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EU ETS surcharge explorer

Explore how EU ETS surcharges vary across carriers and trade lanes, how it compares with Lune’s own estimates, and get the answers to your EU ETS questions below. Carrier surcharge data from CMA CGM, COSCO, Evergreen, Hapag-Lloyd, MSC, ONE. Last updated March 2024.

Asia to Mediterranean, 1 TEU


Carrier surcharge

Lune estimate






124 %

CGA CGM Galapagos

CGA CGM Galapagos



196 %

COSCO Nebula

COSCO Nebula



213 %

The EVER Top is in service between East Asia and the Mediterranean, via The Cape due to the Red Sea crisis.

Our estimate includes 50% of CO₂ emissions produced between Singapore and Piraeus, plus 100% emissions between Piraeus and Genoa, as required by ETS.

The takeaway

Carriers overcharge 2–3×: every carrier charges more than the EU ETS surcharge should be, according to Lune’s estimates.

Charging €5–20 extra per TEU seems marginal, especially considering the total cost of the shipment. However, it adds up!

For example:

  • COSCO Hope @ 13,000 TEU capacity: €440,700 profit
  • CMA CGA Galapagos @15,000 TEU capacity: €147,300 profit
  • MSC Fiammetta @ 5,760 TEU capacity: €58,060 profit
Note: these are the profits after paying the EU ETS surcharge estimated by Lune for each one-way voyage!

This may not be fully profiteering, but the carriers may also be adding a buffer to account for administrative work, EUA price fluctuations (which can be high), or simply applying a different calculation method (e.g. charging for 100% of emissions instead of the 40% required by the EU ETS).

The EU ETS (EU Emissions Trading System) is not a new scheme. The 'cap and trade' system was set up in 2005, with the goal to combat climate change by reducing greenhouse gas emissions (GHG). Before, the policy only covered electricity and heat generation, energy intensive sections such as oil refineries, steel works, and the production of iron, aluminum, glass etc. But as of January 2024, the EU ETS now includes maritime transport.

Companies affected by this policy must annually report on their emissions through the EU MRV (Monitoring, Reporting, and Verification) system, and “surrender/use“ purchased ETS allowances (EUAs) to cover these emissions.

Effectively, it’s a tax. The aim is to make producing emissions more expensive. Thus, incentivising rapid decarbonisation.
EUAs are a type of carbon allowance: companies affected by the EU ETS will be charged for the amount of CO₂e they emit. EUAs can be bought and sold on the market, and the variable market price of EUAs reflects the cost of reducing emissions.
Yes. The EU ETS regulation does not take into account voluntary carbon offsetting. Regardless of whether a company has chosen to voluntarily offset their emissions or not, they must still pay for enough EUAs to cover the cost of the emissions.
Yes, the EU ETS applies to maritime transport. Over time, the scope of shipments covered by the EU ETS will grow.

As of 2024, carriers will need to report on and pay the allowances to cover the CO₂ emissions for:
  • Cargo and passenger ships of or above 5000 gross tonnage (GT)
  • 100% of the emissions from intra-EU maritime voyages
  • 100% of emissions from ships at berth in EU ports
  • 50% of emissions from voyages which start or end at EU ports, where the other destination is outside of the EU
However, there are some exceptions. For example, it does not include port of calls further than 300 nautical miles from EU ports, or emissions resulting from the combustion of biofuels, or stops for obtaining supplies etc. For more information on specific rules and derogations, visit the EU Action hub.
Carriers are responsible for measuring and disclosing their overall emissions. They are also responsible for surrendering EUAs to cover the cost of these emissions.

Learn more.
Carriers have decided to pass on the cost of purchasing EUAs to shippers in the form of a ‘surcharge‘. These surcharges are not imposed by the EU.

It’s important to note that each ‘surcharge‘ is created by individual carriers. Meaning how they calculate the charge, or even the form a surcharge might take can vary from carrier to carrier. For example, some carriers may decide to cover the cost through carbon insetting, bio-fuel shipments, or other alternatives.
The EU ETS asks carriers to surrender one EUA for each tonne of CO₂e they emit, therefore you could calculate the fixed cost per shipment by:

CO₂ Emissions per TEU × EUAs price

However, the reality is not that simple.
  • Carriers collect surcharges before the shipment has taken place, when the shipment emissions aren’t known yet
  • EUA price fluctuates over time
  • Carriers bear admin costs for reporting emissions to the EU ETS
Given all these variables, carriers have decided to charge a flat rate per trade lane and container type (i.e. dry vs. reefer). Therefore it’s likely the final surcharge passed on to the shipper could be higher or lower than the actual cost of EUAs needed to cover the emissions produced by that single shipment.
Lune uses its emission calculation technology to provide estimates on the cost the carriers would incur for a given shipment under the EU ETS rules for 2024:
  • We calculate the emissions of each vessel for shipping 1 TEU on each route displayed above
  • We only consider 40% of CO₂ emissions, and ignore other GHG gases
  • We consider whether one or both ports are within the EEA (50% or 100% emissions considered)
  • We multiply the emissions by the 2023 EUA average price of € 80 / tCO₂e
As the scheme evolves, the total amount of maritime emissions that will need to be covered by EUAs will grow, thus increasing demand for these allowances. For example, as shown in the table below, 70% of emissions will need to be covered by EUAs in 2025, and in 2026 methane and nitrous oxide will also fall under the scope of the EU ETS.

The price of EUAs is expected to increase in the long-term, particularly as the EU reduces supply to reflect the greater cost of emitting. In economic terms, greater demand and smaller supply means higher prices. Unless fleets are rapidly decarbonised, shippers could expect surcharge prices to hike over the coming years.

Learn more about EUAs.
EUA Table
FAQ – Maritime transport in EU Emissions Trading System (ETS)

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