Navigating the evolving EU ETS legislation

Since the start of the year, considerable changes to maritime legislation have continued to develop, with the latest update from the European Commission about EU ETS from just last month. Under the Regulation (EU) 2015/757 of the European Parliament and of the Council, regarding rules for the monitoring greenhouse gas emissions from offshore ships and the zero-rating of sustainable fuels, it has now been announced that offshore vessels, such as dredging ships, will now need to be compliant – acknowledging that some further clarification was needed.

From 1 January 2025, greenhouse gas emissions from offshore ships not below 400 gross tonnage (GT) will need to comply with the scope of the Regulation – which is a sizable change from the previous threshold of 5,000 GT – alongside a feasibility report submitted to the European Commission by 31 December 2026. This now includes dredgers (ad) and hopper dredgers (ae), as updated in Annex I of the Regulation.

What does it mean to the dredging sector?

The key impact is that offshore vessels – including dredgers and hopper dredgers – must maintain documentation, such as statutory certifications, monitoring plans, annual emission reports, verification reports and improvement reports, confirming their design or certification for offshore operations. This change means that from 1 January 2025, emissions during voyages to and from EU ports, as well as operations within EU ports, will need to be recorded and monitored to comply.

The zero-rating for using sustainable fuels, such as Renewable Fuels of Non-Biological Origin (RFNBOs), Recycled Carbon Fuels (RCFs) and Synthetic low-carbon fuels will now also apply to dredgers and hopper dredgers, allowing operators to offset carbon emissions against their sustainable activities.

How will the change impact dredging operators?

With this change, operators now face a more stringent regulatory framework aimed at reducing the environmental impact of dredging operations. The increased reporting regulations upon dredging activities in EU waters will be mandated for voyages and port operations, with penalties for those who don’t comply.

There are steps the dredging sector can take to transition their operations effectively, from my professional view:

·??????? Sustainable fuels

Investing in RFNBOs or other sustainable fuel technologies is no longer optional but will give the user a competitive advantage. The zero-rating benefit of these fuels allows dredging companies to demonstrate environmental responsibility, while reducing emissions-related costs.

·??????? Cost effective compliance

Operators need to implement accurate monitoring and reporting systems, which must be in place by 1 January 2025 to avoid fines. The cost of such transition will likely increase OPEX as new processes are implemented and it is expected to have a wider impact on CAPEX investment in some fleets, as less sustainable vessels may need to be decommissioned or altered to ensure they will be compliant.

The changes will create an immediate pinch point for dredging operators as introducing new processes, fuels and decommissioning/altering of unsuitable vessels all impact the operational costs, but will also have a knock-on effect on resources internally and potentially the operational capacity for staff.

There are alternatives available on the market which have been developed to make reductions and efficiencies, in areas such as CAPEX, OPEX and emissions. New dredging innovations, like Haven Dredging’s Tiamat, offer a practical, scalable solution for port authorities and shipping operators looking to navigate the compliance challenges, while maintaining capacity.

Tiamat avoids the substantial mobilisation and demobilisation costs typically associated with large-scale operations, thanks to its ability to be deployed from a standard workboat, its functionality to redistribute natural waste into the tidal system removing the need to visit offshore disposal sites and its modular design which can be transported by land or sea in a freight container. Its efficiency makes it a highly attractive option for ports seeking a cost-effective environmental solution, and case studies have proven it can reduce operational costs to around ￡1 per cubic meter when compared to ￡2-3 per cubic metre for a TSHD campaign.

·??????? Reducing GHG emissions

Under the EU ETS legislation, it is important to reduce emissions to comply with mandatory caps and avoid the associated financial penalties, as well as preserving our planet for centuries to come. This means finding and developing innovative solutions with low-carbon technologies to protect our valuable marine ecosystems, which will become essential for the future.

Tiamat’s hydrodynamic dredging capabilities significantly reduce GHG emissions by up to 90% on a like-for-like basis compared to traditional dredging methods. As the industry prioritises emissions reductions, Tiamat stands out as a tool to help ports and operators meet regulatory requirements.

·??????? Operational flexibility

Inevitably, the new legislation imposes a huge pressure upon the dredging sector, with a short window of time to define new reporting measures and manage the changes expected on CAPEX and OPEX budgets. In addition to the increased financial impact, this change is likely to impact the operating capacity as operational staff engage in additional administration processes and older plant may need mechanical adaption or removal from the fleet.

Tiamat’s ability to deploy from workboats which are below the EU ETS limits, provides a versatile option for ports and operators looking to quickly adapt to the increased pressure while aiming to decarbonise without triggering additional compliance obligations. Furthermore, its modular design allows it to be shipped globally via standard containers, offering unparalleled flexibility.?

·??????? Implementing new strategies

The change in legislation offers dredging companies an opportunity to adopt innovative strategies, such as a navigable mud management. By improving sediment surveying techniques, companies can accurately determine when compacted sediments reach depths that impede navigation, ensuring dredging occurs only when necessary. This approach minimises operational costs by reducing unnecessary dredging activities and fuel consumption, whilst also lowering emissions.?

The EU ETS remains the most developed framework, with further revisions set for 2025 expected to evaluate its overlap with IMO policies and expand its scope

In contrast, the IMO is anticipated to continue its focus on regulating shipping activity of vessels with international operations, with an expectation to exclude port-specific requirements. The IMO’s policies will be effective from 2027 and will initially apply to vessels over 5,000 GT, and could extend to those over 400 GT as soon as 2028. While ships engaged solely in domestic shipping are likely to remain exempt under the IMO’s evolving Life Cycle Assessment (LCA) guidelines which are designed to set a standardised threshold for GHG intensity measures and Well-to-Wake (WtW) emissions.?

The UK meanwhile, has yet to clarify its Clean Maritime Plan, though it is expected to align with IMO and EU policies while avoiding duplication. With minimal funding allocated to green corridors, the UK’s approach remains energy-agnostic, favouring electrification and system-wide GHG reductions.?

As the legislative frameworks of the EU, UK and IMO continue to evolve, the maritime industry must prepare for increasing scrutiny of emissions and operational practices. Tiamat provides a robust, innovative solution to help ports and shipping operators navigate these challenges. By reducing GHG emissions, offering cost effective deployment and operating flexibly across global markets, Tiamat not only supports compliance but also drives meaningful environmental progress.?

To find out more about Tiamat and the latest news from Haven Dredging, please visit: www.havendredging.com.