Sea and air
50% or 100%: how the EU ETS scope rule changes your invoice
Published: 2026-09-20
Written by Vytautas Natys, founder of UAB NVGroup.
In the EU Emissions Trading System for shipping, there's one rule worth knowing by heart, because half the surcharge hinges on it.
Four cases
Scope is set by the ports at the start and end of the voyage.
When both ports are in the European Economic Area, 100% of the voyage's emissions fall within the system. When one port is in the EEA and the other isn't — regardless of direction — 50% falls within it. When neither port is in the EEA, the voyage isn't within the system at all. Time at berth in an EEA port is charged separately, at 100%.
The rule is symmetrical: exports from Europe and imports into Europe are treated the same way.
Where errors happen
The first source is transshipment voyages. A container travelling from Shanghai via Algeciras to Klaipeda is legally two voyages: one non-EEA–EEA (50%) and one EEA–EEA (100%). If the carrier's system treats this as a single voyage, the result can be either too high or too low.
The second source is ports whose classification isn't obvious. The European Economic Area isn't the same as the European Union — it also includes Norway and Iceland. Outermost regions have separate provisions. A port that intuitively looks European isn't necessarily an EEA port for ETS purposes.
The third is a plain systemic error, where the same scope is applied to an entire route regardless of the actual voyage.
What you need to check it
Three things.
A B/L with port codes. The loading and discharge ports with UN/LOCODE. A name isn't enough — the same name can belong to several ports.
An invoice line with the scope stated. If the carrier doesn't state it, you need to ask.
Vessel data. The system applies from 5,000 gross tonnage. Smaller ships aren't within it at all, and the surcharge shouldn't be applied to them.
What you can't calculate yourself
If the carrier states the scope, the comparison is straightforward. If it doesn't, reconstructing the basis from a single amount is impossible — that would require knowing both the carrier's rate for that period and the scope applied.
So the practical first step isn't calculation — it's a request: ask the carrier to state the ETS scope applied on invoices. It costs nothing and makes the whole line checkable.