Why ETS surcharges aren't uniform, and what that means at the negotiating table

Two carriers, the same route, the same container type, the same month — and two different ETS surcharges. That's not an error, and it's worth understanding before you start a dispute over it.

There's no standard

The scope rule is set in law, but the surcharge calculation isn't. There's no single industry standard for how a carrier is supposed to allocate its ETS costs to containers.

Every carrier uses its own methodology. The inputs — vessel efficiency, voyage load factor, fuel type, the accounting period, the projected allowance price — usually aren't public. Rates are revised quarterly.

That means the difference between two carriers' surcharges can come from a real cost difference, or from a different margin, or both.

What analyses show

In an early-2026 analysis of the Asia–Northern Europe route, one large carrier's published surcharge reached around 59 € per TEU, while the modelled real cost was around 45 € per TEU. A gap of about 14 € per TEU.

At the level of a single voyage, such gaps have been estimated from a few thousand to tens of thousands of euros depending on the carrier, and in one case on a China–Germany route the gap reached around 325,000 €.

The overall picture: in 2025, container shipping's ETS bill exceeded 1.4 billion USD, and 2026 is forecast at around 2.7 billion.

Why this can't be disputed

The surcharge isn't a wrongly calculated invoice. It's a price the carrier published and that you agreed to pay by signing the contract or accepting the quote.

There's no contractual basis to demand a refund. A claim on the grounds that the surcharge is higher than modelled costs wouldn't have any prospects.

It's worth understanding this, because otherwise it's easy to lose time on a dispute that can't end in a result.

Where it's actually useful

Negotiations.

When you go to negotiate next year's contract, the difference between asking "why is your surcharge high" and stating "according to our data, your surcharge on this route exceeded the modelled cost level by X euros per TEU over the year" is fundamental. The first is an opinion, the second is a position.

In practice, this means it's worth tracking ETS surcharges as a separate line by route and carrier, rather than letting them drown in the total freight amount. By year-end, that becomes a comparison table.

Verification is technically possible

Independent recalculation is possible: voyage emissions can be modelled from vessel-tracking data, the allowance price is public, and the scope rule is set in law. Several providers already offer this kind of service, and large shippers are starting to check invoice after invoice.

But the outcome always stays the same: it's a benchmark for negotiation, not a basis for a claim.

Emissions surcharge check