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FuelEU Maritime 2026–2027: Compliance Costs, Penalty Economics and the Fleet Exposure Every Shipping Executive Must Understand

Green Fuel Journal Research & Intelligence Team — see our Editorial Standards and AI Usage Disclosure for how this report was produced and verified.


Published: Sept. 2026  |  Report Type: Executive Intelligence — Premium Research 



The European Commission's enforcement guidance published on 25 June 2026 confirms that FuelEU Maritime has moved into active enforcement — with penalties of €2,400/tonne VLSFO equivalent now financially real for the first 2025 compliance cycle, and penalties payable by 30 June 2026 for unresolved deficits. The regulation's well-to-wake GHG intensity reduction schedule tightens from −2% in 2025 to −6% in 2030 and −80% by 2050, creating a compliance gap that biofuel blending alone cannot bridge for most conventional-fuel fleets beyond 2035.


Every shipping executive now faces a capital-allocation decision — whether to pay the €2,400/tonne penalty, transition to biofuel blends at €31/GJ against VLSFO at €19/GJ, enter pooling arrangements, or pursue structural fleet transformation — with the 2030 zero-emission berth requirement for container and passenger vessels making inaction a stranded-asset risk within four years.


This report provides the structured commercial-risk framework most existing market analysis fails to deliver: a vessel-level exposure assessment using the GFJ FuelEU Maritime Risk Exposure Index, a six-pathway compliance cost decision tree integrating both FuelEU and EU ETS economics, a charter-party cost allocation analysis that identifies who ultimately pays, and three fleet strategy scenarios for 2026–2035.

Poster with cargo ship at sea and large text: FuelEU Maritime: Are You Ready for the 2026-2027 Enforcement Wave?

1. Executive Intelligence Synthesis

GFJ Intelligence Brief

FuelEU Maritime is in active enforcement from 2026. The penalty is €2,400 per tonne VLSFO equivalent of compliance deficit, and EU ETS obligations run simultaneously since 2024 — creating a dual carbon-cost burden that most fleet economic models still treat as two separate problems. Who ultimately pays — shipowner, charterer, or cargo customer — depends entirely on charter-party structure. Container and passenger operators face an additional 2030 zero-emission berth requirement that requires capital decisions no later than 2027–2028.


Signal 1 — FuelEU Has Moved from Regulation to Enforcement

  • FINDING: The European Commission published FuelEU verification and Member State enforcement guidance on 25 June 2026; the first 2025 FuelEU reports are now with verifiers; and EMSA has assessed more than 11,000 monitoring plans.

  • SO WHAT: Shipping companies that treated 2025 as a monitoring-only or grace year face the first real financial consequences in 2026 — not a future compliance date.

  • NOW WHAT: Verify your 2025 FuelEU report is complete, submitted to your verifier, and that your compliance balance is understood before the penalty payable date of 30 June 2026.


Signal 2 — The €2,400/Tonne Penalty Is a Ceiling, Not a Strategy

  • FINDING: The FuelEU penalty formula sets a cost of €2,400 per equivalent tonne of VLSFO for a compliance deficit, but compliance pooling prices are privately negotiated, biofuel premiums vary by procurement route, and the cheapest compliance path depends on each vessel's voyage mix, fuel consumption, and EU ETS interaction.

  • SO WHAT: Companies treating the penalty as a de facto compliance default may be overpaying relative to pooling or biofuel alternatives — or underpaying in the short term while accumulating structural risk through the consecutive non-compliance multiplier.

  • NOW WHAT: Model each high-exposure vessel's penalty cost against the actual cost of pooling, biofuel blending, and operational efficiency before accepting the penalty as the rational response.


Signal 3 — FuelEU and EU ETS Cost a Shipping Company Twice, but Most Fleet Models Count Once

  • FINDING: EU ETS maritime obligations applied since 2024; FuelEU Maritime applied from 2025; the two mechanisms measure different things — carbon-price exposure versus well-to-wake fuel-GHG-intensity — meaning the cheapest FuelEU solution is not necessarily the cheapest combined carbon-compliance solution.

  • SO WHAT: Fleet executives optimising solely for FuelEU may inadvertently increase EU ETS cost exposure, and vice versa, producing a materially incomplete compliance cost picture.

  • NOW WHAT: Build an integrated FuelEU + EU ETS compliance model for each high-exposure vessel before making fuel-procurement or route-design decisions.


Signal 4 — Regulatory Liability and Economic Liability Are Not the Same Entity

  • FINDING: BIMCO's 2025/2026 FuelEU charter-party clauses and MoA amendments demonstrate that FuelEU compliance responsibility, operational control, and economic liability can sit with different parties — owner, technical manager, time charterer, voyage charterer, or cargo owner — depending entirely on contract structure.

  • SO WHAT: A shipowner can face regulatory liability for a compliance deficit while a time charterer controls the fuel selection and voyage-speed decisions that created it.

  • NOW WHAT: Review all active charter parties and ship-management agreements against BIMCO's current FuelEU clause architecture and ensure commercial liability matches operational control.


Signal 5 — The 2030 Zero-Emission Berth Requirement Is a Capital Decision Due Now

  • FINDING: FuelEU Maritime requires zero-emission or on-shore power supply (OPS) compliance at berth for container and passenger ships at major EU ports from 2030, and EU port OPS infrastructure coverage remains materially limited in 2026.

  • SO WHAT: Fleet renewal cycles and newbuild orders that do not account for berth-emission compliance will generate stranded-asset risk within four years.

  • NOW WHAT: Map all container and passenger vessel EU port calls against the 2030 OPS requirement and include berth-emission compatibility in every newbuild specification and fleet-renewal decision from today.


2. Regulatory Scope and the 2026 Compliance Position

GFJ Intelligence Brief

Regulation (EU) 2023/1805 — FuelEU Maritime — applies to ships above 5,000 GT calling any EU/EEA port regardless of flag, from 1 January 2025. It covers 100% of energy on intra-EU voyages, 50% on EU-to-third-country voyages, and 100% of energy at berth. The first compliance cycle — covering 2025 activity — is now in active verification, with penalties payable by 30 June 2026 for unresolved deficits. More than 11,000 monitoring plans have been assessed by EMSA.


