EU ETS surcharge variation highlights transparency challenge for shippers

The comparison does not indicate that carriers are overcharging: published surcharges may also include FuelEU Maritime costs, fuel-related expenses and other carrier-specific commercial assumptions. Instead, the analysis highlights the difficulty shippers face in identifying and comparing the EU ETS component of a broader surcharge.

VesselBot’s case study found that routing and shipment execution can significantly affect a container’s EU ETS exposure, while a standardised per-TEU surcharge may not reflect those differences.

The analysis of Q2 2026 container shipping data found that more than 20,000 EU/EEA-linked voyages generated 11.8 million tonnes of CO₂e, of which 7.15 million tonnes were subject to allowance surrender.

Based on an EU Allowance price of €80 per tonne, VesselBot estimated the associated carbon cost at €572.4 million for the quarter.

However, VesselBot said these fleet-wide figures do not necessarily reflect the costs associated with individual shipments, as the same cargo may move across multiple legs of a carrier’s network.

Instead, it examined individual trades to assess how closely carrier surcharges corresponded with the estimated EU ETS exposure generated by the voyages moving the cargo.

Different routes, different exposure

The case study examined CMA CGM voyages from Singapore to Rotterdam, Valencia and Piraeus.

VesselBot estimated EU ETS exposure of between €26.3 and €30.5 per TEU across the three routes, compared with published Energy Transition Surcharges of €56 per TEU for Singapore–Valencia and Singapore–Piraeus, and €70 per TEU for Singapore–Rotterdam.

The company stresses that the difference should not be interpreted as evidence of overcharging, as the Energy Transition Surcharge also incorporates FuelEU Maritime costs and other carrier-specific commercial assumptions.

Instead, VesselBot says the comparison illustrates the difficulty of identifying the EU ETS component of a broader surcharge without considering how a shipment was executed.

Constantine Komodromos, CEO of VesselBot, said the “underlying ETS cost varies by route, but the amount charged to shippers can also differ” according to the differing methodology used by individual carriers. According to Komodromos, the approach to incorporate EU ETS into wider surcharges    is common but is not applied consistently across carriers.

As a result, shippers may need to assess individual shipments according to the carrier, trade and surcharge methodology involved.

The impact of routing

The effect of shipment execution becomes particularly apparent when a vessel calls at a non-EU/EEA port before entering the EU.

VesselBot examined seven CMA CGM-related voyages involving Singapore, Felixstowe and Zeebrugge. Under EU ETS rules, the Singapore–Felixstowe leg falls outside the scheme, while 50% of emissions on the subsequent Felixstowe–Zeebrugge leg are within scope.

Across the seven voyages, 89,949 tonnes of CO₂e were emitted, but just 451.1 tonnes – 0.5% of the total – were subject to allowance surrender. VesselBot estimated the resulting exposure at approximately €36,100 across the seven voyages.

CMA CGM’s published Energy Transition Surcharge for bookings from Singapore to Zeebrugge was €70 per TEU. On a 100-TEU shipment, this would result in a €7,000 surcharge.

The estimated ETS liability associated with each of the seven observed Felixstowe–Zeebrugge voyages ranged from approximately €4,400 to €6,000.

VesselBot argues that the example demonstrates how routing can alter the underlying ETS cost while a standardised per-TEU surcharge remains unchanged.

A transparency challenge

According to Komodromos, greater transparency around the calculation of ETS-related surcharges would theoretically involve carriers “provid[ing] shippers with detailed information on how each shipment was executed, involving port rotations, vessel utilization, fuel consumption and other vessel and voyage level factors that determine emissions.”

However, he said, “providing this level of transparency at shipment level is difficult to scale and often involves commercially sensitive operational data”.

“Carriers manage thousands of shipments every day, and collecting, validating and reporting vessel and voyage level information for each shipment creates significant operational and data management challenges.”

There is also a question of how shippers would interpret the information once it had been provided, as Komodromos highlights, shippers “need the expertise and analytical capabilities to translate it into meaningful insights”.

Komodromos said an alternative is to use an independent methodology to reconstruct vessel movements and calculate voyage emissions, allowing shippers to benchmark surcharges without requiring carriers to disclose commercially sensitive operational information.

VesselBot uses AIS data alongside digital-twin and fuel-consumption models to calculate voyage emissions and allocate regulatory exposure at shipment level.

The company argues that applying a consistent methodology across carriers could give shippers and beneficial cargo owners a common reference point for comparing ETS, fuel and alternative-fuel surcharges.

Beyond the surcharge

The issue extends beyond the size of an individual surcharge, according to the case study.

VesselBot argues that shipment execution data can allow procurement teams to distinguish between the estimated regulatory exposure generated by a particular voyage and other elements incorporated into a carrier’s surcharge.

Its Q2 analysis concluded that direct Asia-to-EU voyages examined in the study generated estimated ETS costs of approximately €26–€31 per TEU, while the observed services entering the EU through a non-EU/EEA intermediate port generated substantially lower exposure.

For shippers, the company says this creates a need to look beyond the published surcharge when assessing transportation costs.

“Rather than applying a single, standardized approach, they must assess each shipment based on the carrier, trade and surcharge methodology being used,” Komodromos said.

As EU ETS and other regulatory costs become a larger component of freight spend, VesselBot argues that shipment-level data could provide procurement teams with a more consistent basis for understanding and benchmarking those costs.

To read the full report:

EU ETS Surcharges vs. Actual Voyage Exposure What Shipment Execution Data Reveals.pdf