Maritime Decarbonisation: Five questions for 2025 gift wrapped – owners and charterers in Shipping Law News,Shipping: Emission Possible 24/01/2026 Through 2025 fast-paced regulatory, technological and contractual change continued to drive maritime decarbonisation, with numerous fresh challenges emerging day-to-day. To assist owners and charterers in navigating the changing times, by focusing on the practical issues likely to impact their business directly, we illuminated throughout 2025 five key questions addressing important themes of the year. 2025 was a year in which maritime decarbonisation made headlines far beyond the maritime press. With provisional approval of the IMO Net Zero Framework in April, and postponement of the vote on its formal adoption in October, attracting global attention. 2025 was also a year in which the industry grappled with the first ever verification period of the EU Emissions Trading Scheme and first ever reporting period of FuelEU Maritime. The proposed extension of the UK Emissions Trading Scheme started to take shape in the form of final policy decisions, and the other national regulators advanced their plans for national level emissions regulation. Commercially, the drive to adopt lower GHG intensity fuels has brought the maritime industry increasingly into contact with the biofuel and alternative fuels markets, and an entirely new compliance market has emerged in connection with FuelEU pooling. Meanwhile as the benefits of efficiency improvements continue to multiply many technical and technological advancements have been made, with associated financial and insurance structures developing alongside. Throughout, contractual innovation has been essential. Whether responding to regulatory, commercial or technological change, defining specific parties’ responsibilities and liabilities, and aligning those within a wider eco-system of contractual relations, has been crucial to successfully navigating the shifting terrain. ‘Five questions for 2025 gift-wrapped’ brings together all five questions posed throughout 2025 and is accompanied by our very best wishes for 2026. We wish you a peaceful and prosperous year ahead and look forward to supporting you with any maritime decarbonisation queries you may have. QUESTION 1: YOUR VESSEL LEFT THE EEA BEFORE 1 JANUARY 2024 BUT WAS STILL PERFORMING ITS DEPARTURE VOYAGE ON 1 JANUARY 2024, ARE ITS DEPARTURE VOYAGE EMISSIONS WITHIN THE EU ETS? Legal context The EU ETS imposes an obligation on “shipping companies” to surrender EU allowances in connection with the greenhouse gas emissions of vessels on voyages to, from and within the EEA. Now that the 2024 reporting year has concluded, parties are preparing to report their 2024 emissions (in time for compliance with the 31 March 2025 deadline) and acquire EU allowances to cover those emissions (in time for compliance with the 30 September 2025 deadline). 2024 is the first year the EU ETS has applied to emissions from vessels and there are at least two schools of thought as to how emissions from vessels which left the EEA before 1 January 2024, but were still performing their departure voyage on 1 January 2024, should be counted. Why does it matter If a portion of the departure voyage emissions fall within the EU ETS an obligation to surrender allowances in connection with those emissions arises. Whilst charterparties are likely to make provision for EU allowances to be collected and provided along the chain, disputes may ar