As of 2024, the EU Emissions Trading System (EU ETS) was extended to cover emissions from maritime transport. The aim is to reduce greenhouse gas emissions from shipping as part of the EU’s climate and energy policy. In Finland, the Finnish Transport and Communications Agency Traficom acts as the administering authority (AA) for shipping companies in accordance with the MRV Regulation (EU) 2015/757 and the EU Emissions Trading System.
Maritime transport is a part of the EU Emissions Trading System
From 2024 onwards, the EU Emissions Trading System (EU ETS) includes emissions from maritime transport, specifically the commercial transport of cargo and passengers to, from, and between ports located in the EU and EEA. The EU ETS applies to ships of 5 000 gross tonnage or above engaged in commercial activities.
The objective of the EU ETS is to promote cost-effective and economically efficient reductions of greenhouse gas emissions across the European Union. Combined with the requirements of the MRV Regulation (EU) 2015/757 on the monitoring, reporting and verification of emissions, the inclusion of maritime transport in the EU ETS is one of the European Commission’s key measures to reduce greenhouse gas emissions from the shipping sector.
Emission Trading Obligations
Greenhouse gas emissions from ships subject to the EU Emissions Trading System must be monitored, reported, and verified in accordance with Regulation (EU) 2015/757 of the European Parliament and of the Council (the MRV Regulation). EU ETS covers carbon dioxide (CO₂) emissions and, from 2026 onwards, also methane (CH₄) and nitrous oxide (N₂O) emissions.
Designation of the Responsible Entity under the EU ETS
Responsibility for compliance with the EU ETS lies with the ship owner or a company identified as the ship’s company under the ISM Code, if so authorised by the owner. The ship owner must notify Traficom of the ships falling under the scope of the EU ETS. If the ISM company assumes responsibility for compliance, it must submit a ship-specific mandate from the owner to Traficom.
Monitoring Plan
A monitoring plan must be developed for each ship falling under the scope of the MRV Regulation. The plan describes the ship’s emission sources and defines the methods for monitoring emissions and fuel consumption, as well as the procedures for reporting. It must be recorded in the THETIS-MRV electronic reporting system and submitted to a verifier for assessment. The verified monitoring plan must be submitted to the Finnish Transport and Communications Agency (Traficom), acting as the administering authority, for approval via the same system. An approved monitoring plan must be kept up to date. It must be revised whenever there are significant changes in the ship's operation or emission measurement methods. In such cases, the revised plan must be reassessed by a verifier and resubmitted to the administering authority for approval.
Annual emissions report in Thetis-MRV reporting system
Emission data must be reported annually both per ship (Emissions Report, ER) and at the company level (Company Emissions Report, CER). Verified reports must be submitted to Traficom, the administering authority, via the EU’s THETIS-MRV system by 31 March each year.
Annual obligations under the EU Emissions Trading System
There are two main annual obligations under the EU ETS: emissions reporting and surrendering of emission allowances.
Reporting of Emissions to the Union Registry
Company-level emissions (Company Emission Report, CER) must be reported to the Union Registry by 31 March each year. The report must be based on data verified by an accredited verifier. For this purpose, operators must open a Maritime Operator Holding Account (MOHA) in the Union Registry.
Surrendering of Emission Allowances
Each year, companies must surrender a number of emission allowances (EU Allowances, EUA) equivalent to their verified emissions. The allowances must be surrendered via the Union Registry by 30 September. The surrender obligation is phased in as follows: 40% of reported emissions for 2024, 70% for 2025, 100% from 2026 onwards. In Finland, the Energy Authority is the national administrator of the Union Registry.
Shipping MRV verifier
According to the Finnish Emissions Trading Act 1270/2023, shipping MRV verifiers must apply for approval from the Finnish Transport and Communications Agency Traficom.
Frequently Asked Questions
Should the original copy of the shipowner's authorisation to the ISM company be delivered to both the Energy Authority and Traficom?
No, the original copy should preferably be sent to Traficom, but the agencies will share this information with each other on request.
Why should the verifier apply for national approval in Finland?
The Emissions Trading Act (1270/2023) requires this procedure.
Are there requirements related to the content or format of the authorisation granted by the shipowner?
The authorisation must include its purpose (implementation of emissions trading obligations), date, signatures from the owner and the ISM company in accordance with the company’s rights to represent, and the name and IMO number of the vessel. Preferably, no other information should be given.