Sea and air — add-on
Emissions surcharge check: ETS, FuelEU, and the one line that cannot be checked
From 2026, shipping is fully within the scope of the EU Emissions Trading System, and FuelEU Maritime adds a second, independent layer. More and more carriers merge the two into a single surcharge line — and at that point nothing can be checked at all. Our first job is to notice that.
What we check and what we don't
We check whether the EU ETS and FuelEU scope rule (50% or 100%) was applied correctly based on the loading and discharge port codes — that is an invoice error with a legal basis, not a commercial decision by the carrier. The scope is identical for both regulations, so it is the same check.
We don't check whether the size of the surcharge is right — the carrier sets its own commercial surcharge, and a surcharge above cost isn't, by itself, an error. The benchmark report shows the surcharge next to published reference levels — not next to a modelled carrier cost, which we do not have. See below for what that means.
A composite voyage through a transshipment port is legally two voyages with different scope. At the moment we only automatically recognize direct voyages — if your shipment moved through a transshipment port, state the ports of the final leg or contact us for a manual check.
We do not check FuelEU tariff conformance: none of the carriers we checked publishes a FuelEU tariff separately, and a check with no comparison basis would be an empty promise.
We don't file a claim with the carrier on your behalf. We detect, calculate, and prepare the basis — you file the claim under your own contract with the carrier.
Two regulations, not one
EU ETS and FuelEU Maritime are not two versions of the same thing. They work independently and they stack.
EU ETS taxes the quantity of emissions. The carrier buys allowances per tonne and can simply pay.
FuelEU regulates the intensity of the energy used on board, well to wake. Paying and sailing on is not an option: every vessel has an annual intensity target, and a deficit has to be closed by banking, borrowing, pooling or cleaner fuel. The penalty — €2,400 per tonne of VLSFO equivalent — is set so that it is the worst of the options.
The geographic scope of the two is identical: 50 % of the voyage leg into or out of the EEA, 100 % at berth in an EEA port. That is why the same check works for both.
From July 2026 a third layer is added — the UK Emissions Trading Scheme. Its scope is different: it covers domestic UK voyages and time spent in UK ports, but not an international voyage as a voyage. So we do not apply the EU rule to a UK line — doing so would produce a wrong answer, not an unknown one.
A blended line
If the invoice shows a single emissions surcharge with no breakdown, the scope rule cannot be checked at all — it is not known which part belongs to which regulation, and their cost logic differs.
We do not split it ourselves. The ratio depends on the carrier's compliance strategy — whether it bought allowances, joined a pool, or used alternative fuel — and a guess would produce a result that looks well-founded but is not. Relying on such a number in a dispute is worse than having none.
Instead we flag the line and prepare a split request for the carrier. It costs nothing and it restores verifiability for the whole line.
The name alone is not enough
We checked real carrier tariffs: Maersk Emissions Surcharge (EMS/ESS) covers both regulations, Hapag-Lloyd merges them too, while ONE Europe Environment Surcharge (EES) covers ETS only.
The same generic words mean different things at different carriers. So we classify by the tariff content the carrier has published, not by the name of the line. When we do not yet have the carrier's code, the line is marked unclear, not merged — we don't know whether it is merged is not the same as it is merged, and it is a different question for the carrier.
How the scope rule works
The EU Emissions Trading System applies to shipping for ships of 5,000 gross tonnage and above. Scope depends on the nature of the voyage:
- A voyage between two EEA ports — 100% of emissions
- A voyage from an EEA port to a non-EEA port — 50%
- A voyage from a non-EEA port to an EEA port — 50%
- Time at berth in an EEA port — 100%
The rule is set in law and doesn't depend on the carrier. If the surcharge for a voyage from Asia to Northern Europe is calculated on a 100% basis, the overpayment is exactly half the surcharge — and it repeats for every container on the same route.
How it works
01You enter the ETS surcharge data
The loading and discharge port codes (UN/LOCODE) and the scope applied on the invoice — usually by hand, since this information is rarely on the invoice document itself.
02We determine the applicable scope
Based on the port codes and the EU ETS rule. If either port's classification is unclear (e.g. an outermost region with voyage-type exceptions), we don't generate a finding.
