Navigating the Geographic Scope of FuelEU Maritime: Which Voyages Are Covered and How Much Counts?
- Maximilian Schroer
- Mar 30
- 4 min read
With FuelEU Maritime now in full swing, understanding which parts of energy consumed counts on which voyage—and how much—towards your compliance balance can make or break your most cost-effective compliance strategy. The regulation applies to all vessels above 5,000 GT calling EU/EEA ports, but the percentage of energy considered under FuelEU differs dramatically depending on the voyage profile.
Today’s newsletter breaks it down in detail: we look beyond the usual intra-EU vs international distinction and explore how FuelEU handles ports in outermost regions, voyages to small islands, exemptions under public service obligations, and much more.
Understanding the FuelEU Maritime Scope: More Complex Than Expected
FuelEU Maritime defines the energy scope in Article 2(1) based on four primary voyage types:
100% of energy used while at berth in any EU/EEA port.
100% of energy used on voyages between EU/EEA ports (Intra-EU voyages).
50% of energy used on voyages to/from Outermost Regions (OMRs) of EU Member States.
50% of energy used on voyages between EU/EEA ports and third countries (Extra-EU voyages).
But it doesn’t stop there. Several geographical and operational exceptions reshape how the scope is applied—some of them permanent, others temporary until 2029 or 2030.
What Counts Where? The Voyage Scope Illustrated
Each voyage category is treated differently in terms of how much of its energy use is accounted for under FuelEU:
Intra-EU voyages carry full (100%) inclusion (see Figure 1).
International or Extra-EU voyages are only counted as 50% (see Figure 1).
OMRs trigger a 50% scope.
Low-populated island routes and some public service connections may be exempt altogether from FuelEU until 2029.
Special Geographies: Islands, Territories, and Public Routes
Outermost Regions (OMRs)
Although part of the EU, OMRs enjoy special status. Voyages to or from these areas, whether to EU or non-EU ports, only contribute 50% of their energy to your compliance balance—despite being “intra-EU.” Three member states currently have Outermost Regions: Spain (Canary Islands), Portugal (Madeira, Azores), and France (Guadeloupe, French Guyana, Martinique, Mayotte, Saint Martin, Reunion). Note that by 2031, EU ETS will handle this exposure differently than FuelEU Maritime. FuelEU Maritime further allows for exemptions of voyages between OMRs currently requested by the same three member states.
Low Populated or Small Islands (<200,000 residents)
FuelEU Maritime grants temporary exemptions for passenger ships (other than cruise ships) serving small islands within the same Member State until end 2029. On these routes, 0% of energy is counted until 2029. This includes both intra-island voyages and island-to-mainland connections, subject to notification by Member States, which has been requested by eight member states so far (Finland, Greece, Croatia, Italy, Malta, Portugal, and Spain). Again, this differs from EU ETS, while EU ETS exempts both ports until the end of 2030, FuelEU only exempts the port of the low-populated island until 2029.
Public Service Obligations (PSO)
PSOs or contracts under EU cabotage rules may also exempt island services, especially where no land borders exist. These exemptions are also temporary (until 2029) but significantly reduce compliance exposure for many domestic ferry routes. Again, EU ETS and FuelEU differ in the exemption end date as EU ETS allows exemption until end of 2030.
Non-Port Stops and Transhipment Exemptions
FuelEU applies only to recognized ports of call—meaning a stop must involve cargo operations or passenger disembarkation. Exempted stops include:
Refueling-only stops
Repairs or dry-docking
Emergency stops or assistance
Adverse weather sheltering
Transshipment ports (Tanger Med, East Port Said are expected as per the current draft)
However, even when a stop is exempt, energy used on the segment may still fall under FuelEU if either the previous or next stop is a qualifying port of call. For example, if a vessel performs cargo operations in Singapore and Rotterdam but has a bunker (refueling-only) stop on the Cap Verdes, the energy falling under the scope is still 50% of the voyage between Rotterdam and Singapore.
Compliance Implications: Why the Scope Matters
Understanding how much of a voyage’s energy is counted under FuelEU is not just a technicality—it directly affects:
Your compliance balance and potential deficits
Surplus generation potential
Alternative fuel strategy
Banking decisions
For example, a vessel trading primarily between mainland EU and outermost regions may generate less compliance surplus—even if using the same fuels—than one trading between core EU ports. Similarly, passenger ferries on exempt island routes may avoid any compliance exposure altogether. It becomes particularly essential when combined with the fuel/energy allocation allowed under FuelEU Maritime and explained in one of our previous newsletters. Note, that this allocation exercise can not only help when allocating alternative fuels but also when allocating fossil fuels with different emission factors (e.g., HFO vs MDO) to decrease compliance penalties.
Conclusion: Scope Awareness is Strategic Awareness
Knowing what counts, where, and how much under FuelEU Maritime is more than regulatory housekeeping—it’s a critical component of your compliance and commercial strategy. Want to discuss your route portfolio or confirm the scope of your upcoming voyages? Check out our comprehensive list of requested exemptions until 30th March 2025 in the appendix below or reach out to our legal team.
BetterSea’s FuelEU Maritime Compliance Platform with integrated marketplace provides you with a fast, streamlined, end-to-end process covering all potential compliance options, including external pooling and surplus trading. It allows you to comprehensively strategize your FuelEU and EU ETS compliance on a ship-specific level amidst volatile markets. Book a demo below!
Stay tuned for more insights on navigating maritime decarbonisation compliance in our upcoming newsletters. If you have any questions or need further guidance, feel free to reach out!
Best regards,
The BetterSea Team
Contact Us: info@bettersea.tech
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Appendix: List of Requested Exemptions and Other Relevant Documents
Please find a list of regulatory documents below that outline all exemptions, OMRs, etc in full detail (Status: 30th March 2025).
Low-populated or Small Islands:
Croatia | |
Denmark | |
Finland | |
Greece | |
Italy | |
Malta | |
Portugal | |
Spain |
Exemptions for OMRs:
Exemptions for PSOs:
Croatia | |
Cyprus | |
France | |
Italy | |
Spain |
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