Who Falls Within Scope: Ships, Ports and the 100%/50% Accounting Rule

Any vessel above 5,000 GT calling a port within the EU or EEA is subject to FuelEU Maritime regardless of its flag, nationality of ownership, or country of commercial operation. The geographic trigger is the port call itself — making FuelEU a genuinely global compliance obligation for any international shipping company operating qualifying routes, not a European-flag or European-owned fleet issue.


The energy-accounting rules determine precisely how much of a vessel's fuel consumption falls within FuelEU measurement. 100% of energy used on voyages between EU/EEA ports is counted. 50% of energy used on voyages between an EU/EEA port and a port outside the EEA is counted. 100% of energy consumed at berth in EU/EEA ports is counted. A vessel making regular calls between Hamburg and Singapore carries a materially different FuelEU exposure profile to one operating solely within the North Sea — the 50% counting rule for mixed EU/non-EU voyages is the mechanism through which route design becomes a compliance and commercial variable.


The flexibility mechanisms available are broader than most fleet managers currently model: banking of compliance surplus from current years for future use; borrowing an advance compliance surplus subject to regulatory limits; pooling compliance balances between ships on privately negotiated terms; fuel switching; energy-efficiency measures including wind assistance; OPS at berth; or substitute zero-emission technologies. The commercial significance of each option varies dramatically by vessel type, route, charter structure, and fuel availability.


⚠  The Norway & Iceland EEA Gap — What It Means for Voyage Calculations

Because of delays incorporating FuelEU Maritime into the EEA Agreement, Norway and Iceland were treated as third-country ports for FuelEU purposes from 1 January 2025 until EEA incorporation. For operators running routes between EU ports and Norwegian or Icelandic ports during the gap period, the energy-accounting fraction changed from 100% (intra-EEA) to 50% (EU–third-country). Voyage-level compliance calculations for the 2025 reporting year must explicitly reflect this classification. Verifiers will need to confirm how the gap period has been handled in submitted FuelEU reports before the 30 June 2026 penalty deadline.


The GHG-Intensity Reduction Schedule: 2% to 80%

FuelEU Maritime reduces the permitted annual average well-to-wake GHG intensity of qualifying energy consumption against a 2020 reference value. The schedule accelerates. A vessel barely compliant at the −2% threshold in 2025 faces an additional 4 percentage-point compliance gap by 2030 without any operational change. By 2035, the cumulative gap from a 2025 baseline reaches 12.5 percentage points — a quantum biofuel blending alone cannot bridge for most conventional-fuel fleets.

Year

Required Reduction vs. 2020

Key Operational Implication

2025

−2%

First reporting year; verification and penalties in 2026

2030

−6%

Zero-emission/OPS berth requirement activates for container & passenger ships

2035

−14.5%

Meaningful fuel-mix shift required; biofuel blending alone insufficient

2040

−31%

Structural fleet fuel transformation required

2045

−62%

Near-zero conventional fuel operations

2050

−80%

Full low-carbon fuel economy at scale required

Source: Regulation (EU) 2023/1805, European Commission, 13 September 2023.

The 2026 Enforcement Position: Where Compliance Stands Now

The first FuelEU report — covering 2025 activity — was due to verifiers by 31 January 2026. Verification occurs during 2026, with penalties payable by 30 June of the verification period where a compliance deficit remains after flexibility mechanisms have been applied. The Commission adopted Implementing Regulation (EU) 2026/394 on 23 February 2026, establishing access rights and technical specifications for the FuelEU database. On 25 June 2026, the Commission published dedicated FuelEU verification and Member State enforcement guidance — confirming the regime has moved from rulemaking into operational enforcement architecture.


The Dual Burden: FuelEU and EU ETS Running Simultaneously

The EU ETS maritime extension — Directive (EU) 2023/959 — applied to shipping from 2024. FuelEU Maritime applied from 2025. The two mechanisms coexist but do not offset each other. EU ETS prices the carbon-allowance cost per tonne of CO₂ emitted. FuelEU measures the well-to-wake GHG intensity of energy used — a lifecycle metric that credits sustainable fuel pathways which may still produce CO₂ at sea. A biofuel blend that reduces FuelEU intensity may therefore still generate CO₂ on the voyage, sustaining EU ETS allowance liability. Conversely, OPS at berth eliminates both FuelEU berth-energy exposure and EU ETS port-emission costs simultaneously — making it the most dual-efficient compliance option where port infrastructure supports it.


For a structurally parallel analysis of how EU fuel mandates are reshaping adjacent transport sectors, GFJ's report on ReFuelEU Aviation 2026–2030 provides the comparison that multi-modal fleet strategists will find directly instructive.


3. The FuelEU Maritime Risk Exposure Index: Which Fleets Carry the Highest Structural Risk

GFJ Intelligence Brief

No authoritative public dataset provides company-by-company FuelEU compliance deficit data. The GFJ FuelEU Maritime Risk Exposure Index scores structural exposure across 12 fleet characteristics — not verified compliance status — to identify which operators face the greatest commercial risk as targets tighten through 2030. Highest-risk profiles share three characteristics: frequent EU port calls on conventional fuel, no alternative-fuel capability, and no FuelEU charter-party cost allocation in active contracts.


The absence of a public vessel-level compliance dataset means the commercially critical executive question — which shipping companies face the greatest FuelEU cost exposure? — cannot be answered by citing a regulatory register. It can be answered by scoring the structural characteristics that determine whether a fleet is easy or difficult to bring into compliance.


The GFJ FuelEU Maritime Risk Exposure Index provides that framework.

Score each dimension from 1 (low exposure) to 3 (high exposure).

Total score classifies exposure: 1–12 Low; 13–22 Moderate; 23–30 High; 31–36 Critical.


Apply vessel by vessel to identify where compliance investment produces the highest risk-reduction return.

Dimension

Low Exposure (1)

Moderate (2)

High Exposure (3)

1. EU port-call frequency

Occasional EU calls

Regular but limited routes

High-frequency EU hub calls

2. EU voyage share of total energy

<20% of voyages

20–50%

>50%

3. Vessel age

Post-2020 newbuild

2010–2020 built

Pre-2010 built

4. Propulsion / fuel type

Dual-fuel methanol or LNG

LNG single-fuel

Conventional HFO/VLSFO only

5. Alternative-fuel capability

Operational AF capability

Retrofit-ready

No AF capability

6. OPS readiness

OPS-capable, EU-port compatible

Partial / retrofit pending

Not OPS-capable

7. Voyage length & energy consumption

Short voyages, lower energy use

Mixed

Long-haul, high energy consumption

8. Alternative-fuel supply chain

Contracted biofuel or methanol supply

Spot-market access only

No AF supply chain in place

9. Charter-party FuelEU clause

Clear owner/charterer cost allocation

Partial BIMCO clause

No FuelEU allocation clause

10. Compliance pooling access

Active pooling arrangement

Potential partner identified

No pooling access

11. EU ETS combined exposure

ETS-optimised operations

Partial ETS management

High combined ETS + FuelEU exposure

12. Cost pass-through ability

Established emissions surcharge mechanism

Partial customer pass-through

No pass-through mechanism

Source: GFJ proprietary framework derived from Regulation (EU) 2023/1805, BIMCO FuelEU clause architecture, EMSA implementation data, and CE Delft fuel-cost modelling, October 2024.


