Duyurular

SİRKÜLER NO: 6.12 / 451-342 = 20/07/2026

Üyesi bulunduğumuz FONASBA' dan 20.07.2026 tarihinde almış olduğumuz e- posta mesajı aşağıdaki gibidir.  

EU ETS Revision: Maritime Stakeholder Perspectives and Invitation for Member Feedback

FONASBA Members’ Briefing

‘’Dear FONASBA and ECASBA Members,

Following the publication of the European Commission’s proposal for the revision of the EU Emissions Trading System (EU ETS), we continue to monitor developments closely and to assess the implications for ship agents, ship brokers, shipping companies, ports and the wider maritime supply chain.

The revision proposal represents an important stage in the evolution of Europe’s climate policy framework. As discussions now progress within the European Parliament and the Council, the maritime sector is actively evaluating both the opportunities and challenges arising from the proposed changes.

To support members in understanding the evolving debate, we have prepared this briefing summarising the initial reactions from key maritime organisations and associations with whom we engage closely. Their views reflect the different perspectives of shipowners, ports, shipbrokers, agents and other maritime stakeholders. While positions vary, several common themes are emerging, particularly regarding competitiveness, investment support, carbon leakage, alignment with future IMO measures and the need to ensure that ETS revenues effectively support maritime decarbonisation.

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Reference Material: ETS Review Presentation and Additional Information

Members may also wish to refer to the attached presentation:

•           “ETS Review” – 17 July 2026. This presentation provides further background on the current legislative discussions, the proposed amendments and the potential consequences for maritime stakeholders.

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Summary of Key Maritime Organisation Positions

European Shipowners (ECSA)

Overall Position

ECSA welcomes several elements of the European Commission’s proposal but considers that additional improvements are required to protect the competitiveness of European shipping while supporting the transition towards zero-emission operations.

Positive Developments Highlighted

•           Allocation of approximately 110 million ETS allowances to support shipping-related decarbonisation projects.

•           Partial allocation of ETS revenues towards maritime transition measures.

•           Increased support for sustainable maritime fuels.

•           Simplification of reporting requirements between EU ETS and FuelEU Maritime.

•           Improved recognition of offshore shipping activities.

Main Concerns

ECSA highlights concerns that:

•           Support mechanisms should remain open to all technologies capable of delivering meaningful emissions reductions.

•           Temporary derogations for islands, outermost regions and ice-class vessels should receive stronger consideration.

•           Competitiveness measures must ensure a genuine level playing field across all shipping sectors.

•           Greater clarity is required regarding the future relationship between EU ETS and any global IMO greenhouse gas framework.

ECSA Message

The proposal represents progress, but substantially greater reinvestment of ETS revenues into maritime decarbonisation and clearer alignment with future IMO measures are required.

________________________________________

European Sea Ports Organisation (ESPO)

Overall Position

ESPO recognises that the Commission’s proposal addresses some concerns regarding carbon leakage and competitive distortions affecting European ports, but believes further assessment is required.

Key Points

Positive developments include:

•           Recognition of the competitive disadvantage experienced by some European ports compared with neighbouring non-EU ports.

•           Measures intended to reduce evasive port calls.

However, ESPO highlights concerns regarding:

•           The effectiveness and complexity of anti-evasion measures.

•           The impact of extending ETS coverage to vessels between 400 GT and 5,000 GT.

•           The potential consequences for short-sea shipping and modal shift.

•           The continued need for alignment with future global IMO measures.

ESPO Message

Climate ambition must be accompanied by measures that prevent the relocation of emissions, cargo flows and investment outside the European Union.

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Perspective from Germany Shipbrokers Association - Zentralverband Deutscher Schiffsmakler e.V

FONASBA greatly appreciates the contribution provided by our German members and Dr Alexander Geisler, representing the views of the German Shipbrokers Association.

Their assessment highlights that the European Union’s proposals seek to balance climate objectives with competitiveness, security of supply and industrial investment.

Key elements of the proposal include:

•           A slower reduction of the emissions cap after 2030.

•           Continued availability of allowances beyond 2040.

