Captain Alex Byelyavtsev has identified six structural problems with FuelEU Maritime, the European regulation that took effect on 1 January 2025 and is designed to steer shipping toward renewable and low-carbon energy as part of the EU's Fit for 55 plan — the bloc's legislative package targeting net greenhouse gas emission reductions of at least 55% by 2030 compared to 1990 levels.

The mechanism appears straightforward in principle: each year, the greenhouse gas intensity of energy used on board ships must decline. Non-compliance triggers a penalty, while an accepted balance earns the vessel a Document of Compliance. However, the regulation's first year of operation has exposed significant gaps between the rule's design and its real-world outcomes.

Problem One: Pooling Masks Individual Performance

Under Article 21 of the regulation, ships may pool their compliance balances so that the pool meets the greenhouse gas intensity limit on average. This flexibility is explicitly written into the rule, meaning a ship can appear compliant through collective accounting rather than through changes to its own fuel. Under Regulation (EU) 2023/1805, a FuelEU Document of Compliance confirms that a ship met the regulation for a given reporting period, which may include pooling. It does not demonstrate that the vessel reduced its voyage emissions or switched fuels at scale. Compliance is an accounting result; emission reduction is a physical result. Early FuelEU practice has blurred the distinction between the two.

Problem Two: Clean Marine Fuel Is Not Available at Scale

Clean marine energy is not yet ready for fleet-wide deployment. Drop-in biofuels — fuels that can substitute for conventional bunker fuel without engine modifications — remain limited and contested. Methanol and ammonia benefit only ships equipped to burn them. Most of the global fleet still relies on conventional bunkers. Nevertheless, the regulatory year can still conclude with a green balance. The European Commission's own impact assessment pathways envisioned renewable and low-carbon fuels supplying 6% to 9% of the international maritime fuel mix by 2030, and 86% to 88% by 2050. Those figures represent model projections, not current supply. The supply gap is not unique to Europe: the International Maritime Organization's revised GHG Strategy, adopted in July 2023, targets net-zero emissions from international shipping by or around 2050, but the global fuel production trajectory to meet that goal remains uncertain.

Problem Three: Obligations Fall on Users, Not Producers

The regulation places compliance responsibility on the company operating the ship — the fuel consumer — rather than imposing an equivalent obligation on fuel producers to manufacture cleaner fuels at scale. An ICS and ECSA study cautioned that assigning the primary fuel-standard duty to ships instead of suppliers creates enforcement and supply problems. The law can mandate a cleaner fuel that does not yet exist in the required volumes.

Problem Four: Targets Are Dated but Not Necessarily Deliverable

Article 4 sets the greenhouse gas intensity reduction at 2% from 2025, 6% from 2030, escalating sharply toward 80% by 2050. The timeline is clear. For many vessels, however, the physical pathway to compliance is not. The targets are achievable in principle if the fuels materialize, ships are replaced, and funding holds. Someday possible is not the same as achievable now.

Problem Five: Capital Constraints

Genuine transition requires substantial capital for new vessels and scarce fuels. UNCTAD's Review of Maritime Transport 2025 reported the global containership fleet at approximately 30.3 million TEU by April 2025, an increase of roughly 10% year-on-year following heavy ordering and elevated deliveries. Additional capacity means more competition, which compresses the surplus available to fund the next phase of transition.

Problem Six: Responsibility Is Misallocated

FuelEU attaches the legal duty to the ship because the vessel consumes the energy. Research on port congestion indicates that ships frequently sail at high speeds and then wait at anchor for a berth, with average potential emissions savings of about 10% for containerships if waiting time were converted to slower sailing. An IMO-backed Just in Time study found average fuel savings of approximately 14% per containership voyage when speed is matched to berth availability. Despite these operational dynamics, FuelEU continues to place the legal obligation on the vessel.

A System That Certifies Without Delivering

Shipping accounts for approximately 3% to 4% of EU CO₂ emissions on Commission figures. The sector already faces the Emissions Trading System (ETS) for shipping — which entered force in January 2024 and is phasing in its coverage of maritime CO₂ emissions over three years — in addition to FuelEU Maritime. The political attention is disproportionate to that share, and so is the early paperwork success. The actual shift in fuels remains modest.

The core issue with FuelEU is not that shipping was asked to reduce emissions. It is the sequence of the rule. The EU established a mandatory transition for fuel users without matching it to a binding production duty at equivalent scale. It introduced early flexibility mechanisms that keep ships legally compliant. It treated the compliance balance as the visible achievement. The fuels, the fleet renewal, and the funded pathway for real emission reductions are not yet in place at scale. The first year of FuelEU made one gap unmistakably clear: a system can certify compliance without delivering transition.