A carbon line that arrives on the invoice

Container ships calling at EU ports have been inside the EU emissions trading system since January 2024. The rule is phased: 40% of reported emissions were covered for 2024, 70% for 2025, and 100% from 2026. The regulation is the same for every carrier. The surcharge that carriers add to your invoice is not.

I collected the published emissions surcharges for the Asia to North Europe trade from five carriers, as listed in their tariffs in November. They range from 38 to 71 dollars per 40-foot box.

Why the range is so wide

A surcharge has to estimate three things: how much fuel a box represents, what share of the voyage is covered, and the price of an allowance. Each carrier makes those estimates differently.

The share covered is the least ambiguous. For voyages that begin or end outside the EU, half of the emissions count. For voyages between two EU ports, all of them do. A box from Shanghai to Rotterdam is therefore half covered, and a feeder leg from Rotterdam to Gdansk is fully covered.

Allowance prices moved between roughly 62 and 78 euros a tonne over the past quarter. A surcharge fixed in September on the basis of 78 will overcharge if the price falls to 62, until the carrier recalculates. Most recalculate monthly, a few quarterly.

The allocation of fuel to a box is the part I can check least. Two carriers state the method in their tariff: an average of vessel emissions on the service, divided by the boxes carried. Three give a figure and a footnote.

What a shipper can do

First, ask whether your surcharge is calculated per service or as a trade average. A per-service figure can be lower for your box if you sail on a newer ship. Second, ask when it was last reset, and what allowance price was used. Third, if you move boxes between EU ports on a feeder, check that the surcharge on the feeder leg is not applied to the whole journey. I have seen both done.

None of this is a claim that anyone is overcharging. A surcharge based on an estimate will sometimes be above and sometimes below the real cost, and the regulation does not tell carriers how to estimate. It does mean the line on your invoice is a negotiated number in a regulated costume, and a question about it is a fair one.