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May 25, 2022
Lockton P.L. Ferrari

Newsletter 04-22

The European Union’s Emissions Trading System (EU ETS) was extended to cover emissions from shipping as of 1st January 2024.

The EU ETS is limited by a 'cap' on the number of emission allowances. Within the cap, companies receive or buy emission allowances, which they can trade as needed. The cap decreases every year, ensuring that total emissions fall.

Each allowance gives the holder the right to emit:

  • One tonne of carbon dioxide (CO2), or;
  • The equivalent amount of other powerful greenhouse gases, nitrous oxide (N2O) and perfluorocarbons (PFCs).
  • The price of one ton of CO2 allowance under the EU ETS has fluctuated between EUR 60 and almost EUR 100 in the past two years. The total cost of emissions will vary based on the cost of the allowance at the time of purchase, the vessel’s emissions profile and the total volume of voyages performed within the EU ETS area. The below is for illustration purposes:
  • ~A 30.000 GT passenger ship has total emissions of 20.000 tonnes in a reporting year, of which 9.000 are within the EU, 7.000 at berth within the EU and 4.000 are between the EU and an outside port. The average price of the allowance is EUR 75 per tonne. The total cost would be as follows:
  • ~~9.000 * EUR 75 = EUR 675.000
  • ~~7.000 * EUR 75 = EUR 525.000
  • ~~4.000 * EUR 75 * 50% = EUR 150.000
  • ~~Total = EUR 1.350.000 (of which 40% is payable in 2024)
  • For 2024, a 60% rebate is admitted to the vessels involved. However, this is reduced to 30% in 2025, before payment is due for 100% with effect from 2026.
  • Emissions reporting is done for each individual ship, where the ship submits their data to a verifier (such as a class society) which in turns allows the shipowner to issue a verified company emissions report. This report is then submitted to the administering authority, and it is this data that informs what emission allowances need to be surrendered to the authority.
  • The sanctions for non- compliance are severe, and in the case of a ship that has failed to comply with the monitoring and reporting obligations for two or more consecutive reporting periods, and where other enforcement measures have failed to ensure compliance, the competent authority of an EEA port of entry may issue an expulsion order. Where such a ship flies the flag of an EEA country and enters or is found in one of its ports, the country concerned will, after giving the opportunity to the company concerned to submit its observations, detain the ship until the company fulfils its monitoring and reporting obligations.
  • Per the EU’s Implementing Regulation, it is the Shipowner who remains ultimately responsible for complying with the EU ETS system.

There are a number of great resources on the regulatory and practical aspects of the system – none better than the EU’s own:

25th May 2022

Following the recent developments of the Russian – Ukrainian situation, the UKGovernment published a General Trade Licence that impacts all Members insured with UK-domiciled IG Group P&I Clubs, and mandates that Clubs are to collect and maintain recordsof transits through Russian waters and calls to Russian ports.

This legislation is in addition to sanctions regulations and imposes a licensing requirementfor lawful trade, operating in accordance with sanctions restrictions, to enable Clubs toinsure and handle claims arising from such trade to and from, or transiting through, Russianwaters.

All vessels owners (regardless of flag or domicile of member or ship) are thereforerequested to provide to the Clubs within one month of a call to any Russian port or a transitthrough Russian waters the information requested together with a copy of the bill(s) oflading for the relevant voyage.

Failure by Members to provide the necessary information requested may invalidatetheir P&I cover or deny them claims coverage and therefore compliance is of vitalimportance.

The circulars issued by each Club on this matter together with the description of thenecessary data to provide in this respect of each transit through Russian waters and callsto Russian ports can be found at the following links:

The Standard Club club-circulars/18_May_2022__Standard_UK_circular_-_General_Trade_Licence.pdf club-circulars/18_May_2022__Standard_Asia_circular_-_General_Trade_Licence.pdf club-circulars/18_May_2022__Standard_Ireland_circular_-_General_Trade_Licence.pdf

Steamship Mutual

North of England transiting-russian-territorial-waters/

West of England marc/


Skuld waters/

Britannia P&I transiting-Russian-territorial-waters-05-2022.pdf

Shipowners Reporting-of-vessel-calls-to-Russia-and-transiting-Russian-territorial-waters.pdf


The London P&I Club

The Swedish Club vessel-calls-to-russia-and-transiting-russian-territorial-waters

This newsletter, and our information archive, can also be accessed at

P.L. FERRARI & CO. S.r.l.

P.L.Ferrari – A Member of the Lockton Group of Companies

This newsletter is intended solely as an overview of the marine market and does not constitute any form of advice. It is based on sources believed to be accurate at the time of printing andwe cannot be held liable for the omission of any information within the newsletter.

Newsletter 04-22
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