01

What is changing or failing?

FuelEU Maritime has applied fully since 1 January 2025 for covered ships calling at European ports, using annual average greenhouse-gas intensity and allowing mechanisms including pooling. At global level, the IMO approved a draft Net-Zero Framework in April 2025, but adoption talks were adjourned in October 2025 and are due to resume in 2026.

FuelEU measures the yearly average well-to-wake GHG intensity of energy used on board; the covered company reports and an accredited verifier determines the ship’s compliance balance. A bunker delivery note or pathway certificate is therefore an input to a ship-level annual calculation—not, by itself, proof of the buyer’s final compliance result.

The failure is to collapse different regimes, accounting levels and timelines into one claim that a fuel is simply compliant. Actual value depends on vessel, route, reporting method, chain of evidence and the buyer’s chosen compliance strategy.

02

Why does it matter commercially?

A product with usable emissions evidence may create more value than a nominally lower-carbon offer that cannot be verified or fitted into the buyer’s compliance position. Conversely, paying a premium without a defined accounting route can destroy the expected benefit.

For suppliers, the WIIFM is a stronger acceptance case: disclose what the evidence supports, which regime it addresses and where uncertainty remains.

03

What must management decide?

The buyer must decide which compliance outcome the purchase supports and what evidence must be accepted before the premium or commitment is justified.

The supplier must decide which claims it can stand behind without presenting pending IMO measures or pathway assumptions as settled requirements.

Price the evidence outcome, not the label

Compare offers under three cases: the evidence is accepted as represented, accepted with a more conservative factor or rejected for the intended accounting treatment. The commercial premium is defensible only if the contract allocates methodology, verification and replacement-value risk across those cases.

04

What evidence is required?

  • Vessel, voyage and regulatory scope
  • Fuel pathway, lifecycle method and supporting certificates
  • Verifier and reporting-system acceptance requirements
  • Allocation of non-compliance, methodology and data risk
  • Value of banking, borrowing or pooling options to the buyer
  • Retention of assumptions, references, emission factors and bunker-delivery evidence for verification
  • Remedy if the certified pathway, allocation or verifier treatment differs from the representation

05

What should happen next?

  1. Define the buyer’s compliance objective before comparing offers.
  2. Request the evidence package and methodology with the commercial terms.
  3. Model the offer under accepted, conditional and rejected-evidence scenarios.
  4. Contract the claim, evidence owner and remedy explicitly.