Freight intelligence platform VesselBot’s recent Decoding Maritime Emissions Q2 2026 report revealed that higher levels of vessel utilization aboard containerships are among the most important factors in reducing shipping emissions.
The company followed this by publishing a new case study, EU Emissions Trading System (ETS) Surcharges vs. Actual Voyage Exposure: What Shipment Execution Data Reveals.
One of the main takeaways was that only shipment-execution data allows accurate benchmarking of ETS exposure. The study found that, for the same carrier, origin and EU destination, the actual regulatory cost can swing by an order of magnitude depending on port sequence, not distance.
On one route, a single UK port call before entering the EU—the UK is no longer a member of the 27-member bloc—cut the voyage’s actual ETS exposure to less than 1% of total emissions, while the published surcharge on that route stayed fixed.
More Than 20,000 Containership Voyages in Q2
But first, a reminder that the EU ETS is a carbon-pricing mechanism that requires shipping companies to purchase and surrender allowances for their greenhouse gas emissions.
Maritime transport has been included in the system since January 2024. For containerships, the EU ETS covers 100% of emissions from voyages between EU/EEA (European Economic Area) ports and 50% of emissions from voyages between EU/EEA and non-EU/EEA ports.
During the second quarter of 2026, more than 20,000 containership voyages fell within the scope of the EU ETS, either departing from or arriving at an EU/EEA port. Together, these voyages generated more than 11.8 million tonnes of CO₂e, of which 7.15 million tonnes, or 60%, were subject to allowance surrender.
With EU Allowances trading at around €80 per tonne at the end of the quarter, the allowances required to cover these emissions represented an estimated €572.4 million in carbon costs for Q2 alone.
Exposure on a Per-TEU Basis
For shippers, this means millions of euros in carbon costs may be incorporated into freight rates through EU ETS surcharges. It raises the question of how carriers are passing on these costs and whether the surcharges being charged actually reflect their underlying EU ETS exposure, VesselBot noted.
With the overall exposure in Q2 2026 exceeding €572 million, VesselBot asked what this translated to on a per-TEU basis.
Using a digital-twin model, it estimated that during the Q2 containership voyages within the scope of its analysis, 42.8 million TEUs were collectively carried, putting the estimated EU ETS exposure at approximately €13.40 per TEU.
“This figure should be treated as a directional benchmark rather than a shipment-level truth. Voyage-level TEU volumes do not represent unique containers: the same container can be counted on multiple legs as it moves through a carrier’s network, for example, Shanghai to Singapore, Singapore to Rotterdam, and Rotterdam to Hamburg,” VesselBot explained.
A single container therefore appears several times in the fleetwide transport-work calculation, while the shipper ultimately faces one surcharge tied to one specific origin and destination.
Isolating Voyages
Translating fleetwide exposure into a shipper-relevant benchmark therefore requires shipment-level execution data, and VesselBot got closer to this by isolating voyages whose origin-destination pairs do not overlap with one another.
For example, CMA CGM’s direct Singapore–Rotterdam, Singapore–Valencia and Singapore–Piraeus voyages provided a more accurate benchmark: an actual ETS cost of roughly €26–€31 per TEU, well below the carrier’s published surcharge of €56–€70 per TEU.
This did not mean that the difference between estimated ETS exposure and a carrier’s published surcharge represented an overcharge, VesselBot was swift to point out.
Energy-transition surcharges may also incorporate FuelEU Maritime costs and other carrier-specific commercial assumptions. It does mean, however, that the published surcharge alone cannot tell procurement teams whether its ETS component is proportionate to the regulatory exposure generated by a specific shipment.
“Instead, the comparison demonstrates the value of a route-specific ETS benchmark. It gives procurement teams a way to quantify how much of the published surcharge can be explained by the estimated EU ETS exposure generated by the underlying voyage, and to distinguish that regulatory cost from the other components bundled into the surcharge. With this benchmark, the question shifts from simply accepting the published surcharge to evaluating whether its ETS component is proportionate to how the shipment was actually executed.”
UK Port Call Changes Regulatory Treatment
Routing through a non-EU/EEA port before entering the EU changes the equation sharply. On seven observed Singapore–Felixstowe, UK–Zeebrugge voyages, VesselBot found that only 0.5% of total voyage emissions fell within the scope of the EU ETS, producing an exposure of about €5,150 per voyage—less than the surcharge collected from a single 100-TEU shipment on that route.
The pattern shows why a blanket per-TEU surcharge is a blunt instrument: The carbon cost of moving a container between two points can vary by an order of magnitude depending on routing, yet the surcharge charged to the shipper does not currently vary with it.
The question is therefore no longer simply what ETS surcharge a carrier publishes, but whether that surcharge can be benchmarked against the regulatory exposure generated by the shipment as it was actually executed.
“Answering that question requires shipment execution data that captures the vessel, routing, port sequence, emissions, utilization, and applicable ETS coverage behind each move. As carbon costs become a larger component of freight spend, this level of benchmarking will become increasingly important for organizations seeking greater control, transparency, and governance over transportation costs.”
‘Making Intelligence Operational’
Constantine Komodromos, CEO and co-founder of Greece-based VesselBot, said that more accurate emissions measurement was only the beginning.
“The real opportunity is to make that intelligence operational. Transportation is shaped by thousands of operational decisions, and the data behind those decisions has value far beyond reporting.
“Our focus is on helping organizations understand what is actually happening across their freight operations and use that understanding at both a strategic and tactical level to achieve reductions in costs and emissions.”