Four Fleet Segments With the Highest Structural Exposure


Segment 1: Older Conventional-Fuel Container Vessels on Asia–Europe Routes. 

A pre-2010-built container ship burning conventional VLSFO on Asia–Europe rotations calling Hamburg, Rotterdam, and Antwerp accumulates FuelEU liability on 50% of outbound voyage energy and 100% of intra-EU feeder legs — with no alternative-fuel capability and, if operating under time charters lacking BIMCO FuelEU clauses, no contractual mechanism to recover the compliance cost from the party controlling fuel selection. Regulatory liability falls on the owner even when the charterer controls voyage speed and fuel choice.


Segment 2: Bulk Carriers With Significant EU Voyage Shares. 

Bulk carriers serving European agricultural and industrial commodity trades — grain into Hamburg, iron ore into Rotterdam — accumulate FuelEU energy exposure at 100% on intra-EU legs and 50% on European import legs. Many operate on conventional fuel with voyage-charter structures where FuelEU allocation clauses are absent. The result is an uncovered compliance cost that the market has not yet standardised how to apportion.


Segment 3: Passenger Cruise Vessels at Major EU Ports.

Cruise vessels face dual pressure: FuelEU GHG-intensity requirements on voyage energy and the 2030 zero-emission berth requirement applied to port energy. Large cruise ships at Barcelona, Civitavecchia, and Hamburg face 100% berth-energy counting and an OPS compliance deadline that many conventionally equipped vessels cannot meet without technical modification. The commercial consequence is stranded-asset risk for vessels renewed without OPS capability.


Segment 4: Time-Chartered Fleets Without FuelEU Charter-Party Clauses. 

The most commercially underappreciated risk segment is defined not by vessel type but by contract structure. Any vessel where fuel-selection decisions rest with a time charterer but regulatory compliance liability sits with the ship manager or owner creates a structural misalignment. The party bearing the FuelEU fine cannot control the operational decisions that determine the compliance outcome.



4. The Compliance Cost Decision Tree: Penalty Versus Alternatives

GFJ Intelligence Brief

Paying the FuelEU penalty at €2,400/tonne VLSFO equivalent is not automatically the cheapest compliance pathway. Biofuel blends cost approximately €31/GJ versus VLSFO at €19/GJ in 2025 (CE Delft). Pooling prices are privately negotiated. Bio-methanol reaches fossil-methanol cost parity around 2030; e-methanol at €1,374/tonne Germany baseline remains substantially more expensive. The consecutive non-compliance multiplier — penalty × 1 + (n−1)/10 per repeat period — makes sustained penalty reliance progressively irrational.


The FuelEU Penalty Formula: How Non-Compliance Costs Are Calculated

The penalty for GHG-intensity non-compliance is defined in Annex IV of Regulation (EU) 2023/1805:

Penalty = |compliance balance| ÷ (GHG intensity actual × 41,000) × €2,400

The €2,400 figure represents the penalty per equivalent tonne of VLSFO. For a large older container vessel on regular EU-linked routes burning only conventional VLSFO, the compliance deficit can be substantial — resulting in a six-figure annual penalty before any consecutive-year multiplier applies.

The berth non-compliance penalty is separate: €1.50 × total electrical power demand at berth × hours of non-compliance. For a large cruise vessel with high hotel-load electricity demand during multi-day EU port calls, this is not a rounding item.


Consecutive non-compliance is progressively penalised. The GHG-intensity penalty is multiplied by 1 + (n−1)/10 for each consecutive reporting period in deficit. A vessel non-compliant for three consecutive years faces a 1.2× multiplier in the third year; five consecutive years generates a 1.4× multiplier. The regulation's architecture penalises the pay-and-ignore approach, making it rational only for operators with a demonstrably short remaining commercial horizon for specific vessels.


The Six Compliance Pathways: Decision Framework

The optimal compliance pathway is vessel-specific: it depends on EU route share, fuel-system compatibility, charter-party structure, biofuel procurement access, and the combined FuelEU + EU ETS cost picture. The table below sets out indicative cost benchmarks and 2030 risk profiles for each available option.

Pathway

Regulatory Effect

Indicative Cost (2025)

Implementation

Fuel Availability

2030 Risk

Pay the penalty

Clears current deficit; consecutive multiplier builds

€2,400/t VLSFO eq.

Low — administrative

N/A

Multiplier escalation; stranded exposure

Biofuel blend (FAME/HVO)

Reduces GHG intensity proportional to blend %

~€31/GJ vs VLSFO €19/GJ

Low–Medium

Available but supply-constrained

Feedstock scarcity post-2027

Bio-methanol

Significant GHG-intensity reduction

~€361–€700/t (literature); €558/t Germany baseline

Medium — vessel compatibility

Limited but growing

Approaches fossil-methanol parity ~2030

E-methanol

Deep GHG-intensity reduction; RFNBO eligible

~€608–€2,710/t (literature); €1,374/t Germany baseline

High — new supply chain

Very limited in 2026

Expensive without H₂ cost reduction

Operational efficiency

Partial reduction; insufficient standalone post-2030

Vessel-specific; low CAPEX

Medium

N/A

Cannot bridge −6% target alone

Compliance pooling

Transfers surplus from compliant to deficit vessel

Privately negotiated; no regulated price

Low–Medium

Partner-dependent

Surplus may contract post-2030

OPS / Shore-side electricity

Eliminates berth GHG exposure and berth penalty

Port-infrastructure dependent

Medium–High

Limited EU port OPS coverage

Essential for 2030 container/passenger berth requirement

Sources: Regulation (EU) 2023/1805, Annex IV; CE Delft, Impact of Fuel Prices on Energy Efficiency of Maritime Ships, October 2024; Renewable Methanol Techno-Economic Assessment, ScienceDirect/Elsevier, 15 May 2026.

