There has been some confusion in the superyacht industry over the application of the EU Monitoring Reporting and Verification (MRV) and the Emissions Trading System (ETS).
The response I received from the Commision is that it applies to yachts, provided they are 5000 GT and above, and are transporting passengers for commercial purposes (charter) and performing voyages under the scope of the regulation.
The relevant Article is 21(1) of EU 2015/757.
Clearly the charter fleet at this size is very small, nevertheless they will start building up liabilities from 2024.
By 31 March each year from 2025, a verified company emission report needs to be submitted to the administering authority, and by 30 September (indicated, subject to confirmation) each year the necessary emission allowances are required to be surrendered to the administering authority – there are free no allowances.
The following timeline from DNV highlights the reporting periods and when allowances must be surrendered.
Current EU Carbon price is around €64 t/CO2 but has been over €100 t/CO2 so this could add between €205.00 – €320.00 per ton of diesel fuel.
Interestingly the “unit of work” for passenger ships is “passenger-nautical Miles” – not a very favourable unit for yachts!
By 31st December 2024 the Commission will assess whether other additional ship types between 400GT – <5000GT should be included in the MRV.
With the precedent set for very large commercial yachts, we will have to see how that informs the decision for commercial yachts between 400GT – <5000GT in the future?
The image below shows the current situation before the upcoming reviews.
With the precedent set for very large commercial yachts, we will have to see how that informs the decision for commercial yachts between 400GT – <5000GT in the future?
FAQS on the EU ETS can be found here: – Maritime transport in EU Emissions Trading System (ETS)
