunities to forward cargo to other ports). Third, evasion mechanisms 
can lead to reduced ETS revenues, resulting in less money available to support the decarbonisation 
of the maritime transport sector or the wider climate objectives. 

5  European  Commission  website,  https://climate.ec.europa.eu/eu-action/transport/reducing-emissions-shipping-
sector_en#events  
6  European  Commission  website,  https://climate.ec.europa.eu/eu-action/transport/reducing-emissions-shipping-
sector_en#faq  
7  Guidance  Document  n°1:  The  EU  ETS  and  MRV  Maritime  –  General  guidance  for  shipping  companies 
(https://climate.ec.europa.eu/eu-action/transport/reducing-emissions-shipping-sector_en#documentation) 
8 Guidance Document n°2: ETS and MRV Maritime Regulation – General guidance on the process for approval of 
monitoring  plans  by  administering  authorities  (https://climate.ec.europa.eu/eu-action/transport/reducing-emissions-
shipping-sector_en#documentation) 

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Evasive behaviours could become attractive to shipping companies in case compliance costs (ETS 
payments in the present case) outweigh evasion costs (additional costs associated with the evasive 
behaviour,  including  vessel  operating  costs  and  port  costs).  It  also  depends  on  the  capacity  of 
shipping  companies  to  pass  their  ETS  compliance  cost  to  their  final  consumers.  Beyond  such 
economic considerations, shipping companies will also consider other important factors such as 
possible  impacts  on  their  services  (e.g.  deviation  time,  waiting  time),  the  feasibility  of 
implementing evasive behaviours (e.g. non-EU ports’ accessibility, berth availability, connectivity 
or  compatibility  with  their  network  and  investment  policies)  or  other  specific  risks  (e.g. 
reputational considerations, security risks, potential disruptions in supply chains, geopolitics and 
global trade patterns). 

To  mitigate  evasion  risks,  the  ETS  Directive  includes  a  strict  “port  of  call”  definition  (i.e. 
obligation  to  actually  load/unload  or  embark/disembark  cargo  and  passenger),  which  prevents 
companies from making artificial port of calls  for ETS  evasion  purposes.  In addition,  the ETS 
Directive excludes “neighbouring container transhipment ports”9 from the “port of call” definition. 
This  means  that  stops  at  these  non-EU  ports  cannot  be  considered  under  the  Directive  as  the 
beginning or the end of a voyage, hence reducing the incentive to stop at these non-EU hubs before 
or after calling EU ports. Based on the criteria set out in the ETS Directive, the Commission has 
already identified such neighbouring container transhipment ports10 and this work will be updated 
every two years. Currently, the neighbouring container transhipment ports encompass the ports of 
East  Port  Said  in  Egypt  and  Tanger  Med  in  Morocco,  which  represent  around  70%  of  the 
transhipment activities taking place in non-EU Mediterranean countries. As mentioned above, the 
Directive  also  addresses  the  risk  of  evasion  through  the  monitoring  requirements  and  biennial 
reports. 
Beyond the risk of evasion, another concern is the risk of increased shipping costs for shippers and 
consumers as shipping companies are likely to pass, at least partially, the ETS compliance costs 
into the final transport price. Given the importance of maritime transport as the backbone of global 
trade but also  for the connectivity of some islands or other remote territories, in  particular EU 
outermost regions, such an increase in transport costs could lead to unintended impacts. 

The Directive already includes specific measures to mitigate potential impacts on connectivity of 
remote regions by exempting specific voyages until 2030 including: 

•  Voyages between a port in outermost regions and a port within the same Member State;  

9 Defined in Article 3ga(2) of the EU ETS Directive as ports where 1) the share of transhipment of containers exceeds 
65% of the port’s total container traffic, 2) the port’s location is outside the EU but less than 300 nautical miles from 
a port under the jurisdiction of a Member State, 3) the port is located in a non-EU country for which that non-EU 
country does not effectively apply measures equivalent to this Directive.  
10  Commission  Implementing Regulation  (EU)  2023/2297  of  26  October 2023  identifying  neighbouring  container 
transhipment ports pursuant to Directive 2003/87/EC of the European Parliament and of the Council (OJ L, 2023/2297, 
27.10.2023, ELI: http://data.europa.eu/eli/reg_impl/2023/2297/oj). 

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•  Certain voyages by passenger ships between a Member State with no land connection and 
another  closest  Member  State  in  the  context  of  a  transnational  public  service 
contract/obligation (PSC/PSO)11; 

•  Certain voyages by passenger ships between ports in Member States’ islands (with no road 
or rail link with the mainland) with fewer than 200 000 permanent residents12 and other 
ports within the same Member State. 

2.3. What is being monitored 

Following the monitoring requirements of Article 3gg(3) of the EU ETS Directive, the following 
evasive behaviours and broader impacts have been analysed (Table 1). 

Table 1: Evasive behaviours and broader impacts monitored 

Impact 

Description 

Possible evasive behaviours 

Relocation of 
transhipment 
activities 

Evasive port calls 
or change in order 
of port calls 

Container transhipment is the practice of offloading containers from one 
vessel  at  a  port  and  then  loading  them  onto  other  container  ships  for 
onward delivery to a destination, which may be relatively close (‘feeder 
transhipment’)  or  may  involve  longer  voyages  (‘relay  transhipment’). 
Container  transhipment  is  an  activity  that  has  grown  considerably  in 
recent years. A number of ports, in particular in the Mediterranean, have 
recently  expanded  their  capacity  to  be  able  to  play  a  role  in  the 
transhipment  market.  Vessel  operators  may  decide  to  relocate  their 
container transhipment activities from EU transhipment ports to non-EU 
neighbouring ports to reduce their ETS compliance costs. In some cases, 
this  would  bypass  payment  for  emissions  altogether  if  origin  and 
destination of cargo are both non-EU. When the final destination of cargo 
is in the EU, cargo would need to be transported by feeder vessels from 
the non-EU transhipment port to the EU transhipment port or directly to 
the final destination (or the other way around when the origin is in the 
EU). 

Shipping companies may decide to add an extra port call to reduce the 
length of the last leg before calling at an EU port (or the length of the first 
leg after leaving an EU port). Similarly, operators may change the order 
of calls to minimise their ETS exposure. It should be noted that under the 
EU MRV Maritime Regulation, a port call requires a shipping operator to 
load  or  unload  cargo  or  embark  or  disembark  passengers.  As  such,  it 

11 The list of transnational routes under PSC/PSO concerned by this derogation is published in Implementing Decision 
(EU) 2023/2895: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02023D2895-20240101   
12 The list with islands and ports concerned by this derogation is published in Implementing Decision (EU) 2023/2895: 
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02023D2895-20240101  

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Impact 

Description 

Shifting demand 
to other transport 
modes with higher 
environmental 
impacts 

Assigning best 
performing vessels 
to EU routes 

would be necessary for a shipping operator to perform business operations 
in these additional port calls. 