A 2026 peer-reviewed techno-economic study of 166 kt/year methanol reference production plants placed CAPEX requirements at approximately €476 million for bio-methanol and €566 million for e-methanol at Germany production sites. The study concludes bio-methanol approaches fossil-methanol cost parity around 2030, while e-methanol requires further hydrogen-cost reduction and sustained policy support to become competitive at scale.


For the hydrogen production cost trajectory that underpins e-methanol viability, GFJ's Green Hydrogen Cost Economics 2026 provides the benchmark analysis relevant to fleet fuel-procurement planning beyond 2030.


The Integrated FuelEU + EU ETS Cost: Why Optimising One Can Worsen the Other

CE Delft's 2024 modelling projects the weighted average maritime fuel cost rising from €20/GJ in 2025 to €34/GJ in 2040 in a policy scenario reflecting both EU ETS cost pass-through and increasing alternative-fuel penetration.

Fuel

2025 Price (CE Delft)

2030 Projection

2040 Projection

VLSFO

€19/GJ

€21/GJ

€25/GJ

Biodiesel

€31/GJ

€37/GJ

€50/GJ

E-fuel

€62/GJ

€58/GJ

€53/GJ

Source: CE Delft, Impact of Fuel Prices on Energy Efficiency of Maritime Ships, October 2024.



The dual-mechanism interaction is commercially critical. FuelEU credits sustainable fuel pathways using a well-to-wake lifecycle calculation — meaning a biofuel blend that reduces FuelEU intensity may still generate CO₂ at sea, sustaining EU ETS allowance costs. OPS at berth eliminates both simultaneously: zero berth energy counted under FuelEU, and zero port-based CO₂ emissions attracting EU ETS liability.


For CFOs building compliance budgets, the correct economic model is: fuel premium + EU ETS allowance cost + FuelEU penalty or pooling cost + vessel efficiency improvement, assessed vessel by vessel.


For the broader alternative-fuel economics landscape relevant to multi-fuel transition planning, GFJ's Green Molecules Economy 2035 analysis covers green hydrogen, ammonia, methanol, and SAF in an integrated framework.


When Is Paying the Penalty Actually Rational?

Paying the FuelEU penalty is rational under three specific conditions: the vessel's remaining commercial life is shorter than the payback period for a fuel-transition investment; biofuel supply is not available at the relevant bunkering ports for that vessel's route; or the penalty cost per voyage is demonstrably lower than the biofuel premium plus procurement complexity for a specific vessel in a specific operating year. The mechanism that eliminates the penalty-as-strategy logic for most active fleets is the consecutive non-compliance multiplier. At 1.2× in year three and 1.4× in year five, the break-even against biofuel blending shifts materially with each successive penalty period. Vessels with commercial activity extending beyond 2028 should not be managed on the assumption that the penalty represents a stable long-term compliance equilibrium.


5. Who Actually Pays: Charter-Party Allocation and Commercial Risk

GFJ Intelligence Brief

Regulatory compliance liability under FuelEU Maritime falls on the company operating the ship — typically the Document of Compliance holder and ISM manager. Economic liability is a separate question. BIMCO FuelEU charter-party clauses and the 2025 MoA amendment provide contractual mechanisms to allocate compliance costs between owner, technical manager, time charterer, voyage charterer, and cargo owner. Where no FuelEU clause exists, the owner bears the default economic risk regardless of who controlled fuel selection and voyage speed.


The gap between who holds regulatory compliance liability and who controls the commercial decisions that determine the compliance outcome is the most significant FuelEU risk that existing regulatory guidance leaves unaddressed for shipping executives. A shipowner can face the FuelEU penalty for a compliance deficit generated entirely by a time charterer's fuel-selection preferences, voyage-speed instructions, and port-call choices — unless the charter party explicitly allocates that economic risk to the party with operational control.


The FuelEU Cost Allocation Chain

FuelEU regulatory obligation and commercial economic liability travel through distinct contractual chains. The regulatory obligation sits at the top with the ISM/DOC operator; economic liability can be passed to any link in the chain below — but only where a FuelEU clause exists in the relevant contract.

Shipowner  →  Technical Manager  →  Time Charterer  →  Voyage Charterer  →  Cargo Owner  →  End Customer

Where no BIMCO FuelEU clause exists, default liability reverts to the owner regardless of who controlled operational fuel decisions.

The critical link is between the shipowner and the time charterer. Under a standard time charter without a FuelEU clause, the charterer instructs voyage operations — including port calls, voyage speed, and in some cases fuel type — while the owner holds the regulatory compliance obligation. BIMCO's 2025 MoA clause explicitly provides for purchase-price adjustments based on positive or negative compliance balances and the consecutive non-compliance penalty multiplier — treating compliance history as an asset-liability characteristic of the vessel in a transaction.


The FuelEU Due Diligence Checklist for Vessel Acquisitions

Five questions determine whether a vessel being acquired or chartered carries a FuelEU liability that is not visible in the headline price. Any of the following gaps can convert a commercially attractive asset into a compliance-cost burden from day one of ownership or operation.

  • Question 1.

    What is the vessel's 2025 FuelEU compliance balance — surplus or deficit? A deficit transferred with the vessel can activate the consecutive non-compliance multiplier from year one of new ownership.

  • Question 2.

    Is the vessel currently in a compliance pooling arrangement — and does that arrangement transfer on sale or charter? A pooling surplus is a measurable compliance asset; its loss on transfer eliminates a buffer the buyer may have priced into their acquisition assumptions.

  • Question 3.

    Have there been consecutive compliance deficits in prior years that activate the 1 + (n−1)/10 multiplier for 2026 and beyond?

  • Question 4.

    What is the OPS capability status and is it compatible with OPS infrastructure at the vessel's regular EU berths? A pre-2030 OPS incompatibility is a quantifiable future liability for container and passenger vessels operating EU port rotations.

  • Question 5.

    Is there a live FuelEU clause in all active time charter parties — and if not, who holds the default economic risk position?


