Photo: Smaller vessels should not be exempted. Photo: © m.afiqsyahmi /

Loopholes in EU shipping proposal criticised

The European Commission has proposed to include the shipping industry in the European Union’s Emissions Trading System (ETS). However, Transport and Environment and a number of other NGOs and industry representatives have criticised loopholes in the proposal. The criticism is presented in an open letter, in which the signatories “…urge the gross tonnage threshold for Monitoring, Reporting and Verification (MRV) Regulation, the Emissions Trading System (ETS) Directive and the FuelEU Maritime Regulation be brought down to 400 gross tonnage and that offshore and service vessels are included in these laws”.

The open letter highlights six points in support of its demands, namely:

1. Green tech is ready

2. Long-term investment decisions require predictability now

3. A level playing field means ending fossil fuel subsidies 

4. Companies already know their fuel consumption; the additional administrative burden is negligible

5. Ending loopholes is a no-brainer for industry, the climate and human health

6. Empower green European business 

In a concurrent report by Transport & Environment, entitled “Lost at sea: EU States ’ €20 billion giveaway to the shipping industry”, the positions of EU institutions (colegislators) are analysed. Concerning the tonnage limit, the analysis points out that the exclusion of smaller ships could delay or compromise decarbonisation, since there would be an incentive for ships to run on Liquified Natural Gas (LNG) and since small vessels are often used to test new (greener) technologies. The analysis also addresses other exemptions in the proposal. In monetary terms, the analysis that compared the positions of the institutions concludes that the Council’s proposal would amount to the said €20 million giveaway to the shipping sector.

Sources: Shippingwatch, “Businesses and NGOs urge stricter requirements for shipping in ETS”, 21 September 2022,

T&E report, “Lost at sea: EU States’ €20 billion giveaway to the shipping industry”, September 2022

T&E Joint letter, September 2022,


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