03We compare it with what was charged
If you stated the scope applied on the invoice, you get an exact calculation with the overpaid amount. If you didn't, we don't generate a finding — you need to ask the carrier.
What it means in money
This is an illustrative calculation based on publicly published surcharge levels, not verified statistics. Only a check shows how many such errors are in your own invoices.
Benchmark report
Separately from the scope-error check, we show how much surcharge you paid by route and carrier, next to published reference levels.
For FuelEU there are two such levels, and they differ by tens of times. The penalty is €2,400 per tonne of VLSFO equivalent — but that is a deterrent set in law, not a market price. The pooling price index stood at roughly €105 per tonne of CO₂ equivalent in July 2026. If a carrier prices off the penalty while actually closing its deficit in a pool, the gap between the two bases is twentyfold.
In the first compliance cycle the great majority of shipowners joined pools — the penalty is rare in practice.
What this comparison does not do
It does not calculate the carrier's cost. That would need per-voyage fuel consumption data, which we do not have — and a number that looks like a modelled cost while actually being a guess is worse than no number at all.
For ETS the limit is even clearer: the allowance price is quoted per tonne of CO₂, the surcharge per container. Without the voyage emissions attributable to that specific container the two cannot be compared directly. The price is shown as context, not as what it should have cost.
With no reference-level entry for that month we make no comparison — we do not take the neighbouring month's value, because the index moves far too much for that to be an approximation.
And most importantly: the gap between a published surcharge and a reference level is never an invoice error. A carrier is not obliged to tie its surcharge to its costs. It is material for negotiating next year's contract, not for a claim.
Pricing
Ongoing monitoring €49/mo
An add-on to any Cargo plan with the Sea and air module selected. We check new ETS, FuelEU and UK ETS surcharge lines as you enter them. The price does not change — this is the same add-on with a wider scope. Selected as a checkbox on the pricing order form, activated immediately.
Historic review 25%
A three-year invoice review for scope errors — part of the Freight invoice audit module, the same gain-share terms (capped at €5,000/case, minimum €100). For German clients, the success-fee option isn't available — a fixed price applies instead.
Prices exclude VAT. Clients from other EU member states with a valid VAT number are charged under the reverse-charge mechanism.
Frequently asked questions
Is this the same as the carrier's ETS report?
No. The carrier reports how much surcharge you paid. It does not check whether the scope was applied correctly — auditing your own invoice isn't possible.
What if the carrier doesn't state the scope on the invoice?
Then we can't run the scope check and no finding is generated. The line stays unverified — you need to ask the carrier to state the ETS basis applied to that specific voyage.
Are ETS and FuelEU together on one invoice double taxation?
No. The regulations are independent and cumulative: one taxes the quantity of emissions, the other regulates energy intensity. Having both on an invoice is lawful. From July 2026 a third may join them — UK ETS, on UK routes.
Why don't you split a blended surcharge yourselves?
The ratio depends on the carrier's compliance strategy — whether it bought allowances, joined a pool, used cleaner fuel. The invoice does not show that, and a guess would give a wrong scope-check result that looked well-founded. Instead we prepare a split request for the carrier.
Do you check the FuelEU surcharge tariff?
No. None of the carriers we checked publishes a FuelEU tariff separately — it is buried in the combined emissions surcharge. A check with no comparison basis would be an empty promise, so we do not make one. We check the scope rule, which is set in law.
Do you apply the same 50/100 rule to the UK ETS surcharge?
No, and that matters. Since 2026-07-01 UK ETS covers domestic UK voyages (100%), GB–Northern Ireland voyages (50%) and emissions at berth in UK ports — but not an international voyage as a voyage. Applying the EU rule to it would produce a wrong answer, not merely an unknown one. If a UK surcharge appears on an international voyage, we flag it as a question for the carrier, not as an overcharge.
Does the check work for voyages through a transshipment port?
Not automatically at the moment. A composite voyage through a transshipment port is legally two voyages with different scope, and our document extraction doesn't yet split them out. State the ports of the final direct leg, or contact us for a manual check.
How long are uploaded documents kept?
Original documents are kept for 24 months from upload, customs documents for 40 months. After the period expires the original file is deleted automatically, the data extracted from it remains. If you want a specific document removed earlier (GDPR Art. 17 right to erasure), contact us by email.
Requires the Sea and air module.
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