Maersk's Emissions Surcharge: A Real-World Cost Migration Model

A.P. Møller–Maersk activated its emissions surcharge mechanism on 1 December 2025, explicitly incorporating FuelEU Maritime compliance costs alongside EU ETS allowance costs into the charge structure applied to cargo customers. A large operator has determined that the optimal response is not to absorb compliance costs at fleet level but to migrate them explicitly into freight pricing. Shipping companies without an equivalent mechanism absorb the same compliance costs — but against operating margin rather than as a transparent freight pricing line.

"Bridging the cost gap between fossil fuels and low-emission alternatives is critical — and it demands firm regulatory support."

— Vincent Clerc, CEO, A.P. Moller–Maersk, 2026 corporate sustainability material


For the structural parallel in aviation fuel cost economics, GFJ's SAF Price Premium analysis provides the fuel-cost-gap comparison that maritime strategists benchmarking EU fuel mandates across transport modes will find directly applicable.


6. Named Company Case Studies: Four Strategies for FuelEU Maritime

GFJ Intelligence Brief

Four major operators represent four distinct strategic postures under FuelEU Maritime: A.P. Møller–Maersk (surcharge-and-transition — FuelEU cost migrated to cargo customers); NYK Line (profitability-led — FuelEU treated as competitive differentiator); Mitsui O.S.K. Lines (corporate governance — FuelEU institutionalised at board level); COSCO Shipping (supply-chain control — FuelEU exposure addressed via alternative-fuel infrastructure).


These four cases represent the spectrum of strategic responses currently being deployed by major operators. They are not compliance exemplars — they are commercial models from which fleet executives can extract a decision architecture that is absent from existing regulatory guidance.

Company

Strategic Posture

Key Verified Data

Core Commercial Insight

A.P. Møller–Maersk

Surcharge & Transition

10 dual-fuel methanol vessels; surcharge active 1 Dec 2025; $2–8bn green-fuel spending through 2030

FuelEU cost explicitly migrated to cargo customers

NYK Line

Profitability & Fleet Strategy

Project LOTUS launched May 2024; FuelEU framed as profitability variable in Oct 2024 presidential message

FuelEU treated as competitive advantage, not compliance burden

Mitsui O.S.K. Lines

Corporate Governance

Internal FuelEU framework established post-Jan 2025; FuelEU on environmental-management committee FY2024 agenda

FuelEU institutionalised at board governance level

COSCO Shipping

Supply Chain Control

19.56m TEU volume in 2025; first green marine ammonia bunkering at Dalian, July 2025

FuelEU exposure addressed via supply chain control

Sources: Maersk sustainability materials (2026); Maersk emissions surcharge announcement (1 December 2025); Maersk Green Financing Framework (2024); NYK Line presidential message (2 October 2024); NYK/GCMD Project LOTUS (9 May 2024); MOL Sustainability Factbook 2025; COSCO Shipping facts (2026).


A.P. Møller–Maersk: The Surcharge-and-Transition Model

Maersk has constructed a FuelEU response operating on two simultaneous tracks. On the fleet track, 10 dual-fuel methanol vessels joined the fleet in the most recent reporting year, with 6 additional dual-fuel vessels expected through 2026. 230 owned vessels and 150 time-chartered vessels received fuel-saving initiatives. 6 × 9,000-TEU methanol-enabled vessels are planned for 2026–27 delivery, and green-fuel spending is projected at $2–8 billion through 2030 depending on regulatory and market conditions.


On the commercial track, the emissions surcharge activated on 1 December 2025 converts FuelEU compliance cost from an operating-margin compression into a transparent pricing variable in freight negotiations. Maersk has already established the commercial architecture that allows it to recover FuelEU and EU ETS costs from cargo customers. Operators without that architecture absorb the same costs against margin.


NYK Line: The Profitability-and-Fleet-Strategy Model

NYK's positioning of FuelEU Maritime — articulated in the 2 October 2024 presidential message — represents the most commercially sophisticated framing of any operator examined in this analysis. NYK stated explicitly that FuelEU would turn GHG emissions into a cost and warned that navigation choices could materially affect profits. It also identified its early fuel-transition strategy as a potential competitive advantage. This is profit-and-loss framing applied to a mandatory regulatory variable, not sustainability language.


In May 2024, NYK and the Global Centre for Maritime Decarbonisation launched Project LOTUS, testing long-term biofuel use under real commercial operations and explicitly linking the trial to CII and FuelEU compliance. Early operational evidence on biofuel performance reduces the commercial uncertainty competitors face when making the same fuel-transition decision under greater regulatory pressure later.


Mitsui O.S.K. Lines: The Corporate Governance Model

Mitsui O.S.K. Lines established an internal FuelEU Maritime compliance framework and listed FuelEU response among its environmental-management committee agenda items for FY2024 — the year the regulation moved from final implementation to operational compliance. A company of MOL's scale treated FuelEU as a board-level governance question immediately upon commencement rather than an operational matter to manage at fleet level. For executives evaluating whether their own internal governance frameworks are adequate for a regulation that tightens progressively through 2050, MOL's response indicates where institutional expectations are heading.


COSCO Shipping: The Supply Chain Control Model

COSCO Shipping Lines reported 19.56 million TEU of shipping volume in 2025, including a substantial Asia–Europe network that generates direct FuelEU exposure on intra-EU segments and 50% exposure on Asia-originating voyages terminating at EU ports. At that scale, FuelEU compliance is a supply chain question, not a vessel-by-vessel management question. COSCO-linked fuel operations completed what Chinese authorities described as the world's first green marine ammonia bunkering operation at Dalian in July 2025 — a signal that China's shipping industry is building the alternative-fuel supply chain infrastructure that will determine bunkering options for Asia–Europe operators as FuelEU targets tighten.


For the green ammonia production and export landscape relevant to maritime fuel-procurement strategy, GFJ's Green Ammonia Exports 2027 provides the verified market development picture.

"The transitions ahead – to zero carbon, to digital systems, to new trade routes – must be just transitions."

— Rebeca Grynspan, Secretary-General, UN Trade and Development, 24 September 2025


7. India and International Operator Exposure

GFJ Intelligence Brief

FuelEU Maritime applies to any vessel above 5,000 GT calling an EU/EEA port regardless of flag. Indian-owned or operated ships on India–EU routes are directly within scope for 50% of voyage energy on India–EU legs and 100% of berth energy at EU ports. India's major ports handled 915.17 million tonnes of cargo in FY2025–26 — a scale that situates Indian shipping firmly within the international networks where FuelEU compliance obligations apply.


