Shipping now answers to three overlapping decarbonization regimes, FuelEU Maritime, the EU ETS, and a stalled IMO framework, each treating biomethane differently. The fuel is shipping's most readily available decarbonization tool today. But the infrastructure to certify and trade it is lagging badly behind the incentives built to reward it. That gap is now the central risk facing fleet operators.
Three regimes, one fuel, three different rulebooks
| FuelEU Maritime | EU ETS (Maritime) | IMO Net-Zero Framework | |
|---|---|---|---|
| Type | GHG intensity mandate (well-to-wake) | Carbon pricing (cap-and-trade) | Global GHG intensity target + levy |
| Scope | Ships ≥5,000 GT calling at EU/EEA ports | Ships ≥5,000 GT calling at EU ports | All international shipping, once adopted |
| Status | In force since Jan 2025; 2% GHG cut required in 2025–26, rising to 80% by 2050 | Fully phased in from Jan 2026; CH₄ and N₂O now included alongside CO₂ | Approved April 2025, but adoption postponed a year after US-led opposition; talks resume in 2026 |
| Biomethane / bioLNG treatment | Rewarded on lifecycle basis - GHG savings up to 206% let LNG-fuelled ships over-comply | RED-compliant biofuels get zero CO₂ rating, but methane slip cannot be zero-rated | Would reward zero/near-zero fuels; risk of biofuels being treated as merely "transitional" |
| Certification bar | Uncertified fuel defaults to fossil emission factor - counts as fossil | Must meet RED sustainability criteria | Still being finalized |
| Compliance flexibility | Surplus compliance can be pooled and sold to under-compliant peers | Standard EU Allowance trading | Fund-based, redistributive |
The asymmetry matters: FuelEU is generous to biomethane, ETS is stingier on methane slip, and the IMO - meant to unify global rules - is on pause. Operators are optimizing for two EU regimes with no certainty about what a global standard will eventually demand.
Inside the EU: the subsidy question is settled, supply isn't
The Commission confirmed in July 2025 that subsidised biomethane counts toward FuelEU compliance, closing a year of market uncertainty. But that clarity has pulled shipping into direct competition with domestic heating and industrial obligations for the same limited pool of gas, most 2026 Dutch and Danish supply was committed to maritime before the year even began.
Outside the EU: the barrier isn't subsidy, it's traceability
Beyond EU borders, the constraint flips entirely. The EU's Union Database is set to exclude sustainability certification for biomethane produced in third-country gas grids over mass-balance integrity concerns, putting supply from the US, Japan, Canada, and Australia at risk of exclusion from compliance markets even when it meets every technical threshold. Industry coalitions representing over 45 signatories have warned this will function as a de facto trade barrier just as demand accelerates.
The message for shipping companies
Certification failure is a silent compliance killer, uncertified fuel defaults to fossil status, meaning an operator can believe they're compliant and be wrong. National rules can also override EU-wide eligibility, as the Netherlands' exclusion of UCOME from maritime compliance shows. The response is straightforward: demand independently verified certification on every cargo, lock in multi-year offtake rather than relying on a tightening spot market, map feedstock eligibility jurisdiction by jurisdiction, and use pooling mechanisms proactively rather than defensively. Build compliance strategy around the stricter of the two EU regimes, don't wait for the IMO.
The message for regulators
The policy signal is right; the plumbing isn't ready. A biomethane cargo that is environmentally sound but administratively invisible delivers no decarbonization value at all. Finalizing third-country equivalency under the Union Database, and aligning FuelEU and ETS treatment of methane slip, is now more urgent to the pace of maritime decarbonization than any new target. Fuel that cannot be traced cannot be trusted, and fuel that cannot be trusted will not scale.
As certification and traceability rules keep shifting across FuelEU, ETS, and the IMO, staying ahead means knowing exactly what's moving and what it means. That's where Vessel Tracker and Wood Mackenzie's consulting team come in.
