Amid all the justified excitement around Fuel EU Maritime, effective in just a few weeks time, and the reaction to BIMCO's freshly-minted Fuel EU clause for time charters, it is easy to forget that EU ETS continues to present challenges to owners, charterers and ship managers across the sector. The slow-burn nature of the cap-and-trade scheme's implementation sees steps for compliance spread over almost two years between launch on 1 January 2024 and the first EUAs being surrendered in September 2025. This, together with the apparent lack of any joined-up approach between Member States on the opening of all-important Maritime Operator Holding Accounts (MOHAs)  means many shipping companies are still struggling to set up the necessary processes. Add to this the myriad issues reported by experts on the correct measurement of emissions data (due for submission in March 2025) and it is plain that EU ETS is still a compliance headache for many almost a year after coming into force. Nor has there been much let up on the legal side, with shipping lawyers fielding regular questions on EU ETS charter clauses, the effect of ship sales on the parties' liabilities for EU ETS compliance, and the role and responsibility of bareboat charterers. All of these problems require tailored advice and individual solutions. 

The global supply chain, in which shipping dominates, has suffered numerous shocks in recent years, including the pandemic, a blockage of the Suez Canal and any number of geo-political disruptions. The physical and financial impact on the supply chain of EU ETS, and other maritime decarbonisation initiatives such as CII and Fuel EU Maritime, has yet to emerge but, for now, the industry can perhaps be forgiven for concentrating on the continuing challenge to comply.

To read more about supply chain opportunities and challenges, click here for our new series: From A2B: Decoding the global supply chain.