Freight  companies  may  move  freight  transport  from  maritime  to  other 
modes (in particular road transport), which have higher emissions than 
maritime. This would be rather affecting Short Sea Shipping (SSS) routes 
which face stronger competition from land-based modes. 

Vessel  operators  may  decide  to  use  their  most  efficient  vessels  (with 
lowest GHG emissions per tonne-mile) to routes that include calls at EU 
ports  and  use  their  less  well-performing  vessels  on  other  routes.  This 
could have environmental benefits for the EU, including for air quality, 
but not reduce total greenhouse gas emissions.  

Use of ships below 
size threshold 

Vessel operators, particularly those that operate smaller vessels (but still 
above 5 000 GT), may choose to use vessels (slightly) below the 5 000 
GT threshold that are excluded from the ETS scope. 

Use of ship-to-ship 
transfers outside 
EU ports 

Vessel  operators  may  use  ship-to-ship  transfers  outside  EU’s  ports 
(particularly of liquid cargoes) to avoid making EU port calls and thereby 
reduce their obligations under the EU ETS. 

Other possible impacts 

Impacts on 
transport costs 

Impacts on 
essential services 
for territorial 
continuity 

Impacts on 
Outermost 
Regions 

The purchase of allowances by shipping companies to ensure compliance 
with  EU  ETS  or  the  costs  linked  to  the  implementation  of  mitigation 
measures  are  likely  to  impact  overall  shipping  costs.  Some  shipping 
companies pass through ETS costs to their customers in the forms of ETS 
surcharges. 

Increased shipping costs could lead to changes in the supply and price of 
ferry (RoPax) services connecting EU islands and remote territories to the 
mainland. 

Increased shipping costs could lead to changes in the supply and price of 
shipping services connecting Outermost Regions. Furthermore, services 
to  Outermost  Regions  could  also  be  impacted  by  evasive  behaviours 
described above. 

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3.  Monitoring approach 

3.1. Constraints of the analysis 

Impacts of the Red Sea crisis on shipping traffic 

As a result of the Houthi attacks which commenced in November 2023, many of the vessels that 
previously transited through the Suez Canal re-routed around South Africa, via the Cape of Good 
Hope. The transits  through  the Suez Canal  decreased by around 60% in  2024 compared to  the 
situation in 2022/2023, with the decrease reaching close to 70% for containerships13.  

This led to a reduction in port calls (notably from deep sea routes and larger container ships) and 
traffic in East Mediterranean ports and in some Central Mediterranean ports from Q1 2024. At the 
same time, the re-routing caused an increase in activity levels in West Mediterranean ports, with 
more feeder services to East Mediterranean ports. This distortion creates a significant challenge in 
monitoring evasive behaviours in the Mediterranean as the types of voyages and vessels affected 
by the Red Sea crisis (deep sea routes and larger container vessels) coincide with those likely to 
be mostly impacted by potential evasive behaviours. 

To isolate the effect of the EU ETS from those of the Red Sea crisis, the following approach has 
been adopted: 

•  Differentiated analysis  of Mediterranean basins (West,  Central  and East)  to  account  for 

varying impacts of Red Sea crisis on each area. 

•  Comparison of EU and non-EU ports within the same Mediterranean basin to control for 

broader Red Sea crisis effects affecting the whole basin. 

•  Two EU control groups have been established: a Southern group, further differentiated by 
Mediterranean basin and a Northern control group (when applicable) for comparing with 
trends  observed  in  EU  transhipment  ports  and  detect  possible  broader  market  trends 
affecting all ports (i.e. not only transhipment activities). 

Timing of the analysis  

Due to the legal deadline provided in the Directive for this first report, the analysis has been carried 
out during 2024. This report builds on the most recent information and data available at the time 
of the analysis,  which  covers for 2024 the period from  the entry into force of  the EU ETS  for 
maritime transport (January 2024), until the end of the third quarter of 2024 (30 September 2024). 
In some instances, however, data was only available for the first half of the year. 

Given the high volatility of maritime traffic, particularly in transhipment operations, this partial 
coverage limits the ability to reach definitive conclusions from traffic data analysis. 

In addition, 2024 is the first year of the ETS phase-in period, where only 40% of emissions are 
subject to ETS compliance costs. This may have impacts on the extent of evasive behaviours, as 
these are notably influenced by the trade-off between evasive costs and ETS pricing of emissions 
(which will only apply in full as from 2026). 

13 Source: EMSA own analysis on the Impact of developments in the Red Sea on maritime traffic. 

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This timing constraint will be addressed by monitoring ETS implementation on a continuous basis. 
The present report is part of an ongoing process: the evolution of relevant indicators will continue 
to be analysed on a regular basis. 

Transhipment data availability 

Data on transhipment operations is not publicly available in a consistent manner for all ports under 
the scope of this report. To fill this gap, commercial data from Econdb was used. Econdb data is 
extracted from a sample of tracked containers, which represent a small percentage of the global 
fleet  (around  2%)  but  are  distributed  representatively.  Hence,  container  movements  (including 
transhipments) data from Econdb may not be fully accurate when considered at an individual port 
and month level; however, they provide a useful overview of trends over time and across regions. 

Econdb  data  was  sense-checked  against  equivalent  and  official  data  (total  container  and 
transhipment movements) for Spanish ports, as published by Puertos del Estado. Inputs from port 
questionnaires were also used for sense-checking purposes. The comparison reveals that Econdb 
data  is  sufficiently  robust  to  use  for  trends  and  for  relative  comparisons  between  ports  with 
significant levels of transhipment activity. However, this data would be less appropriate to analyse 
absolute transhipment levels in detail, and when considering ports with low transhipment activity. 

3.2. Method and tools 

This  monitoring  exercise  has  been  structured  around  a  set  of  research  questions  and  a  suite  of 
indicators  to  answer  each  of  them.  The  exercise  includes  both  backward-looking  and  forward-
looking  analyses.  Backward-looking  analysis  aim  at  detecting  evidence  of  possible  evasive 
behaviours or broader impacts that might have already occurred during the monitored period, while 
forward-looking  analyses  aim  at  identifying  potential  future  risks  and  impacts  beyond  the 
monitored period.  

Indicators  used  for  the  backward-looking  analysis  include  port  activity  data  (port  calls,  traffic 
volume, transhipment operations, connectivity) and vessel data. In contrast, the forward-looking 
analysis mostly relied on qualitative information on route announcements, legislative changes in 
neighbouring non-EU countries and data on port capacity expansion projects. 