•           Recognition of high-quality international emission credits between 2036 and 2040.

•           Integration of permanent CO² removals.

•           Adjustments to the Market Stability Reserve.

•           Greater reinvestment of ETS revenues into decarbonisation sectors, including shipping.

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Specific Maritime Provisions Highlighted

1. Sustainable Maritime Alternative Propulsion (SMAP)

The proposed SMAP mechanism would make approximately 110 million allowances available between 2028 and 2040 to support maritime decarbonisation.

Funding could support:

•           Advanced biofuels.

•           E-fuels.

•           Electrification.

•           Wind-assisted propulsion.

•           Other low-emission technologies.

The German Shipbrokers Association notes that this could represent a significant support mechanism, depending on accessibility and practical implementation.

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2. Possible Inclusion of Smaller Ships

The extension of ETS coverage to high-emission vessels between 400 and 5,000 GT is identified as a particularly important issue for:

•           Short-sea shipping.

•           Smaller cargo vessels.

•           Feeder vessels.

•           Offshore and supply vessels.

•           Workboats.

•           Ferry and specialised services.

The Association highlights the potential for additional administrative requirements, documentation obligations and cost exposure, particularly for smaller operators.

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3. Protection Against Traffic Diversion

The proposed measures to address carbon leakage and evasive port calls are welcomed in principle, but careful implementation will be required to avoid creating new market distortions or excessive complexity.

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4. Simplified Reporting

The proposed alignment of ETS and FuelEU Maritime reporting requirements is considered positive, provided that:

•           Digital systems are standardised.

•           Responsibilities are clearly allocated.

•           Smaller companies receive appropriate support.

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Implications for Shipbrokers, Ship Agents and Maritime Service Providers

The German Shipbrokers Association highlights several areas where maritime intermediaries may experience indirect impacts:

•           ETS costs will increasingly need to be reflected in voyage calculations and port cost assessments.

•           Charter party and agency agreements should clearly define responsibility for emissions data and allowance costs.

•           Smaller vessel operators may require additional advice and support.

•           Port calls, cargo movements and transhipment patterns may become increasingly relevant for ETS calculations.

For ship agents and brokers, the evolving ETS framework reinforces the importance of accurate information exchange, contractual clarity and close cooperation throughout the maritime supply chain.

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FONASBA/ECASBA Overall Assessment

The revision proposal presents both opportunities and challenges.

Positive developments include:

•           Increased recognition that ETS revenues should contribute to maritime decarbonisation.

•           Creation of dedicated support mechanisms such as SMAP.

•           Improved coordination between ETS and FuelEU Maritime reporting.

However, concerns remain regarding:

•           The extension of ETS obligations to smaller vessels.

•           Administrative burdens on smaller companies.

•           The accessibility of funding mechanisms.

•           The need to avoid double regulation between EU and future IMO systems.

•           Ensuring that maritime revenues are reinvested effectively into the sector.

The final impact will depend significantly on:

•           The final definition of vessels covered between 400 and 5,000 GT.

•           The practical accessibility of SMAP funding.

•           The proportion of ETS revenues returned to maritime projects.

•           The outcome of negotiations between European institutions.

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FONASBA/ECASB Request for Member Feedback

As the legislative process develops, we wish to ensure that the views and experiences of our members are fully reflected.

We therefore invite all FONASBA and ECASBA member associations to share their comments, observations and national perspectives regarding the proposed ETS revisions.

Members are particularly encouraged to provide views on:

•           The impact of ETS developments on ship agents and ship brokers.

•           The practical consequences for smaller operators and short-sea shipping.

•           The effectiveness of proposed support mechanisms.

•           Concerns regarding competitiveness and carbon leakage.

•           National experiences with implementation challenges.

•           Recommendations that FONASBA should consider in future engagement with European institutions and maritime stakeholders.

Your feedback will be valuable in helping FONASBA represent the interests of our global membership and ensure that the perspective of ship agents and ship brokers remains visible in the ongoing policy discussions.

We thank all members for their continued engagement and cooperation.

Yours sincerely,’’

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Ek1: 2027-07-17-TB-ETS-review_0901

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