DECISION BRIEF
What the rule requires
Directive 2003/87/EC, as amended by Directive (EU) 2023/959, extended the EU emissions trading system to maritime transport and created a separate system, ETS2, for fuels supplied to buildings, road transport and small industry.
Free allocation to EU industry is being phased out in step with CBAM, which is why the Commission’s current proposals on the post-2030 cap, aviation and the extension of free permits matter to exporters as well as to EU operators. Those proposals are tracked in the coverage below.
Who is affected, and from when
Built for: Shipping and logistics operators, exporters shipping into EU ports, and anyone modelling the cost of EU carbon in a supply chain or a fuel bill.
Shipping companies operating ships of 5,000 gross tonnage and above that call at EU ports are covered regardless of flag: 100% of emissions on voyages between two EU ports and at berth in an EU port, and 50% of emissions on voyages starting or ending outside the EU.
They must submit verified emissions reports through THETIS MRV by 31 March each year and to their assigned administering authority, hold a document of compliance by 30 June, and surrender allowances for 40% of emissions reported for 2024, 70% for 2025 and 100% for 2026 onwards — the first full surrender falls due in 2027. Methane and nitrous oxide are added to the maritime scope from 2026.
ETS2 covers fuel suppliers rather than fuel users. Regulated entities were required to hold a greenhouse gas emissions permit by 1 January 2025 and to submit annual emissions reports by 30 April; the start of trading was postponed by one year to 2028. Turkish companies are reached through the fuel prices their EU operations and EU customers pay.
What to do next
- Check whether any group company operates ships of 5,000 GT or above calling at EU ports — the obligation follows the shipping company, not the flag or the owner.
- Reconcile THETIS MRV figures with your corporate GHG inventory before an auditor does it for you; they are built on different boundaries and rarely agree at first.
- Model the surrender ramp explicitly: 40% for 2024, 70% for 2025, 100% from 2026 emissions onwards, plus methane and nitrous oxide from 2026.
- Track the ETS revision as a CBAM input. The pace at which free allocation ends sets the CBAM factor that Turkish exporters ultimately pay through their EU customers.
Coverage boundary
Türkiye’s national ETS has its own hub, and this page does not cover UK ETS or voluntary markets.