When assessing these indicators, two main comparative analyses have been performed: 

•  Comparison over time: Data over the monitored period is compared against the situation 
before the entry into application of the EU ETS for maritime transport, covering 2022 and 
2023 data. For this purpose, quarterly data over the period Q1 2022 to Q3 2024 is analysed 
to extract relevant trends. In addition, a year-on-year comparison is performed by analysing 
differences  in  Q1-Q3  2024  data  vis-à-vis  Q1-Q3  2023.  This  aims  to  control  for  the 
seasonality and volatility of maritime traffic data. 

•  Comparison with control groups: This analysis helps discern potential shifts attributable 
to evasive behaviour from broader trends (e.g. driven by global economic context, trade 
policies, geopolitics, including  the Red Sea crisis as mentioned above, developments  in 
port infrastructure and operational efficiency, port fees, etc.). The two control groups of 
EU  ports  (Southern  and  Northern  control  groups)  are  used  to  represent  baseline  trends. 

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They include ports with lower levels of transhipment activity, which are, to a certain extent, 
less likely to be impacted by the risk of transhipment relocation. 

Additionally, several case studies are considered where relevant to focus the analysis on specific 
geographies or market segments likely to be most impacted. These include a case study looking at 
EU-US flows (i.e. expected to be less affected by the Red Sea crisis) for the monitoring of the risk 
of evasive port calls and two additional case studies looking at evidence of possible modal shift in 
freight transport between Spain and Italy and between Bulgaria and other non-EU countries in the 
Black Sea, respectively. 

3.3. Data sources 

Data sources used in this study are summarised below in Table 2. 

Table 2: Data sources used 

Source 

Use  

Port call data from 
MARINFO database 

Route modelling tool 
developed by the 
European Maritime 
Safety Agency 
(EMSA) 

Data on number of port calls by type of voyage and vessel type/size. 
This data is used to monitor trends in relation to evasive behaviours 
(transhipment relocation, evasive port calls and modal shift) and 
impacts on shipping services in remote territories and Outermost 
regions. 

Data on historic maritime traffic on specific routes, including 
intermediate port calls, to understand how the nature of routes 
including EU ports has evolved. This tool builds on MARINFO port 
call data. 

Commercial data from 
Econdb 

Data concerning container traffic by service and statistics by port 
(including on transhipment). This is used to analyse trends on 
transhipment operations in EU and non-EU ports. 

UNCTAD 

Data on port liner shipping connectivity index (EU and non-EU 
ports) to assess trends in relation to port connectivity. 

THETIS - MRV 

Data on vessel technical efficiency data to monitor potential 
assignment of best performing vessels in the EU and CO2 emissions 
data used to estimate EU ETS costs. 

Survey of port 
authorities 

Additional data on EU port activities (including on investments) and 
information on the impacts of the EU ETS at a port level 

Publicly available port 
statistics 

Cross-check with other data sources used for port activity and to 
provide additional insights 

9 

 
 
 
 
Source 

Use  

Desk review of 
publicly available 
information 

Identify information on routes used by vessel operators, including 
announced changes to those routes (or new routes) and announced 
investments in ports (to increase ports’ capacity, in particular). 

Commercial reports 
(including from 
Drewry) 

Additional information on the trends identified and on deals and 
investments at relevant ports. 

Eurostat international 
road freight transport 
data  

Quarterly data on road freight transport between Spain and Italy and 
Bulgaria and other non-EU countries (Georgia, Türkiye) analysed to 
identify possible evidence of modal shift towards road transport. 

3.4. Ports included in the analysis 

The  analysis  covers  specific  ports  or  sets  of  ports  (with  geographic  groupings  in  some  cases), 
which  allows  for  meaningful  comparison  of  trends.  Grouping  of  ports  aims  at  facilitating  the 
identification of overall impacts. The choice of the port groups has been discussed with Member 
States representatives in dedicated expert group meetings and are described in Table 3. The names 
of all ports considered under each group are listed in Annex to this report. 

Table 3: Port groups used 

Port group 

Definition and selection criteria 

Use 

EU 
transhipment 
ports at risk 

EU ports with high levels of container 
transhipment incidence and considered 
most exposed to the transhipment 
relocation risk, notably given the 
proximity of non-EU transhipment 
ports.  

Neighbouring 
non-EU ports 
(transhipment) 

Non-EU ports considered most likely to 
potentially benefit from additional 
activity arising from the transhipment 
relocation risk. This includes: 

Monitoring of evidence of 
transhipment relocation outside 
the EU. The following 
disaggregation was used for the 
analysis: 

-  Western Mediterranean 
-  Central Mediterranean 
-  East Mediterranean 
-  Black sea 
-  Other 

Monitoring of evidence of 
transhipment relocation outside 
the EU. The following 
disaggregation was used for the 
analysis: 

-  Western Mediterranean 
-  Central Mediterranean 

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Port group 

Definition and selection criteria 

Use 

-  East Mediterranean 

-  Ports within 300 nautical miles 
distance from an EU port14 
-  Ports with existing container 
transhipment capability, or 
which may develop that 
capability in the short term 

Neighbouring 
non-EU ports 
(evasive port 
calls) 

Non-EU ports that have the highest 
potential to be used for evasive port 
calls (i.e. within 300 nautical miles of 
EU ports). This includes ports that are 
close to EU ports and with capacity to 
accommodate large deep-sea vessels. 

This category encompasses: 

Monitoring of evidence on 
evasive port calls.  

For the analysis, the following 
disaggregation was used: 

-  UK ports 
-  Ports in Türkiye and 

North Africa 

- 

- 

all ports falling under the above 
category (‘neighbouring non-EU 
ports (transhipment)’), except 
those beyond 300 nautical miles; 

additional ports within this 
distance range even if not 
specialised in transhipment 
activities 

Southern 
control group 

EU container ports in the Mediterranean 
for whom transhipment is not the major 
contribution to their activities. 

Northern 
control group 

EU container ports in Northern Europe 
for whom transhipment is not the major 
contribution to their activities (and that 
would be expected to be less affected 
by changes to traffic patterns in the 

Control for changes in overall 
traffic patterns in the 
Mediterranean, regardless of 
transhipment operations, for 
comparison with those identified 
at the EU transhipment ports. 

Disaggregated by basin: 

-  Western Mediterranean 
-  Central Mediterranean 
-  East Mediterranean 

Control for general changes in 
EU maritime activity, regardless 
of traffic patterns in the 
Mediterranean, for comparison 

14 Some other non-EU ports further away have been considered, as deemed relevant. 

11 

 
 
 
 
 
Port group 

Definition and selection criteria 

Use 

Mediterranean such as those due to Red 
Sea crisis). 

with those identified at the EU 
transhipment ports. 

Ports in 
islands and 
outermost 
regions 

Main ports located in EU islands and 
Outermost Regions. 

