The European Commission’s pledge to prevent shipping companies from being charged twice for the same emissions is a welcome step, but the industry now needs clear guidance on how this will work in practice, according to integrated emissions management service EmissionLink. 

Although the principle of avoiding double charging is clear, the practical reality is far more complicated. Shipping is already operating within an increasingly crowded regulatory landscape, with EU ETS and FuelEU Maritime now in force, while the International Maritime Organisation (IMO) moves towards its own global Net-Zero Framework. 

Each system, however, has a different scope, timeline, calculation method and commercial logic. As a result, EmissionLink warned that, without detailed guidance, avoiding duplicate carbon costs will not be straightforward. 

A vessel trading into Europe may be exposed to EU ETS, FuelEU Maritime and future IMO carbon rules. At the same time, the obligations will not always sit with the same party, emissions data may not always be calculated in the same way, and costs may not be recoverable under existing charterparty terms. 

For shipowners, the risk is therefore not limited to paying twice for the same emissions. It also includes reporting twice, calculating twice and building parallel compliance processes, increasing cost, complexity and confusion. 

Philippos Ioulianou, Managing Director of EmissionLink, said the industry now needs to understand “how EU and IMO obligations will be reconciled, how equivalent payments will be recognised, and what evidence shipowners will need to prove that the same tonne of emissions has not been penalised more than once”. 

He added that this will determine whether carbon regulation is viewed as “a fair transition tool or simply another cost burden”. 

At the same time, EmissionLink said accurate and auditable emissions data will become more important than ever. Yet data alone will not be enough, as owners and operators will also need the expertise to interpret that data across different regulatory schemes and make informed commercial decisions. 

The company has already supported the delivery of accurate FuelEU emissions data for more than 600 vessels, giving it first-hand insight into the complexity of compliance across different vessel types and operating profiles. 

Philippos Ioulianou, Managing Director of EmissionLink

Ioulianou said that “every vessel has a different operating profile, every voyage has a regulatory consequence, and every compliance decision can affect cost exposure, penalties, pooling options, charterparty recovery and future planning”. 

In this context, he said the challenge is no longer simply submitting the right figure into the right system. Instead, it is about understanding how current and future emissions schemes interact, how they affect the business, and how companies can avoid double penalties, duplicated processes and unnecessary costs. 

EmissionLink also stressed that carbon pricing will only retain credibility if revenues are clearly directed back into maritime decarbonisation. 

Speaking at a ShipEnergy forum during Posidonia, Ioulianou argued that EU member states must set out a clear pathway for the use of revenues generated through EU ETS and FuelEU-related mechanisms, saying that “these funds should be directed back into the maritime sector” and “should not become a general revenue stream for governments”. 

He added that asking shipping to pay more while failing to invest in the infrastructure needed to make decarbonisation possible is “not a transition strategy”, but “taxation with a green label”. 

Therefore, while the European Commission is right to recognise the risk of duplicate carbon costs, EmissionLink said the industry now needs practical, transparent and enforceable rules that support compliance while helping shipping move towards lower-carbon operations. 

Ioulianou said that “shipping cannot decarbonise on promises alone”, adding that the sector needs clarity, consistency and confidence that regulation will support the transition rather than simply adding cost and complexity.