FuelEU + EU ETS compliance costs for CMA CGM, Hapag-Lloyd and COSCO

  • This case study calculates and compares EU ETS and FuelEU compliance costs for three major shipping companies: CMA CGM, Hapag-Lloyd and COSCO. From 2025 until 2050, these three companies will pay a total compliance cost of:

    CMA CGM > $16.7 billion EU ETS and $37.0 billion FuelEU penalties

    Hapag-Lloyd > $8.0 billion EU ETS and $17.0 billion FuelEU penalties

    COSCO > $9.7 billion EU ETS and $21.9 billion FuelEU penalties

    The normalized compliance costs per mT of fuel from 2025 until 20250 are almost $300 per mT for CMA CGM and Hapag-Lloyd, and $200 for COSCO. Of greatest impact is the amount of time spent sailing in EU waters. Normalized compliance costs over this period can rise to $1,000 per mT and beyond in case all voyages are inside EU waters.

    The absolute compliance costs are in the hundreds of millions per year for each company. Until 2035, compliance costs are dominated by EU ETS. After that, costs are dominated by FuelEU Maritime. By 2050, compliance costs for FuelEU alone are in the order of 2 – 5 billion USD. CMA CGM has the highest absolute costs due to its highest fuel consumption and EU exposure.

  • The Fuel Cost Calculator compares the use of up to three different fuels on a normalized and absolute cost basis. It compares fuel costs, EU ETS costs, FuelEU penalty and pooling benefits if applied. This tool helps shipowners, operators, and fuel suppliers assess the economic impact of different fuel choices while considering regulatory developments, in particular FuelEU Maritime and EU ETS.

    The tool allows for a scenario-based analysis, allowing you to explore predefined fuel price evolutions (Steady State, Fossil Future, Biofuels Better, and Renewable Rise) or define your own price trends. It also enables dynamic selection of a start and end year, so you can focus on specific time ranges to analyse fuel cost evolution. A report of your analysis can be printed and shared to showcase different options all the way up to C-level for strategic decision-making purposes. In short, you can use the tool for …

    Operational Cost Forecast – Project fuel costs over time, incorporating EU ETS and FuelEU penalties or pooling benefits.

    Regulatory Compliance Assessment – Determine the cost implications of EU ETS and FuelEU Maritime penalties and identify cost-saving strategies.

    Investment Case Report – Create a structured analysis to present fuel cost scenarios and regulatory impacts to decision-makers.

    Feasibility Study – Assess the financial and regulatory impact of switching to alternative fuels before making investment decisions.

    Fuel Cost Benchmarking – Compare fuels on an energy-equivalent basis to understand which is most cost-effective for specific routes or operations.

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References

CMA CGM - CSR Report 2023

Hapag-Lloyd - Sustainability Report 2023

COSCO - Sustainability Report 2022

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