Monitoring of impacts on 
essential shipping services for 
territorial continuity and on 
Outermost Regions 

Figure 1: Map of ports included in each grouping [not showing ‘Ports in islands and outermost 
regions’] 

Port categories 

Neighbouring non-EU ports (transhipment) 

Neighbouring non-EU ports (evasive port calls) 

EU transhipment ports at risk 

Northern control group 

Southern control group 

12 

 
 
 
 
 
 
 
 
 
 
 
4.  Monitoring of possible evasive behaviours in 2024 (Q1-Q3) 

4.1. Monitoring of the risk of transhipment relocation 

•  There is currently no evidence to support the existence of a discernible trend in the relocation 

of container transhipment activities from EU to non-EU transhipment ports.  

•  There  is  an  overall  increase  in  traffic  of  containerships  in  EU  ports  located  in  West 
Mediterranean and a decrease in traffic (in particular extra-EU voyages) at the EU ports in 
the  East  Mediterranean  basin  (e.g.  Piraeus).  However,  such  trends  are  generally  similar 
across EU and non-EU ports in the region and seem to be largely driven by the Red Sea 
situation. 

Port  data  up  to  Q3  2024  has  been  analysed  by  Mediterranean  basin,  including  number  of 
containerships’  port  calls  by  type  of  voyage  and  vessel  size,  levels  of  container  transhipment 
operations and port liner shipping connectivity index. Main results are presented in Table 4 below. 
These results do not present evidence of generalised relocation of transhipment activities from EU 
to  non-EU  ports  so  far.  Changes  in  port  activity  observed  in  West  Mediterranean  and  East 
Mediterranean are considered consistent with the Red Sea crisis effects. 

Table 4: Summary of results from analysis of port activity data by Mediterranean basin 

West Med 

Central Med 

East Med 

Port calls 

(Q1-Q3 2024 
vs 2022-2023) 

Number of port calls: 
Similar upward trend 
in number of port calls 
is found in both EU 
and neighbouring non-
EU transhipment 
ports. 

Number of port calls: 
Trends observed at EU 
transhipment ports are 
generally comparable to 
those found in the control 
group and in neighbouring 
non-EU transhipment 
ports. 

Vessel size 
distribution: Increase 
in port calls from both 
feeder and large 
vessels can be 
observed in EU ports, 
consistent with trends 
in neighbouring non-
EU ports. 

Vessel size distribution: 
Increase in port calls from 
feeder vessels and 
reduction in port calls 
from large vessels, 
consistent with trends in 
neighbouring non-EU 
ports. 

Number of port calls: 
Similar small 
reduction in container 
vessel port calls in 
both EU and 
neighbouring non-EU 
transhipment ports. 
This is consistent with 
the Red Sea crisis 
effects.  

Vessel size 
distribution: Similar 
decrease in port calls 
from larger vessels is 
found in both EU and 
neighbouring non-EU 
transhipment ports. 

Voyage type 
distribution: No 

Voyage type 
distribution: No general 

Voyage type 
distribution: 

13 

 
 
 
 
 
 
 
West Med 

Central Med 

East Med 

reduction in extra-EU 
port calls at EU 
transhipment ports 
(both non-EU/EU/non-
EU and non-
EU/EU/EU voyages 
slightly increased). 

decrease in non-
EU/EU/non-EU voyages 
at EU transhipment ports, 
but a slight decrease in 
non-EU/EU/EU voyages, 
which does not seem to be 
driven by any specific 
vessel size. 

Transhipment 
operations 

(Q1-Q3 2024 
vs 2022-2023) 

Generally increasing 
levels of transhipment 
operations, both at EU 
and neighbouring non-
EU transhipment 
ports. 

An increase in container 
transhipment activities 
over time at EU and at 
neighbouring non-EU 
transhipment ports. Total 
container throughput and 
transhipment trends do not 
show any significant 
differences between the 
EU transhipment ports, the 
control group ports and 
the non-EU transhipment 
ports. 

Connectivity 

(Q1-Q3 2024 
vs 2022-2023) 

No significant 
difference in the 
evolution of 
connectivity of EU 
transhipment ports 

No significant difference 
in the overall evolution of 
connectivity of EU 
transhipment ports 
compared to neighbouring 

Decrease in extra-EU 
port calls at EU 
transhipment ports 
(both non-
EU/EU/non-EU and 
non-EU/EU/EU 
voyages), primarily 
from larger vessels 
(above 14 500 TEU15). 

Total throughput and 
transhipment 
operations remained 
relatively stable, with 
similar general trends 
in EU and 
neighbouring non-EU 
transhipment ports. 

Information for 
individual ports, 
however, shows 
decreased 
transhipment activity 
in some EU ports (e.g. 
Piraeus) coupled with 
increases in some 
Turkish ports. The 
increase in traffic in 
Turkish ports may be 
influenced by the 
Israel/Hamas crisis, 
potentially redirecting 
some traffic from 
Israel to Türkiye. 

Connectivity increased 
in Limassol but 
decreased in Piraeus 
compared to 2023. 

15 TEU: Twenty-Foot Equivalent Unit, a standard measure of cargo capacity based on a 20-foot shipping container. 

14 

 
 
 
 
 
 
West Med 

Central Med 

East Med 

compared to 
neighbouring non-EU 
transhipment ports. 

Similar overall 
variation found in 
neighbouring non-EU 
transhipment ports. 

non-EU transhipment 
ports. When looking at 
individual ports, however, 
there are some 
differences: Cagliari, 
Marsaxlokk and Taranto 
show significant 
reductions in connectivity 
while the majority of the 
other ports in the Central 
Mediterranean, both EU 
and non-EU, show much 
less variation. 

General 
remarks 

Increased activity 
levels, with no 
significant 
differences between 
EU and non-EU 
transhipment ports. 

No significant variations 
in trends for EU or non-
EU transhipment ports. 
However, there are some 
notable differences 
between EU ports. 

Variation in trends 
in both EU and 
neighbouring non-
EU transhipment 
ports overall 
consistent with 
effects of the Red Sea 
crisis. While some 
changes in specific 
ports (i.e. decrease in 
activity in Piraeus 
coupled with 
increases in some 
Turkish ports) might 
suggest some evasive 
behaviours, the main 
drivers seem to be 
the effects of the 
Israel-Hamas crisis 
and the Red Sea 
crisis. 

4.2. Monitoring  of  the  risk  of  evasive  port  calls  or  changes  in  order  of  port  calls  by 

containerships 

•  Overall,  there  is  no  evidence  of  a  generalised  implementation  of  additional  port  calls  at 
neighbouring non-EU ports by shipping companies or systematic changes in order of port 
calls by containerships to circumvent ETS rules. 

15 

 
 
 
 
 
•  There is no significant increase in containerships’ calls at UK ports before (or after) calling 
EU ports over the monitored period. Further detailed analysis of flows from the US to EU 
shows however an increase in the share of intermediate port calls in the UK when comparing 
2024 to 2023.  