Indian Shipping's Direct FuelEU Exposure

Indian shipowners and operators whose vessels exceed 5,000 GT and call EU or EEA ports carry a direct FuelEU compliance obligation regardless of the vessel's flag or the company's domicile. On an India-to-EU voyage, 50% of the energy used across the entire voyage segment counts toward FuelEU GHG intensity measurement — not merely the portion within EU waters. On arrival at berth in Hamburg, Rotterdam, or Piraeus, 100% of berth energy falls under FuelEU scope.


India's major ports handled 915.17 million tonnes of cargo in FY2025–26, up 7.06% year-on-year. JNPA alone handled 102.01 MT. India–EU trade volumes represent a commercially material and growing component of that throughput — which means the number of Indian-operated qualifying vessels accumulating FuelEU liability on EU routes is increasing in proportion to trade growth.


India's Green Shipping Infrastructure: Progress and the Supply-Chain Gap

India's Green Tug Transition Programme targets conversion of at least 50% of tugs at major ports to green alternatives — electricity, LNG, green methanol, and green hydrogen — by 2030. In September 2025, India and Singapore formally established cooperation on a Green and Digital Shipping Corridor, with India positioned as a potential alternative-marine-fuel production and export base and Singapore as the primary bunkering hub. By 2025, Singapore had established 9 Green and Digital Shipping Corridors, supported by the Maritime Singapore Green Initiative's additional S$50 million commitment in 2024.


The India–Singapore corridor carries a direct practical implication for Indian operators seeking FuelEU compliance fuel. Singapore's bunkering infrastructure provides a near-term access point for certified biofuel and green methanol supply for EU-bound voyages — because India does not yet have FuelEU-grade certified alternative-marine-fuel supply infrastructure at commercial scale. The contrast with China is instructive: by end-2025, China had approximately 8 million tonnes/year oil-equivalent of green-fuel capacity, including 380,000 t/y of green methanol and 700,000 t/y of green ammonia per the National Energy Administration. India's domestic alternative-fuel production for maritime use remains at an earlier stage of development.


For the broader context of capital flows into maritime and clean-energy infrastructure in India's region, GFJ's New Energy M&A Playbook 2026–2027 provides the investment landscape analysis.

The GFJ Biofuels & Feedstocks Hub tracks feedstock availability and pricing developments that directly affect FuelEU compliance economics for operators sourcing biofuel supply in Asia.


8. Friction, Risk and Systemic Bottlenecks

GFJ Intelligence Brief

Four structural bottlenecks complicate FuelEU Maritime compliance beyond the direct regulatory obligation: overlapping and misaligned regulatory frameworks across FuelEU, EU ETS, UK ETS, and IMO; alternative-fuel supply constraints confirmed by the JRC's January 2026 RFNBO status report; the 2026 EU Ports Strategy's explicit acknowledgement of cargo-diversion risk from EU to non-EU transshipment hubs; and the absence of any authoritative public vessel-level compliance cost dataset for fleet benchmarking.


Regulatory Fragmentation: Four Overlapping Regimes

UNCTAD has argued for a universal regulatory framework for shipping, noting that fragmented rules risk creating a two-speed decarbonisation process. The table below sets out the five regulatory regimes that currently shape maritime carbon compliance and identifies where their logic diverges — creating the overlapping cost obligations that fleet economics models must resolve.

Jurisdiction

Instrument

Status

What It Measures

Key Difference from FuelEU

EU/EEA

Regulation (EU) 2023/1805 — FuelEU Maritime

Mandatory from 2025

Well-to-wake GHG intensity of energy used

Direct fuel-intensity mandate with penalty formula

EU

EU ETS Maritime, Directive (EU) 2023/959

Mandatory since 2024

CO₂ allowances per tonne emitted

Carbon price per tonne; does not offset FuelEU

UK

UK ETS Maritime Provisions

Domestic, from 1 July 2026

CO₂ allowances (domestic voyages and UK ports)

Separate national carbon market; UK-only scope

US

DOT Maritime Energy & Emissions Innovation Action Plan (Dec 2024)

Strategic framework only; SMR initiative launched May 2026

Technology and infrastructure approach

Not a fuel-intensity mandate; US opposed IMO Net-Zero Framework August 2025

China

2026 MoT Green/Low-Carbon Shipping Opinion

National policy framework

Carbon MRV + 15%+ carbon intensity reduction vs 2025 by 2030

National transition framework; no FuelEU-equivalent penalty

IMO

Net-Zero Framework (under development)

Contested; US publicly opposed August 2025

Global GHG intensity target

Not yet adopted; geopolitical fragmentation undermines global coverage

Sources: Regulation (EU) 2023/1805; Directive (EU) 2023/959; UK DfT UK ETS guidance (2026); US DOT Maritime Action Plan (December 2024); US DOE statement on IMO Net-Zero Framework (12 August 2025); China Ministry of Transport (16 April 2026); UNCTAD Review of Maritime Transport 2025.


The UK ETS domestic maritime provision — effective 1 July 2026 — illustrates the practical complexity. UK ports handled 52% of their international tonnage traffic with EU routes in 2025. UK operators on EU-linked routes therefore face EU ETS on the EU side of their voyages, FuelEU Maritime on EU port-call energy, and UK ETS on domestic voyages and UK port operations — three simultaneous carbon-cost obligations in a single fleet economics framework.


Fuel Availability and RFNBO Supply Risk

The JRC's January 2026 RFNBO status report identifies three material barriers to the alternative-fuel supply that FuelEU compliance increasingly requires: limited renewable-hydrogen supply, limited carbon-capture deployment, and high CAPEX and OPEX relative to fossil alternatives. The Commission's own FuelEU Q&A acknowledges that the RFNBO subtarget within the regulation is conditional on whether sufficient production capacity, geographical availability, and reasonable pricing exist. For operators building compliance strategies that rely on e-methanol or other RFNBO-category fuels beyond 2030, supply-chain risk is as commercially material as fuel-price risk. Aviation, road transport, and industrial processes all compete for the same certified sustainable feedstock pools.


Route and Transshipment Distortion

The European Commission's 2026 Ports Strategy — adopted 4 March 2026 — explicitly addresses competitiveness, resilience, and sustainability of European ports in the context of global port competition. The Commission has acknowledged the risk that FuelEU's voyage-energy accounting creates commercial incentives to alter port rotations rather than modify fuel strategies. Under the 50% accounting rule for EU–third-country voyages, a vessel calling a non-EU transshipment hub rather than a direct EU port changes the voyage-energy classification for the onward leg. The Commission adopted specific rules in 2025 identifying neighbouring container transshipment ports within FuelEU scope — a measure designed to close the route-design arbitrage that the accounting structure could otherwise create. The Commission's explicit acknowledgement of this risk in the 2026 Ports Strategy is the beginning of a regulatory review that shipping executives should monitor closely.


