Frequently Asked Questions

For companies with under-compliance, pooling represents a straightforward compliance option that can be utilised easily without any investments or technical adjustments of the ship. It does not pose any technical or commercial risks, such as recent reports of engine damages due to cashew nut-based biofuels or supply constraints, the use of alternative fuels may have especially for smaller shipping companies. For companies with over-compliance, pooling represents an option to commercialise their emission reductions similar to book-and-claim schemes on the voluntary market.

In contrast to other environmental regulations such as CII and EU ETS, FuelEU Maritime not only considers greenhouse gas emissions instead of only CO2 but also the full lifecycle of the fuel. This approach is generally referred to as well-to-wake (WtW).

Pooling is a completely new compliance mechanism with several complexities such as contractual arrangements, liabilities of pooling partners, and data alignment. Further, the price of external pooling, commonly referred to as surplus value, is likely to be volatile and seasonal with an expected higher value by the end of the compliance period and before the final pool reporting date (30th April of the following year). Engaging in pooling early can therefore significantly decrease the cost of compliance with FuelEU Maritime and ultimately does not expose any additional risk as unutilised surplus can always be banked for use in future compliance periods.

Pooling is one of the mechanisms shipping companies can utilise under the FuelEU Maritime Regulation to achieve compliance. It allows companies to comply on a group rather than ship level. Within a group of ships, so-called pools, compliance is determined by summing the compliance balances (numerical value showing compliance under FuelEU) of each ship. This allows for over-compliant ships to offset under-compliant ships and shall foster long-term investments in low-carbon fleets. Pooling is not restricted to single companies but can also be done in a Business-to-Business (B2B) environment.

The deadline stipulated by the FuelEU Maritime Regulation for pool verification and reporting is the 30th of April of the following year. For the reporting period 2025, this would be 30th April 2026.

The FuelEU Maritime Regulation is part of EU’s Fit for 55 package targeting the uptake of low-carbon fuels in the maritime industry. It assesses the well-to-wake greenhouse gas intensity of ships above 5,000 GT calling EU ports based on a regulatory limit. In case of non-compliance, shipping companies face a penalty of 2,400 €/t VLSFOe.

The price of external pooling under FuelEU Maritime, commonly referred to as surplus value, is likely to be volatile and seasonal with an expected higher value by the end of the compliance period and before final pool reporting date (30th April of the following year). Several studies have been conducted to forecast the value. BetterSea has also done market research, during which the average price was 421 EUR/t CO2e with a spread of 250 to 550 EUR/t CO2e. While the actual price remains exposed to volatility, the value will naturally be capped at 640 EUR/t CO2e, the penalty price. Some companies may also compare the surplus value with corresponding biofuel prices to find the most cost-effective compliance option.

FuelEU Maritime allows for a number of different compliance means and mechanisms. Direct compliance can be achieved with the use of alternative fuels (e.g., biofuels or RFNBOs), wind-assisted propulsion, and onshore power supply. By 2030, the latter becomes mandatory for container and passenger ships. On top of these direct options, the regulation created different compliance mechanisms: banking, borrowing, and pooling. Any over-compliance achieved under FuelEU can be banked infinitely and utilised in later compliance years. On the contrary, borrowing refers to covering up to 2% under-compliance with a ship’s next year compliance balance. Pooling describes the grouping of vessels to share positive compliance balance (surplus) and achieve compliance with the regulation (please read more under “What is pooling?”). Lastly, a penalty can be paid (2,400 EUR/t VLSFOe) but consecutive non-compliance will be additionally penalised.

The FuelEU Maritime regulation does not allow for ships to be in more than one pool within the same compliance period. In the case that a charterer has the pooling rights for a ship but the charter period is less than the current compliance period, it is of utmost importance to align with the owner as well as the future charterer on how compliance shall be achieved on the vessel within that particular FuelEU compliance period.

The ISM company is generally responsible for compliance with the FuelEU Maritime regulation. However, in most cases, the ISM company does not control the fuel supply of the vessel and, therefore, its compliance exposure. The responsibility to achieve compliance is, therefore, contractually passed on to other entities, such as the charterer. These contractual arrangements are highly individual and do not allow for a general statement. But it is fair to say that in most cases surplus ownership (pooling rights) are assigned to the charterer in case of long-term charter arrangements of a minimum of one compliance period, whereas owners remain surplus ownership for shorter charter periods. This approach is followed by BIMCO’s FuelEU charter clause.

The responsibility to achieve FuelEU compliance is usually contractually passed on from the ISM company to other entities such as the charterer. These contractual arrangements are highly individual and do not allow for a general statement. But it is fair to say that in most cases surplus ownership (pooling rights) is assigned to the charterer in case of long-term charter arrangements of a minimum of one compliance period, whereas owners remain surplus ownership for shorter charter periods. This approach is followed by BIMCO’s FuelEU charter clause.

No, each transaction is based on the price that the interested parties negotiate with each other. BetterSea does not set or control the FuelEU surplus value.

The BetterSea FuelEU Maritime platform uniquely combines a compliance mechanisms-independent approach that allows users to successfully balance their initial FuelEU compliance strategies with potential changes that may result from operational or market changes. It allows to execute end-to-end on all potential FuelEU compliance mechanisms, banking, borrowing, alternative fuels, external and internal pooling in a single platform, preparing the user to not only follow their compliance strategy but also react if necessary. As the only FuelEU platform in the market, it provides a fully developed and streamlined framework around pooling, including the necessary contractual and financial processes and documents, making the initially overwhelming task of setting up B2B pools a few simple clicks in a software.

While BetterSea discloses a surplus rate for different time periods based on historic trading data, it does not define the price of the surplus. Instead, B2B negotiations between interested parties define the individual price per transaction.

BetterSea FuelEU Maritime platform allows for internal pooling, as well. The user can use the FuelEU Maritime platform to form and track an internal pool.

No, BetterSea does not create a supercool resulting out of all surplus trades. Instead, the users form their pools based on their own FuelEU pooling marketplace engagement.

This is possible. In that case, the offering on the FuelEU Maritime pooling marketplace would automatically reduce by the amount of surplus sold and you can continue to sell the remaining amount, creating a multilateral pool.