•  There is no evidence of trend of evasive port calls (or changes in order of port calls) taking 

place before (or after) calling at Mediterranean EU ports. 

Overview at EU level 

Results from the EMSA route modelling tool show no overall increase (in terms of containerships’ 
port calls and total vessel capacity) of intermediate stops at neighbouring non-EU ports before (or 
after)  calling  EU  ports.  Similarly,  the  analysis  of  average  distance  on  first/last  leg  after/before 
leaving/arriving at EU ports does not point to any reduction associated with evasive calls or change 
in the order of port calls. On the contrary, average distance of the first/last leg has increased slightly 
over the monitored period compared to 2023 and 2022, most likely due to re-routing caused by the 
Red Sea crisis. 

Risk of evasive port calls in the UK 

Aggregate port call data shows no significant increase in containerships’ calls at relevant UK ports 
before (or after) calling at EU ports (also when looking at Northwest European ports only) over 
the monitored period. 

However, when looking specifically at flows from the US to the EU, an increase in the share of 
voyages with  intermediate port calls in  the UK  can be observed in  recent years. Such voyages 
represented 30% of US-EU voyages in 2023 and 34% in 2024. 

Risk of evasive port calls in Türkiye or North Africa 

Overall, with the ongoing crisis in the Red Sea affecting the number of port calls in the region, it 
is difficult to pinpoint the extent of the effects of the implementation of the EU ETS in this region, 
if any. In any case, detailed results from the EMSA route modelling tool show no overall increase 
(both in terms of total vessel capacity and total number of calls) of intermediate port calls at non-
EU Mediterranean ports before (or after) calling at EU Mediterranean ports. 

4.3. Monitoring of the risk of shifting demand to other transport modes 

•  The examined case studies (Spain-Italy and connections across the Black Sea to Bulgaria) 

reveals no evidence of a trend towards increased modal shift to road freight.  

Case study Spain-Italy (RoRo and RoPax services) 

Ro-Ro  and  RoPax  services  between  Spain  and  Italy  face  competition  with  land  transport 
alternatives (mostly road freight), given the relatively short distance between these two countries 
for both land and maritime connections. To investigate potential impacts on modal shift since the 
implementation of the EU ETS extension, port calls from RoPax and Ro-Ro cargo vessels between 
Spain and Italy have been monitored and compared against EU-wide trends for these vessel types. 
In addition, road freight traffic data up to Q1 2024 has been collected to compare against Ro-Ro 
and RoPax traffic and detect potential trends in modal shift. 

16 

 
 
 
 
Overall, the data do not point to a general or systematic reduction in the level of maritime traffic 
between  these  countries,  nor  to  an  increase  in  road  freight  transport  in  the  transport  of  goods 
between the two countries. There is therefore no clear evidence of a trend towards increase modal 
shift to road transport. However, as data available are limited to a very short period following the 
introduction of the ETS, it is too early to reach any firm conclusion. Additional data on the level 
of maritime and road freight traffic is considered necessary to further substantiate the analysis in 
future reports. 

Case study Bulgaria - neighbouring countries (RoPax and containerships) 

To  further  examine  the  possible  risk  of  modal  shift,  data  for  port  calls  from  RoPax  ships  and 
containerships at the ports of Burgas and Varna in Bulgaria have been monitored.  

The  analysis  shows  that  there  are  slight  fluctuations  in  traffic  since  the  start  of  2024  when 
considering specific vessel types but, overall, there is no available evidence at this point of any 
significant reduction in maritime traffic to the port of Burgas and Varna from neighbouring ports 
that would indicate an increased use of other transport modes (mainly road transport) to deliver 
the goods.  

4.4. Monitoring of the risk of assigning best performing vessels to EU routes 

•  The analysis shows that a slightly higher share of recent vessels (expected to be more energy-
efficient) has called at EU ports in 2024 compared to 2023; however, other considerations 
(such as global fleet replacement) are considered more likely to influence such findings. 

•  Analyses of energy efficiency indexes of vessels visiting EU ports do not show any sudden 

improvements when comparing 2024 to 2023. 

Analyses by EMSA show that 14% of the container vessel fleet visiting EU ports in 2024 are 5 
years of age or less, compared to 12% in 2023. At the same time, 20% of the fleet in 2024 is at 
least 20 years of age, compared to 19% in 2023. There is, therefore, some evidence that the fleet 
visiting  EU  ports  in  2024  is,  on  average,  slightly  younger  than  in  2023  (and,  hence,  assumed 
slightly  more  energy  efficient).  However,  the  evidence  that  such  a  trend  is  linked  to  evasive 
behaviour is not conclusive as other considerations (such as global fleet replacement levels) are 
considered more likely to influence the results. For instance, it is estimated that the percentage of 
the worldwide fleet of containerships less than 5 years of age was 17% in 2024, compared to 14,5% 
in 2023.16 

Furthermore, the analysis of energy efficiency index reported by vessels visiting EU ports from 
2022 to 2024 shows only a small improvement in the fleet’s average efficiency from 2022 to 2023, 
and none from 2023 to 2024. It provides therefore no indications of a significant change in the 
energy efficiencies of vessels used on routes to and from the EU since 2024.  

4.5. Monitoring of the potential use of ships below size threshold 

16  United  Nations  Conference  on  Trade  and  Development,  2024  Review  of  Maritime  Transport 
(UNCTAD/RMT/2024) and 2023 Review of Maritime Transport (UNCTAD/RMT/2023). 

17 

 
 
 
 
 
•  There is no evidence of an increased use of vessels between 4 000 GT and 5 000 GT in 2024 

compared to the previous year. 

If shipping companies were to use smaller vessels to circumvent ETS rules, they would most likely 
use  vessels  between  4  000  GT  and  5  000  GT  to  reduce  their  overall  operator  costs.  When 
examining these vessels, the analysis shows that they form a small percentage of the total number 
of port of calls at EU ports, with some disparities among ship types. For general cargo vessels, 
considered as the most relevant vessel category for this risk, about 11% of port visits on incoming 
extra-EU routes were by vessels in this size range in 2024. This represents a very small increase 
relative to 2022 and 2023 levels (levels were 10,6% and 9,9%, respectively). On intra-EU routes, 
the percentage of port visits by general cargo vessels  between 4 000 GT and 5 000 GT is also 
small, at about 9% in 2024; it has remained very stable since 2022.  

For other vessel categories that percentage of the port calls by vessels of this size is also small, for 
example  0.5%  for  container  vessels  and  12%  for  oil  tankers  on  incoming  extra-EU  voyages. 
Overall, the comparisons of the percentages for port calls in 2024 with those for previous years do 
not indicate any significant increase in the use of vessels above 4 000 GT and below 5 000 GT for 
any vessel category. 

