FuelEU Maritime - Pooling

Pooling, as introduced in the FuelEU Maritime Regulation, is a practical tool that allows ships to share their greenhouse gas (GHG) compliance efforts. Instead of every ship needing to meet GHG intensity targets independently, pooling enables a group of ships to achieve compliance together by redistributing surplus credits from low-emitting ships to those that exceed the limits. This mechanism makes compliance more flexible, cost-efficient, and collaborative, especially during the transition to low-carbon fuels and technologies.As long as the group’s combined balance is positive, no penalties are applied, making pooling a lifeline for operators managing diverse fleets.

The Need for Pooling

Pooling addresses a fundamental challenge in the maritime industry: the variation in ships’ readiness to meet GHG targets. Not every vessel is equipped with cutting-edge green technologies or has access to low-GHG fuels. Older or traditionally powered ships might struggle to comply, while newer ships using advanced fuels like e-methanol or bio-LNG could easily outperform the regulatory requirements. Pooling bridges this gap by allowing these ships to collaborate, easing the burden on less-equipped vessels while providing incentives for greener operations.

Beyond flexibility, pooling has a financial dimension. Ships running on low-GHG fuels can monetise their surplus credits by sharing them with higher-emitting ships, offsetting their own costs. At the same time, pooling spares less-efficient ships from paying penalties, which can be substantial. For instance, penalties for non-compliance are set at approximately €643 per tonne of CO? equivalent in 2025, and this cost can escalate over time. Pooling, therefore, benefits all participants by creating a collaborative and financially viable pathway to compliance.

How Pooling Works in Practice

To understand pooling, consider a scenario in 2025, when the FuelEU regulation sets a GHG intensity limit of 89.34 grams of CO? equivalent per megajoule (gCO?eq/MJ). Imagine two ships, each operating under different conditions.

The first, Ship A, runs on e-methanol, a low-emission fuel, achieving an intensity of 50 gCO?eq/MJ. By emitting significantly less than the limit, Ship A generates a surplus compliance balance of 200 tonnes of CO? equivalent over the reporting year. The second, Ship B, uses marine gas oil (MGO), a conventional fuel, and emits at 100 gCO?eq/MJ, resulting in a deficit of 150 tonnes of CO? equivalent.

Through pooling, Ship A can transfer 150 tonnes of its surplus to Ship B, neutralising Ship B’s deficit. After the transfer, Ship B achieves compliance without penalties, and Ship A retains a surplus of 50 tonnes for future use or additional pooling agreements. Together, these ships comply with the regulation as a group, demonstrating how pooling can facilitate cost-effective compliance and collaboration.

Pooling Versus Banking

While pooling and banking are both mechanisms under FuelEU Maritime, they operate in distinct ways. Banking allows an individual ship to save its surplus credits for future years, providing a safety net for that specific ship in case of future challenges. These credits remain tied to the ship and can follow it even if ownership changes.

Pooling, on the other hand, is a shared effort. It enables surplus credits to be redistributed within a group of ships in the same reporting year. This redistribution supports underperforming ships immediately, helping the entire pool meet compliance targets. In essence, banking is about planning ahead for individual compliance, while pooling is about collective problem-solving in the present.

The Broader Significance of Pooling

Pooling is more than just a regulatory tool—it’s a strategic enabler for the maritime industry’s transition to sustainability. For fleet operators, it offers an opportunity to manage compliance in a cost-efficient manner, especially for fleets with a mix of older and newer vessels. It also incentivizes early adopters of low-GHG fuels and technologies, as they can capitalize on their surplus performance by participating in pooling agreements.

This mechanism fosters a culture of collaboration in the maritime sector, allowing companies with different capabilities to work together toward a common goal. Even ships from different ownership can join the same pool, creating a flexible framework that benefits the industry as a whole.

Pooling as a Transitional Strategy

As GHG intensity targets become stricter over time, pooling will remain a valuable tool, especially in the early years of the FuelEU regulation. For instance, in 2025, a single e-methanol-fueled ship can generate enough surplus to offset the deficits of multiple MGO-fueled ships. However, as the regulatory limits tighten, the ability to share compliance will diminish, requiring broader adoption of low-carbon fuels and innovative technologies.

Pooling is not a permanent solution but a transitional one. It supports the maritime industry during its shift toward greener operations while providing financial and operational incentives for early adopters. By enabling collaboration and reducing the compliance burden, pooling ensures that the industry can meet ambitious regulatory goals while navigating the practical challenges of transformation.

ER-Marine’s Role in Facilitating Pooling and Compliance

ER-Marine is committed to helping shipowners navigate FuelEU Maritime compliance through solutions like auxiliary system optimisation and methane slip reduction. By providing strategic guidance on pooling and other compliance mechanisms, ER-Marine ensures clients can minimize costs while meeting GHG intensity targets. With a focus on practical, efficient strategies, ER-Marine is a trusted partner in the maritime industry's transition to greener operations.