"The new European Maritime Transport Environmental Report is a valuable guide for the future of European shipping, one that is both sustainable, competitive and resilient."

— Apostolos Tzitzikostas, European Commissioner for Sustainable Transport and Tourism, 4 February 2025


9. Future Scenarios and Fleet Strategy 2026–2035

GFJ Intelligence Brief

Three strategic scenarios are available to shipping executives managing FuelEU exposure through 2035: absorb near-term penalty costs while maintaining current operations (Scenario A); accelerate biofuel and alternative-fuel adoption with contract restructuring (Scenario B); or pursue structural fleet transformation via newbuilds, retrofit, and supply-chain investment (Scenario C). The 2030 zero-emission berth requirement makes Scenario C unavoidable for container and passenger operators with significant EU port-call exposure — and the order lead time reality means the decision window is 2026–2028.


The three scenarios are not mutually exclusive across a fleet. Many operators will rationally apply Scenario A to vessels nearing end-of-life, Scenario B to mid-age conventional vessels, and Scenario C to newbuilds and vessels with long remaining commercial lives. The critical discipline is applying the correct scenario to the correct vessel cohort — not defaulting to one approach fleet-wide.


[A]  Pay & Manage

  • Fleet profile: Operators with limited EU route exposure, short remaining charter periods, or fleet renewal already planned before 2030.

  • Strategy: Accept penalty costs for non-compliant vessels; use compliance pooling and banking flexibility to reduce net deficit; build FuelEU and EU ETS costs into freight pricing or charter-party adjustments where contractual architecture allows.

  • Economics: The €2,400/tonne VLSFO-equivalent penalty is rational where the biofuel premium plus procurement complexity and vessel incompatibility makes fuel-transition cost genuinely higher than the penalty for a specific vessel in a specific year. The break-even shifts materially when the consecutive non-compliance multiplier begins applying — at 1.2× in year three.

  • Capital implication: Minimal near-term capex. Primary risk is escalating penalty exposure and stranded-asset profile for vessels still active post-2028.


[B]  Transition

  • Fleet profile: Mid-fleet-age operators with significant EU route exposure whose vessels lack alternative-fuel capability but retain 5–10 years of commercial life.

  • Strategy: Increase biofuel blends (HVO/FAME) progressively; negotiate FuelEU allocation clauses into all charter renewals; participate in compliance pooling markets; invest in operational efficiency and speed optimisation.

  • Economics: A biofuel premium of approximately €12/GJ over VLSFO at 2025 CE Delft prices is manageable for operators with strong freight rates or established surcharge mechanisms. Biodiesel prices are projected to reach €37/GJ by 2030 and €50/GJ by 2040 — making blending progressively more expensive as a standalone strategy.

  • Capital implication: Moderate fuel-procurement investment; limited vessel capex. Primary risk is feedstock availability constraints post-2027 as aviation and maritime compete for the same certified biofuel feedstock.


[C]  Structural Transformation

  • Fleet profile: Large operators with high EU route concentration, long fleet planning horizons, and access — or achievable access — to alternative-fuel supply chains.

  • Strategy: Order alternative-fuel newbuilds (methanol dual-fuel, ammonia-ready); retrofit mid-life vessels where investment economics support it; secure long-term bio-methanol or green methanol supply agreements; redesign charter parties to allocate FuelEU costs explicitly; develop OPS capability for 2030 berth compliance.

  • Economics: Bio-methanol approaches fossil-methanol cost parity around 2030 per the 2026 techno-economic study. E-methanol remains expensive at €1,374/t Germany baseline without hydrogen-cost reduction and sustained policy support. Structural transformation is economically rational for fleets where EU route concentration makes sustained biofuel blending plus escalating penalty exposure through 2035 more expensive over a 10–15-year planning horizon.

  • Capital implication: Highest near-term capex. Primary risk is alternative-fuel price volatility and availability uncertainty for e-methanol and green ammonia pre-2030.

The 2030 Zero-Emission Berth Requirement: Why the Decision Window Is Now

Container and passenger ships at major EU ports must comply with zero-emission or OPS requirements at berth from 2030. EU port OPS infrastructure coverage remains materially limited in 2026. Multi-year order lead times for newbuilds mean OPS-compatible vessel decisions must be taken by 2027–2028 at the latest to achieve fleet readiness for 2030. The arithmetic is direct: 2030 is four years away, and vessel production cycles mean the physical assets required must be ordered within the next 24 months.

Year

Key FuelEU Milestone

Strategic Action Required

2026

First penalties payable (30 June); enforcement guidance published (25 June)

Verify 2025 compliance balance; model fleet exposure; audit charter parties

2027

Second compliance year; consecutive multiplier risk builds

Negotiate FuelEU clauses into charter renewals; begin biofuel contracting

2027–2028

Final window for OPS-compatible newbuild orders for 2030 readiness

Newbuild decisions for container and passenger OPS compliance

2030

−6% GHG intensity target; zero-emission berth requirement activates

Full fleet compliance required; OPS-capable vessels at EU ports

2035

−14.5% GHG intensity target

Structural fuel transformation required; biofuel blending alone insufficient

Source: Regulation (EU) 2023/1805; GFJ strategic analysis.


10. Strategic Recommendations

GFJ Intelligence Brief

Immediate priorities in 2026 for all fleet operators: verify the 2025 FuelEU compliance balance; build an integrated FuelEU + EU ETS cost model by vessel; audit all charter parties for FuelEU clause gaps; score fleet exposure using the GFJ Risk Exposure Index; and map container and passenger vessel EU port calls against the 2030 zero-emission berth requirement. Operators who act on these five points in 2026 will face structurally lower compliance costs in 2027–2030 than those who wait.


For Shipowners and Fleet Operators

  • Immediate (2026):

  • Verify your 2025 FuelEU compliance balance and confirm your verifier has received the full FuelEU report. Score your fleet against the GFJ Risk Exposure Index to identify the highest-exposure vessels. Model penalty versus pooling versus biofuel cost for each. Audit all active time charter parties for FuelEU clause gaps — the absence of a BIMCO FuelEU clause is a quantifiable liability.