4.6. Monitoring of the potential use of ship-to-ship transfers 

•  Overall, there is no evidence of an increase in the number of ship-to-ship transfers of cargo 

taking place in EU waters since January 2024. 

Analyses  of  ship-to-ship  transfers  in  EU  waters  identified  that,  while  the  number  of  transfers 
increased  significantly  in  2022  following  the  Russian  invasion  of  Ukraine,  there  has  been  no 
overall further increase since January 2024 (compared to 2023) that could indicate a greater use of 
ship-to-ship (STS) transfers as a potential evasive behaviour following the extension of the EU 
ETS to maritime transport. 

5.  Forward-looking: Review of relevant findings beyond the monitored period 

• 

• 

• 

In terms of routes announcements, while there are a few examples that may suggest a risk of 
evasion in relation to stops added in the UK, an analysis of transatlantic routes for 2025 does 
not provide indications of any discernible evasive trend through UK ports. Routes involving 
ports in the Mediterranean are likely to continue being impacted by the Red Sea crisis. 
In terms of investments, there is currently no clear evidence to conclude that a change of 
investment  patterns in  ports is  taking place leading to  a general  reduction of investments 
being made at EU ports coupled with accelerated investments at non-EU neighbouring ports. 
The  most  relevant  findings  for  investments  at  non-EU  neighbouring  ports  are  the  recent 
capacity expansion in the Port of Damietta in Egypt as it could make this port more prone to 
attract further transhipment operations. In addition, in 2027, the container handling capacity 
of Nador in Morocco is also expected to be substantially expanded. These ports should be 
closely monitored in the next years, among others. 
In terms of legislative and regulatory news, there is no identified developments in non-EU 
neighbouring countries that would increase evasion risks in the future. On the contrary, the 
recently announced carbon pricing system for maritime transport by Türkiye may contribute 

18 

 
 
 
 
to mitigate evasion risks in relation to Turkish ports. The inclusion of domestic maritime 
emissions within the UK ETS– and possibly the other half of UK-EU maritime emissions – 
should  also  partially  mitigate  evasion  risks.  Further  developments  will  be  continuously 
monitored. 

5.1. Routes changes of container lines 

Overall, there are limited announcements on route changes  affecting East  Mediterranean ports. 
Announcements  from  shipping  operators  related  to  this  region  tend  to  confirm  that  vessels  are 
expected to continue to bypass the Red Sea in 2025 and use the Cape of Good Hope, due to the 
situation in the Red Sea remaining volatile. It is therefore anticipated that traffic at Piraeus port 
will continue being  diverted away.  Some of the  diverted services from  Piraeus are expected to 
continue instead opting to use smaller feeders from West Mediterranean ports (EU ports in many 
cases) to transport cargo into the East Mediterranean. There is no evidence on routes diverted from 
Piraeus for reasons other than for re-routing around the Red Sea crisis. 

In  the  case  of  Central  Mediterranean  ports,  there  is  no  clear  identification  of  new  routes 
announcements that may affect Central Mediterranean ports on a systematic basis across the region 
and that  may be  caused  by the ETS  implementation.  It is  anticipated that  a diversion of larger 
vessels away from Malta Freeport might continue in 2025, essentially due to the continuation of 
the Red Sea crisis. 

In  West  Mediterranean  ports,  there  are  several  examples  of  non-EU  ports  (particularly  Tanger 
Med) being added to existing routes operating in this area.  Besides, there is evidence of operators 
adding  EU West  Mediterranean ports (e.g. Sines, Valencia, Barcelona) to Far East  and Middle 
East connections. Therefore, such changes are considered to be mostly related to impacts from the 
Red Sea situation. 

In the North Sea, there are several announcements of route changes, with some adding port calls 
in the UK that could suggest a possible risk of evasion. The detailed analysis comparing routes 
between North America and Northwest Europe in 2024 with those announced for 2025 points to 
various examples of routes being modified from 2024 to 2025. According to this case study, while 
few transatlantic routes include in 2025 a new stop in the UK, there are other routes where an EU 
port call is added and/or a UK port call removed. At this stage, it is therefore difficult to identify 
any clear trend of evasive behaviour planned for 2025, also in the North Sea region.  

5.2. Investments in container ports capacity expansion 

A significant number of ports capacity expansion projects for containers have been identified in 
both  EU and non-EU neighbouring  ports. Many  European ports  continue following an organic 
growth in the context of a mature market, with existing container terminals gradually increasing 
their  capacity  to  improve  their  competitiveness  and  market  share.  Driven  by  a  strong  market 
dynamic  (67%  increase  in  container  volumes  since  2010  in  non-EU  Mediterranean  countries), 
neighbouring  non-EU  ports  continue  their  swift  developments,  with  some  important  projects 
located away from older city centres.  

When summing up ports container capacity increases identified for 2025-2035, these represent 25 
million additional TEU for EU ports, compared with 34 million TEU for non-EU neighbouring 

19 

 
 
 
 
ports. For the latter, this is mainly driven by investments in the East Mediterranean (i.e. Turkey 
and Egypt) and West Mediterranean (i.e. Morocco). 

These include for instance investments in the ports of Damietta and Nador. At Damietta (Egypt), 
a  new  terminal  with  3.3  million  TEU  annual  capacity  is  expected  to  start  operations  in  2025 
(compared to 1.2 million TEU capacity currently) and aim to become Hapag-Lloyd's dedicated 
strategic transshipment hub in the East Mediterranean. At Nador (Morocco), the project to expand 
container  handling  capacity  at  the  Nador  West  Med  Terminal  is  progressing  after  a  decade  of 
planning. Once fully operational by 2027, the terminal will offer a capacity of 3.4 million TEUs 
annually (compared to negligible container handling capacity at Nador currently). A joint venture 
between CMA CGM and Marsa Maroc will equip and operate 50% of the new container terminal. 
This capacity expansion aims to complement transhipment capacity of Tanger Med. 

Currently, there is no clear evidence to conclude that a change of investment patterns in ports is 
taking place (i.e. investments being cancelled or reduced at EU ports and accelerated in competing 
non-EU  ports)  as  a  result  of  ETS.  However,  given  the  planned  investments,  it  is  important  to 
continue closely monitoring these fast-expanding neighbouring ports. 

5.3. Legislation changes in neighbouring countries 

There are no legislative and regulatory developments in non-EU neighbouring countries that could 
potentially  increase  evasion  risks  in  the  future.  On  the  contrary,  two  of  these  neighbouring 
countries,  the  UK  and  Türkiye,  have  announced  plans  on  implementing  carbon  pricing 
mechanisms for the shipping sector.  

