Piraeus: Greek shipping companies have been the first to face penalty notices under the FuelEU Maritime Regulation, after the national maritime administration confirmed that twelve vessels had exceeded the greenhouse gas intensity limits applicable to commercial shipping calling at Union ports. The fines, totalling four point seven million euros, are the first concrete enforcement action under the regulation that entered application at the start of 2025.
Regulation (EU) 2023/1805 sets a declining greenhouse gas intensity trajectory for the energy used on board ships above five thousand gross tonnage operating in Union waters. The baseline value of the regulation translates roughly to the well-to-wake greenhouse gas intensity of conventional very low sulphur fuel oil. From 2025 onwards, the limit decreases by two percent, with progressively steeper reductions in 2030, 2035 and 2040, reaching an eighty percent reduction by mid-century.
Compliance is calculated on a vessel-by-vessel basis but offset rights are extensive. Pooling between ships under the same managing company is permitted, as are temporary borrowing arrangements that allow a vessel to defer compliance to the following reporting year at the cost of a corrective multiplier. The fundamental design choice of the regulation was to leave technology selection to the market while imposing an outcome obligation, a logic that places significant analytical demands on operators.
The Greek cases reveal the operational reality of compliance. None of the twelve vessels concerned had taken advantage of the pooling or borrowing arrangements, an oversight that magnified the size of the penalty. The fines are calculated according to a formula in the regulation that multiplies the compliance gap by a unit cost of two thousand four hundred euros per ton of very low sulphur fuel oil equivalent. Three of the twelve cases are reported to be under administrative appeal.
The trajectory of the regulation is the more important policy story. The 2030 reduction target represents a six percent decrease against the baseline. The 2035 target represents a thirty-one percent decrease. From that point onwards, the trajectory steepens significantly, and compliance through conventional marine fuels will become impossible. Alternative fuels with credible production pathways at scale include liquefied biomethane, e-methanol, ammonia and, in a narrower set of applications, hydrogen. Each has different infrastructure, safety and economic implications.
The bunkering infrastructure landscape has begun to respond. Several Union port authorities have published alternative fuel readiness plans, with Rotterdam, Hamburg, Algeciras and indeed this city among the more advanced. The interaction between FuelEU Maritime and the Alternative Fuels Infrastructure Regulation, which sets out port-side fuelling availability obligations, will determine whether the supply side keeps pace with the demand the regulation creates.
Two areas of regulatory clarification are awaited. The first concerns the methodology for measuring the well-to-wake emissions of biofuels, particularly those produced from waste and residue feedstocks. The default values in the regulation are conservative, and disputes have arisen over the eligibility of specific feedstocks for the low-default emission rating. The second concerns the rendezvous fueling exemption, which applies to vessels that fuel at non-Union ports under specific conditions.
For the European Maritime Safety Agency, which supports national administrations on FuelEU Maritime, the Greek cases are a useful test of the enforcement architecture. The bigger test comes in 2030, when compliance moves from administrative novelty to operational reality.
