Sea and air
ETS surcharge in ocean freight: what it's made of and what can be checked
Published: 2026-09-20
Written by Vytautas Natys, founder of UAB NVGroup.
Since January 2024, shipping has been included in the EU Emissions Trading System. The phase-in was gradual: in 2024 carriers had to cover 40% of their emissions, in 2025 — 70%, and from 2026 the full 100% scope applies. From 2026, the system covers not just carbon dioxide but also methane and nitrous oxide.
Carriers pass the cost on to the client as a separate invoice line. Its size has grown substantially over two years: if in 2024 the surcharge was around 1% of the base freight, by early 2026 on the Asia–Northern Europe route it reached about 6–7%, averaging around 168 USD per 40ft dry container.
What in the surcharge is actually checkable
The surcharge consists of two things, and it's worth separating them, because only one of them is checkable.
The scope rule is set in law. How much of the emissions falls within the system isn't the carrier's call. A voyage between two EEA ports carries a 100% scope. A voyage from an EEA port to a non-EEA port, or the other way round — 50%. Time at berth in an EEA port — 100%. The system applies to ships of 5,000 gross tonnage and above.
If a surcharge is calculated on a 100% basis for a voyage that only carries 50%, that's an invoice error with a legal basis.
The size of the surcharge is a commercial decision. There's no single industry standard for how the surcharge is calculated. Every carrier uses its own methodology, its inputs aren't public, and rates are revised quarterly.
That means the question "is the surcharge right" has no single answer. The question "was the scope applied correctly" does.
How much a scope error costs
On a 168 USD surcharge for a 40ft container, a wrongly applied 100% instead of 50% means roughly an 84 USD overpayment per container.
What matters is that this kind of error isn't random. If the carrier's system misclassifies the route, the error repeats for every container on that same route for the entire period. For a flow of a thousand containers, that's roughly 84,000 USD a year.
This is an illustrative calculation based on publicly published surcharge levels, not verified statistics.
What's often missing from the invoice
The biggest practical obstacle is simple: many carriers don't state on the invoice which scope was applied. You see the amount, but not the basis.
In that case, checking is impossible — you need to ask the carrier to state the scope applied for that specific B/L. That's a legitimate request, and it's worth making standard practice, because without it the surcharge stays fundamentally unverifiable.
What isn't ETS
Invoices also carry other decarbonization surcharges — FuelEU Maritime, for example. That's a separate regulation with its own rules and its own calculation. Having two environmental surcharges on an invoice isn't, by itself, duplication.
Duplication only means the same ETS surcharge charged twice for the same B/L.