The UK plans to expand the scope of the UK ETS to cover maritime emissions as from 2026. A 
consultation  was  launched  in  November  202417  with  the  objective  to  look  at  different 
implementation  options  as  well  as  to  consult  on  potential  future  expansion  of  the  UK  ETS  to 
additional maritime emissions. The consultation mentions the possibility to cover half of UK-EU 
emissions on top of UK domestic emissions, and potentially half of emissions from international 
voyage which starts or ends in the UK from overseas, should multilateral action through the IMO 
be delayed or prove insufficient in reducing GHG emissions from international shipping. 

 In Türkiye, the Parliament has amended its ports law in July 2024 with the intention to oblige 
commercial ships calling at Turkish ports to pay for their GHG emissions. A regulation should 
further  detail  the  coverage  of  the  system  (tonnage,  types  of  voyages),  emission  fee  rates,  and 
procedures for monitoring, reporting, and verifying emissions. It is therefore yet unclear whether 
the ETS will only apply to TK-EU voyages, domestic voyages, and/or whether it would also apply 
to extra-TK voyages, in which case it would fully address the evasion risk in relation to Turkish 
ports. 

17  UK  Emissions  Trading  Scheme  Scope  Expansion:  Maritime:  A  joint  consultation  of  the  UK  Government,  the 
Scottish Government, the Welsh Government and the Department of Agriculture, Environment and Rural Affairs for 
Northern Ireland. Closing date: 23 January 2025. 
  https://assets.publishing.service.gov.uk/media/6747627277462f7809147537/uk-ets-scope-expansion-maritime-
consultation.pdf  

20 

 
 
 
 
 
Egypt  has  also  recently  launched  a  voluntary  carbon  market,  however  there  is  no  mention  of 
maritime coverage.  

No  announced  relevant  legislation  changes  have  been  identified  in  Morocco  nor  in  any  other 
neighbouring countries that would be relevant for the present analysis. 

Besides these national legislation changes in neighbouring countries, the EU is also fully engaged 
at global level to push for an ambitious regulatory framework. There are ongoing discussions at 
the  level  of  the  International  Maritime  Organisation  (IMO)  with  a  view  to  agree  on  concrete 
measures to achieve the objectives agreed under the revised IMO GHG strategy. Outcomes at IMO 
level will be duly considered, including in the context of the monitoring of the implementation of 
the ETS Directive in relation to maritime transport. 

6.  Monitoring of other impacts 

•  ETS costs are estimated to represent on average an increase of 3,7% in overall shipping costs 

in 2024, with great variation across vessel categories. 

•  An analysis of ETS costs and surcharges shows that containership operators fully pass on 
ETS costs to shippers. The impact of the announced ETS surcharges on transport prices for 
shippers represent an increase of around 1% to 5% on freight rates. At the same time, global 
freight rates for container shipping grew approximately by 120% from October 2023 to June 
2024 due mostly to the Red Sea crisis.  

•  There is also evidence of specific ETS surcharges being applied on short sea shipping routes. 
An analysis of various ferry routes suggests that the impact of ETS costs on ticket prices 
largely varies across routes selected, with a price increase ranging from 3% to 11%. 

•  There is currently no evidence to suggest that a reduction in shipping services to EU islands 

has occurred, based on the trend in port calls analysed.  

•  Analysis of port traffic in Outermost Regions does not indicate any unusual reductions in 
any  of  the  Outermost  Regions  in  2024.  Furthermore,  there  is  little  indication  of  any 
differences  in  trends  of  port  calls  in  Outermost  Regions  depending  on  the  origin  of  the 
voyage. Transhipment activities are relatively minimal in ports of the Outermost Regions, 
except for the Canary Islands, and no significant evasive behaviours were identified. 

6.1. Impacts on transport costs 

Considering an average price for ETS allowances at 64 EUR/tCO2 in 2024, and the 40% phase-in, 
it is estimated that shipping companies will surrender around 34 million EU allowances in 2024 
(assuming 2023 activity levels), which would imply a cost of around EUR 2,200 million to acquire 
ETS allowances. When compared to total shipping costs (e.g. fuel costs, staff costs, ports fees, 
capital costs, etc.), this represents an increase of around 3,7% if no energy efficiency or emissions 
reduction measures are taken by operators and/or shipowners. 

Cost impacts vary greatly across vessel categories, depending on their relative share of intra and 
extra-EU emissions. For instance, containerships, tankers or bulk carriers usually have a higher 
share of extra-EU related emissions compared to passenger ships.  

Total ETS cost impacts in 2024 for a selected route from Far East to North Europe (Shanghai to 
Rotterdam with containership built in 2015 carrying around 14 000 TEUs) using only fossil fuels 

21 

 
 
 
 
were estimated at around EUR 145 000 per trip when re-routing via the Cape of Good Hope and 
at EUR 106 000 when sailing via the Suez Canal. This represents an additional cost of around 10 
EUR/TEU and 7 EUR/TEU, respectively, with an estimated load factor of 78%. 

Liner  operators  have  announced  ETS  surcharges  to  pass  through  ETS  costs  to  shippers.  As  an 
illustration, ETS surcharges on the route Asia to North Europe amount to 30 EUR/TEU on average 
(and 20 EUR/TEU in the opposite direction), in both cases higher than the cost of 7-10 EUR/TEU 
estimated above for this route in 2024. This seems to indicate that liner operators can fully pass 
through ETS costs, and it shows that such surcharges do not necessarily reflect the true EU ETS 
costs expected on a specific route. 

The analysis of ETS surcharges in comparison to freight rates shows that the impact of ETS on 
transport prices for shippers is likely to be limited in 2024. Announced ETS surcharges by liner 
operators are mostly within the range of 1 – 5% of container freight rates. This compares against 
the  120  percentage  points  increase  in  container  freight  rates  from  October  2023  to  June  2024, 
mostly attributable to the Red Sea crisis, as estimated by UNCTAD.18 

There is also evidence of specific ETS surcharges being applied on short sea shipping routes. An 
analysis of various ferry routes in the EU shows that the impact of ETS costs on ticket prices varies 
across routes, with a price increase ranging from 3% to 11% in 2024. 

6.2. Impacts on essential services for territorial continuity 

The analysis of port calls for top 10 ferry services to EU islands shows that, in those cases where 
there are no exemptions for domestic services to islands with fewer than 200 000 residents, ETS 
can be expected to bring relatively sizeable impacts to the total annual voyage costs, with greater 
impacts in the following years. In 2024, the ETS cost is estimated to be an additional 8% over the 
total shipping cost for ferry routes that are using 100% fossil fuels. In 2025 and 2026 the ETS cost 
is expected to increase in accordance with the phase-in approach regarding ETS allowances to be 
surrendered. To this point, there is currently no evidence to suggest that a reduction in shipping 
services to islands has occurred, based on the trend in port calls analysed, both for exempted and 
non-exempted island ports. Responses to the questionnaire sent to port authorities does not provide 
any additional evidence on supply adjustments in ferry services to islands. Therefore, the ETS cost 
in the current year does not seem to have affected the frequency of shipping services to islands or 
deterred companies from undertaking these routes, based on the data available. 

