The EU Emissions Trading System (EU ETS) is the EU’s cap-and-trade scheme for reducing greenhouse gas emissions. It sets a limit on emissions and obliges companies to surrender EU Allowances (EUAs) to meet compliance obligations.

Ships over 5,000 GT operating in EU waters must monitor, report, and surrender allowances. Ships over 400 GT must monitor and report, with surrendering obligations to be reviewed in 2026.

The shipowner holds the obligation unless the ISM DOC holder has agreed in writing to take it on.

A Maritime Operator Holding Account (MOHA) is required for compliance. A Trading Account is optional and has the same functionality as the MOHA, with the exception of being able to surrender allowances. Everybody can open a Trading Account, whereas a MOHA can only be opened by companies with a surrender obligation to an EU member state.

Yes — Grey Epoch can arrange transactions and deliver allowances directly to a third party or to your account once it is open.

Yes — EUAs can be transferred to other accounts, including those of your clients and counterparties.

A port of call is the port where a ship stops to load or unload cargo, to embark or disembark passengers, or where an offshore ship stops to relieve the crew. Exclusions exists for refuelling and drydock, amongst other things. 

Operators failing to surrender sufficient allowances face a penalty of €100 per tonne of CO₂ emissions not covered, plus liability to purchase the missing allowances retrospectively. Repeat violations may result in vessel detainment or restrictions on port entry.

Emissions must be allocated to the period in which they occur. Operators should track fuel use daily or per voyage segment to ensure accurate reporting for each reporting period.

The EU has expressed its intention to avoid double-charging for the same emissions. No guidance has been set out but EU ETS costs might act as a minimum price, with possible adjustments or discounts if IMO measures apply. More clarity to be expected during the EU ETS 2026 review.