  • Medium-term (2027–2028):

  • Negotiate FuelEU allocation clauses into all time charter renewals before signing. Secure biofuel supply agreements for the highest-exposure vessels. Develop an OPS readiness roadmap for all container and passenger vessels with regular EU port calls. Formalise a compliance pooling arrangement for the fleet.

  • Long-term (2029–2035):

  • Align the newbuild programme with alternative-fuel capability — methanol dual-fuel or ammonia-ready — for vessels whose commercial life extends through 2035. Build FuelEU compliance history as an explicit vessel asset-value factor in sale and purchase negotiations. Review fleet composition against the −14.5% GHG intensity target in 2035 and identify vessels that cannot reach it cost-effectively.


For Investors and Financiers

Incorporate FuelEU compliance history and projected compliance cost into vessel valuation models from 2026 onwards. A vessel with consecutive compliance deficits carries a quantifiable discount relative to a surplus vessel — the BIMCO MoA clause makes this commercially explicit. Apply the GFJ Risk Exposure Index scores in fleet credit assessment and maritime asset-backed lending. Monitor bio-methanol and green methanol supply chain development — particularly COSCO's green ammonia bunkering programme and the India–Singapore Green Corridor — as forward indicators of alternative-fuel bunkering availability.


For capital allocation frameworks across clean-energy transition assets, GFJ's Corporate PPA 2027 analysis provides the procurement strategy framework relevant to energy-intensive operators managing multiple regulatory cost exposures simultaneously.


For Policymakers and Port Authorities

Accelerate EU port OPS infrastructure deployment. The 2030 zero-emission berth requirement is a policy deadline with a vessel-order lead-time constraint — ports without OPS infrastructure by 2028–2029 create compliance impossibility for operators who have ordered OPS-compatible vessels in good faith. Address the Norway/Iceland EEA incorporation delay definitively, as the third-country-port classification during the gap period created voyage-calculation uncertainty for the 2025 reporting year. Publish standardised FuelEU compliance reporting at fleet-segment level to enable market transparency without requiring disclosure of commercially sensitive penalty data.


The operator who maps FuelEU exposure clearly in 2026, acts on the highest-risk vessel cohort, and restructures charter parties and fuel procurement accordingly will spend materially less on compliance in 2030 than the operator who waits for the regulation to force the decision.


11. Executive FAQ


What is FuelEU Maritime and which ships are subject to it in 2026?

Regulation (EU) 2023/1805 applies to any vessel above 5,000 GT calling a port in the EU or EEA, regardless of flag or nationality of ownership, from 1 January 2025. It covers 100% of energy used on intra-EU voyages, 50% on voyages between EU/EEA and third-country ports, and 100% of energy used at berth. The 2025 reporting year is the first subject to formal verification in 2026, with penalties payable by 30 June 2026 for unresolved compliance deficits.


How is the FuelEU Maritime penalty calculated and how much does it cost?

The GHG-intensity non-compliance penalty is: |compliance balance| ÷ (GHG intensity actual × 41,000) × €2,400, where €2,400 represents the penalty per equivalent tonne of VLSFO. The berth non-compliance penalty is €1.50 × total electrical power demand at berth × hours of non-compliance. Repeated non-compliance triggers a multiplier of 1 + (n−1)/10 for each consecutive non-compliant reporting period — reaching 1.2× in year three and 1.4× in year five.


Is paying the FuelEU Maritime penalty cheaper than buying compliant fuel or using pooling?

The answer is vessel-specific: it depends on voyage mix, fuel type, EU route share, EU ETS exposure, and charter structure. At 2025 CE Delft projections, biodiesel costs €31/GJ against VLSFO at €19/GJ — a €12/GJ premium that for many vessels is lower than the annualised penalty cost. Pooling prices are privately negotiated with no regulated floor. The consecutive penalty multiplier escalates the cost of sustained non-compliance with each successive year, making the penalty a rational short-term choice only for vessels with limited remaining commercial life.


Which types of shipping companies face the highest FuelEU Maritime compliance cost risk?

The highest-risk structural profile combines: frequent EU port calls, conventional VLSFO or HFO propulsion without alternative-fuel capability, no OPS readiness for the 2030 berth requirement, and no FuelEU charter-party allocation clause in active contracts. Time-chartered fleets where the charterer controls fuel selection but the owner holds regulatory liability carry an additional governance risk layer. No authoritative public dataset currently identifies individual companies' compliance deficits — the GFJ Risk Exposure Index provides the structural framework for self-assessment.


How does FuelEU Maritime interact with the EU ETS, and what is the combined cost impact?

EU ETS maritime obligations have applied since 2024 and price carbon allowances per tonne of CO₂ emitted. FuelEU measures the well-to-wake GHG intensity of fuel used — a different metric that does not directly offset EU ETS liability. CE Delft projects the weighted average maritime fuel cost rising from €20/GJ in 2025 to €34/GJ in 2040 under a policy scenario that captures both FuelEU and EU ETS cost pressure. Optimising solely for FuelEU without modelling EU ETS interaction produces a materially incomplete compliance cost picture.


What should shipping executives prioritise in 2026 to reduce FuelEU Maritime compliance costs?

Five priorities in order: verify the 2025 FuelEU compliance balance and confirm the report has been submitted to your verifier; build an integrated FuelEU + EU ETS cost model by vessel; audit all active charter parties for FuelEU clause gaps against BIMCO's current clause architecture; score your fleet against the GFJ Risk Exposure Index to identify where compliance investment produces the highest risk-reduction return; and map all container and passenger vessel EU port calls against the 2030 zero-emission berth requirement, given that newbuild order lead times mean the decision window closes within the next 24 months.


Scope & Disclaimer

This report is provided for strategic research and informational purposes only. It does not constitute legal, financial, investment, engineering, or safety-certification advice. Nothing in this report should be relied upon as the basis for any commercial or regulatory decision without independent professional verification. No company referenced in this report is endorsed by Green Fuel Journal. Company-claimed figures are labelled as such where applicable. Regulatory information reflects sources available at the time of research and may be subject to change.


References & Strategic Sources


This report is backed by authoritative research, institutional analysis, industry intelligence, and strategic data sources.


© 2026 Green Fuel Journal. All rights reserved.

Published by Sekason Research Limited (Company No. 14339910), registered in England and Wales.

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