6.3. Impacts on shipping services to/from Outermost Regions 

The impact assessment on the extension of the EU ETS to maritime transport identified that the 
most remote EU territories, the outermost regions, are particularly exposed to economic impacts 
from changes in the shipping sector. This is due to several factors, including significantly longer 
voyage  legs  to  outermost  regions  than  intra-EU  journeys  (some  outermost  regions  are  10  000 
kilometres away from Europe) and significantly lower GDP per capita in these regions compared 
to their national (and wider EU) averages. It is for all these reasons that, in line with Article 349 

18 UNCTAD, 2024 Review of maritime transport (Chapter 3) RMT 2024 - Chapter III. Freight rates, maritime transport 
costs and their impact on consumer prices and economic activity 

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of  the  Treaty  on  the  Functioning  of  the  European  Union,  the  ETS  Directive  includes  specific 
derogations in relation to shipping emissions linked to EU outermost regions.  

The analysis of port calls at the different Outermost Regions in 2024 reveals trends consistent with 
previous years or linked to changes in regional traffic (in particular within the Caribbean). There 
is no evidence of unusual reductions in traffic across any of the outermost regions in 2024. 

Furthermore, there is little variation in the trends of port calls in Outermost Regions depending on 
the origin of the voyage. In the Canary Islands, there is a greater increase in 2024 of port calls on 
voyages from non-EU countries, but these appear to be related to the impacts of the situation in 
the  Red  Sea,  rather  than  to  the  extension  of  the  EU  ETS.  There  is  also  no  indication  of  any 
reduction  in  traffic  from  other  EU  Member  States  towards  outermost  regions,  or  increases  in 
national  traffic  from  the  European  continental  territory  of  a  given  Member  State  towards  its 
outermost regions nor between outermost regions of the same State, which could have indicated 
changes in routes (i.e. changes in the order of port calls) seeking to reduce ETS payments by using 
existing derogations for voyages within the same Member State. 

Container transhipment activity at ports in EU outermost regions is predominately driven by ports 
in the Canary Islands, which experienced a significant increase in early 2024. This surge is deemed 
due to the impacts of the situation in the Red Sea. In contrast, transhipment activity in ports of 
other outermost regions remained at low level. Therefore, it is not possible to identify any direct 
effects of the EU ETS on these activities in 2024. 

7.  Conclusions 

This  report  provides  an  initial  analysis  of  the  impacts  of  the  EU  ETS  extension  to  maritime 
transport, which commenced on 1 January 2024, with the objectives of detecting potential evasive 
trends at an early stage and assessing the broader implications of the system, including its effects 
on transport costs and key shipping services. 

When looking at market trends over the first three quarters of 2024, the available data shows that 
important changes in maritime traffic and routes occurred in 2024. However, these changes seem 
mainly  related  to  the  ongoing  impacts  of  the  Red  Sea  crisis,  which  resulted  in  many  shipping 
companies deviating their routes around South Africa, via the Cape of Good Hope.  

To  disentangle  the  effects  of  the  Red  Sea  from  the  ones  from  the  ETS  extension  to  the  extent 
possible, the analysis compares trends at EU and non-EU ports, taking into account their economic 
activity, location and exposure to the Red Sea crisis. The analysis shows no concrete evidence of 
a general trend in relocation of container transhipment activities, whereby neighbouring non-EU 
ports would profit from a decrease in port activity at EU ports. There is also no clear evidence 
suggesting that shipping companies are adding stops at neighbouring non-EU ports or modifying 
the order of their port calls to circumvent ETS obligations. In addition, analysis of available data 
on two case studies (Spain-Italy  and Bulgaria-neighbouring countries) provides no evidence of 
modal shift towards road transport. Furthermore, available data do not point to an increase in the 
use of smaller ships outside the scope of the system or ship-to-ship transfers, which could have 
suggested that companies are implementing such evasive behaviours.  

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When  examining  forward-looking  indicators,  including  route  announcements  for  2025  and 
planned investments in ports, the analysis reveals no discernible trends that could indicate a change 
in market behaviour resulting from the ETS extension to maritime transport. Meanwhile, the study 
highlights  the  shipping  industry's  highly  dynamic  landscape,  e.g.  with  container  shipping 
companies rapidly adapting their routes and operations in response to the Red Sea crisis. Although 
a  few  examples  suggest  that  companies  may  be  considering  circumvention  behaviours  when 
designing their future routes, the analysis does not provide conclusive and generalised evidence of 
such a trend. In addition, planned investments in ports, both in the EU and neighbouring countries, 
are not experiencing a noticeable turnaround compared to already ongoing trends in recent years, 
with many ports that continue planning ambitious investments to increase their competitiveness 
and market share, particularly for container transhipment activities.  

In  terms  of  broader  impacts,  the  ETS  extension  to  maritime  transport  and  the  obligation  for 
shipping companies to surrender EU allowances is expected to increase, on average, total shipping 
costs  by  3,7%  in  2024,  if  no  energy  efficiency  or  emissions  reduction  measures  are  taken  by 
operators  and/or  shipowners.  Higher  increases  are  anticipated  in  2025  and  2026,  linked  to  the 
phase-in approach. These costs are generally passed on to shippers by shipping companies, with 
relatively limited impact on total transport prices. ETS surcharges imposed by shipping companies 
in 2024 represent an increase of freight rates between 1% and 5% for deep sea container services 
and between 3% and 11% for various ferry lines in Europe. The analysis does not show evidence 
of  reduced  shipping  services  to  EU  islands  or  Outermost  Regions,  with  port  traffic  and 
transhipment activities remaining relatively stable. 

While  this  first  report  does  not  find  evidence  of  major  changes  directly  attributable  to  the 
introduction of the EU ETS, these conclusions should be viewed with caution due to the limitations 
of this analysis. Notably, the significant spill-over impacts of the Red Sea crisis on maritime traffic, 
the limited time since its introduction and therefore limited experience in the implementation of 
the  system  for  maritime  emissions,  and  data  limitations  all  factor  into  the  limitations  of  the 
analysis.  This  initial  report  should  therefore  be  seen  as  the  first  step  of  an  ongoing  process 
providing  the  foundation  for  future  analysis  and  for  possible  enhancements  of  the  monitoring 
approach, in particular when it comes to considering future perspectives – including consideration 
of the entry into application of the FuelEU Maritime Regulation  as  from January 2025.  In this 
endeavour,  the  Commission  will  continue  its  monitoring  activities  as  required  by  the  ETS 
Directive and will seek active support and collaboration of Member States, agencies, and relevant 
stakeholders to ensure the rapid identification of new trends, patterns, and emerging issues that 
will inform decision-making and policy development. 

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