On September 30, 2026, shipping companies administered by the Dutch Emissions Authority (Nederlandse Emissieautoriteit, NEa) must surrender EU allowances covering 70% of their verified 2025 CO2 maritime emissions to their Union Registry account, the second step of the EU ETS maritime phase-in set by Directive 2003/87/EC as amended by Directive (EU) 2023/959. The obligation applies to ships of 5000 GT and above performing commercial voyages to and from EU ports, implemented in the Netherlands through Titel 16.2 of the Wet milieubeheer (Wm).
EU shipping companies operating covered vessels, including chemical tanker and parcel tanker operators calling at Rotterdam and Amsterdam, must surrender allowances equal to 70% of verified 2025 emissions by September 30, 2026, or pay the excess-emissions penalty of EUR 100 per tonne (inflation-indexed, Article 18 of Directive 2003/87/EC) for each missing allowance plus the continuing duty to surrender, enforced by the NEa under Wm Titel 16.2.
- Deadline : September 30, 2026, the second maritime allowance surrender and the 70% phase-in step for FY 2025 emissions
- Who : shipping companies with vessels of 5000 GT and above on commercial voyages to or from EU ports, administered by the NEa
- What : surrender EU allowances equal to 70% of verified 2025 CO2 maritime emissions to the Union Registry account
- Otherwise : EUR 100 per tonne excess-emissions penalty (inflation-indexed) per missing allowance, plus the continuing surrender duty, enforced by the NEa
- Official source : Directive 2003/87/EC (EU ETS), EUR-Lex
What applies on September 30, 2026
On September 30, 2026, the second EU ETS maritime surrender falls due: every covered shipping company must surrender EU allowances equal to 70% of the verified CO2 emissions its ships reported for 2025, up from the 40% share that applied to 2024 emissions (surrenderable by 30 September 2025). The phase-in reaches 100% for 2027 emissions, surrenderable by 30 September 2028, as the EU ETS Directive requires and the NEa confirmed in April 2026 when it reported compliance rising from 71% for 2024 emissions to 84% for 2025 emissions.
| Reporting year | Share to surrender | Surrender deadline |
|---|---|---|
| 2024 | 40% | 30 September 2025 |
| 2025 | 70% | 30 September 2026 |
| 2027 onwards | 100% | 30 September of the following year |
Who is covered
The obligation covers ships of 5000 GT and above performing commercial voyages to, from or between EU ports, under the "shipping company" definition in Directive 2003/87/EC. For bareboat-chartered or time-chartered vessels, the responsible shipping company is the entity that operates the ship, not necessarily the registered owner, so chemicals producers running their own chemical carriers and operators of chartered tonnage carry the surrender duty directly.
By market exposure the covered actors include EU shipping companies on covered routes, Dutch shipowners and operators administered by the NEa and calling at Rotterdam and Amsterdam, and the chemical tanker and parcel tanker segment that moves chemicals into EU ports. The NEa supervises companies administered in the Netherlands; shipping companies administered in another member state answer to their own competent authority but owe the same surrender on the same date.
What to do before September 30, 2026
- Confirm the verified 2025 CO2 emissions figure for every covered vessel from the approved monitoring plan and verification report.
- Calculate 70% of verified 2025 emissions and check that the Union Registry account holds enough EU allowances to cover that quantity.
- Acquire any shortfall of allowances, through auctioning or the secondary market, in time for settlement before September 30, 2026.
- Surrender the allowances through the Union Registry account and keep the transaction record for the NEa compliance file.
- For chartered vessels, confirm which party is the shipping company under the charter party and that the surrender responsibility is contractually allocated.
What happens otherwise
A shipping company that fails to surrender enough allowances by September 30, 2026 incurs the EU ETS excess-emissions penalty under Article 18 of Directive 2003/87/EC, set at EUR 100 per tonne of CO2 and inflation-indexed, for each allowance not surrendered, on top of the continuing obligation to surrender the missing allowances. The NEa enforces the regime under Wm Titel 16.2 for companies administered in the Netherlands, through administrative penalties and recovery under Dutch environmental law.
Continuous, per-jurisdiction real-time monitoring surfaces this kind of deadline the moment the regulator publishes guidance, so compliance teams see the surrender date while there is still time to act.
Follow this topic in real time with a free monitoring job
