Who owns shipping’s carbon decisions?

In an industry where a position list is a competitive weapon, the question is no longer just how to comply—but where carbon decisions are made and who controls the data behind them, said Argyris Zafeiropoulos, principal advisor at Resilience & Compliance Advisory.

With the EU Emissions Trading System fully phased into shipping and FuelEU Maritime tightening year by year, carbon is now a line item in every fixture. On a single laden Aframax voyage from the Gulf to Rotterdam, the FuelEU penalty alone climbs to about €246,000 ($276,000) by 2040 — same ship, same route, same fuel.

Who pays is a matter of contract. The EU places the obligation on the company holding the ship’s Document of Compliance, and the emissions clauses now in wide use pass it on: under a time charter the charterer typically reimburses it, under a voyage charter the owner prices it into the freight, and a commercial operator carries it on every voyage it fixes.

Far less attention goes to a quieter question: where are these carbon decisions actually made, and who can see the data behind them?

The reflex of the past decade has been a subscription: upload fleet, fixture and consumption data to a cloud platform and receive a number back. It is convenient. Made by default, it is also a remarkable concession. Position lists, fixture pipelines and consumption curves are competitive assets, and routing them through third-party infrastructure surrenders control at a cost that never appears on an invoice.

There is a second cost. Many platforms work as black boxes: they deliver an ETS exposure or a FuelEU penalty, but the methodology stays behind the vendor’s walls. Even scope is a judgement, not a given — whether a Norwegian ore port counts as inside the system, or a transhipment call counts as a port of call at all, can move a leg from 50% to 100% of its emissions. When a broker challenges a break-even, a counterparty disputes an allocation or an auditor asks for justification, “the system said so” is not an answer. In a market where carbon is negotiated line by line, an unauditable calculation is a liability.

The alternative rests on three principles. Data should stay under the company’s control by default; what leaves the organisation, and why, should be a conscious choice. Models should be traceable to their sources and anchored in Regulation (EU) 2023/1805 and the IMO framework, not in a formula only the vendor can see. And whoever owns the model owns the decision — which is where the commercial value lies.

The real shift is from reporting to deciding. A charterer comparing two similar vessels on the same route may find that the cheaper fixture becomes the more expensive one once ETS and FuelEU are weighed. Discovered after the fixture is concluded, that is a compliance calculation. Understood before it is signed, it is a commercial decision.

And deciding means years, not single voyages. On that Aframax, burning conventional very low-sulphur fuel oil, the FuelEU penalty is roughly €19,000 ($21,300) at today’s target, €50,000 ($56,100) at the 2030 target and €246,000 ($276,000) by 2040. A period charter or contract of affreightment signed today is signed across those steps — and the IMO’s draft Net-Zero Framework, due back at MEPC85 in December, could put a global price alongside them.

The arithmetic reaches the cargo too. On that voyage, ETS and FuelEU together come to about €104,000 ($116,600) at an €81 ($91) allowance price — roughly one euro ($1.12) on every tonne of a 100,000-tonne cargo, rising to about €1.36 ($1.53) by 2030. In commodity trades, the choice between CIF and FOB helps decide who absorbs it. Carbon has moved beyond the charter party and into the commodity contract.

Third-party platforms are not the problem. Surrendering decision authority to them is. Software is the vehicle, not the authority, and the company that can explain and defend its own numbers stands on firmer ground. Shipping has always rewarded those who control their critical assets — ships, cargo relationships, market intelligence and commercial judgement. As carbon becomes embedded in every voyage, another joins the list: the ability to understand, challenge and defend the carbon number before it becomes a commercial commitment.

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