Nine active compliance frameworks — EU ETS, FuelEU Maritime, IMO CII, IMO DCS, BOG Guarantee, Sea Cargo Charter, IMO GFS 2028, biofuel pathway modelling, and US EPA/CARB — calculated from your existing voyage data. No separate entry. Output formatted for submission or verifier review.
EU ETS (MARPOL Annex VI / EU Regulation 2023/957) requires vessel operators to surrender European Union Allowances for every voyage leg starting or ending in an EU/EEA port. At ~€65/tCO₂e, a 140,000 cbm LNG carrier on a Qatar-to-Europe trade carries €2.0–2.8M in annual EUA liability. Missed year-end surrender incurs a €100 penalty per unredeemed allowance plus a carry-forward obligation. UK ETS applies to UK port calls with separate GBP-denominated allowances and its own surrender schedule. CH₄ slip is priced from 1 January 2026 at GWP-28 under EU ETS — XDF engines are disproportionately exposed.
FuelEU Maritime (EU Regulation 2023/1805) sets a Well-to-Wake GHG intensity limit for all vessels calling EU ports from 1 January 2025, tightening at each five-year checkpoint to 2050. Non-compliance carries a penalty of €2,400 per tonne CO₂e of deficit. For an LNG carrier on European trades at 80% load factor, a single non-compliant year can generate €400K–1.2M in penalties depending on voyage mix and fuel pathway. The platform calculates your GHG intensity score from each voyage logged, shows your annual compliance position in real time, and identifies which regulatory period your current fuel mix will breach first.
The Carbon Intensity Indicator (MEPC.338(76)) grades every vessel A through E on annual carbon intensity. A vessel rated D or E for three consecutive years triggers a mandatory corrective action plan. Charter parties increasingly include CII warranty clauses — a D or E rating can expose operators to hire adjustments and charter party disputes during annual review. Chartering managers and class surveyors examine CII trajectories before fixing or surveying vessels. VEMO FuelIQ recalculates your grade after every voyage logged and projects your year-end position at all times, so there are no surprises in Q4.
IMO DCS (MARPOL Annex VI, Regulation 22A) requires annual fuel oil consumption reporting to flag states for all vessels above 5,000 GT. EU MRV (Regulation 2015/757) requires third-party verified emissions data for all EU port calls, with a submission deadline of 31 May each year. Failure to submit or submission errors result in detention risk at port state control. For EU MRV, a missing Verification Statement prohibits the vessel from operating in EU waters. VEMO FuelIQ compiles both reports from existing voyage data — no separate data entry, no transcription risk.
BOG guarantee clauses are standard in LNGC time charter parties, defining the contractual BOG rate for each laden and ballast leg — typically 0.10–0.15%/day on cargo capacity. If actual BOG exceeds the guarantee, charterers can claim a financial adjustment per voyage. On a 25-day laden leg, a 0.02%/day overrun on a 138,000 cbm cargo at current LNG prices is approximately $80,000–120,000 in potential claim exposure. VEMO FuelIQ tracks actual versus guaranteed BOG per voyage leg and alerts operators when variance approaches the threshold — before the charterer raises the claim.
The Sea Cargo Charter is voluntary in name but commercially enforced — 50+ major charterers including Cargill, Trafigura, Shell, BP, and Vitol are signatories who require annual carbon intensity disclosure before placing cargo. Vessels reported as "Misaligned" may face rate adjustments or exclusion from fixtures with signatory charterers. SCC alignment is now a standard pre-fixture due diligence item alongside CII grade. The same dataset simultaneously satisfies Poseidon Principles reporting for $185B in ship finance across 29 member banks — no separate data entry required beyond what is already logged for IMO CII.
| Charterer | Framework | Status |
|---|---|---|
| Cargill | Sea Cargo Charter | Signatory |
| Trafigura | Sea Cargo Charter | Signatory |
| Louis Dreyfus | Sea Cargo Charter | Signatory |
| Shell | Sea Cargo Charter | Signatory |
| BP | Sea Cargo Charter | Signatory |
| Vitol | Sea Cargo Charter | Signatory |
VEMO FuelIQ produces the Sea Cargo Charter annual report as a one-click CSV export from existing voyage data — no additional logging required.
The IMO Net Zero Framework (MEPC 83, April 2025) is the first mandatory carbon pricing mechanism at IMO level. Vessels above 5,000 GT with fuel intensity above the base GFI tier contribute financially to the IMO Net Zero Fund at $380/tCO₂e deficit from 2028. LNG (fossil) is compliant under the 2028 base tier — but the trajectory tightens at each five-year checkpoint. Owners and chartering managers are already requesting GFS 2028 impact assessments for newbuilding decisions and charter party negotiations. VEMO FuelIQ tracks your GFI position from existing voyage fuel data and shows levy exposure in dollar terms per voyage.
| Fuel Type | GFS 2028 Base Tier | Outlook |
|---|---|---|
| LNG (fossil) | ✓ Compliant | Compliant through first reduction checkpoint |
| VLSFO | ✗ Levy applies | Levy from day one in 2028 |
| HFO | ✗ Levy applies | Levy from day one in 2028 |
| Bio-LNG (waste pathway) | ✓ Full surplus | Significant compliance margin |
| e-Methane (RFNBO) | ✓ Full surplus | Maximum compliance surplus |
| Green hydrogen | ✓ Full surplus | Maximum compliance surplus |
LNG operators start from a better position than HFO and VLSFO fleets under GFS 2028. VEMO FuelIQ shows the levy exposure per vessel in dollar terms per voyage. Emission factors and methodology basis available in the Methodology Reference.
Bio-LNG and e-methane purchases carry a premium over fossil LNG — typically $200–400/tonne for bio-LNG on spot market. Before committing to bunkering, operators need to know exactly how many tonnes of bio blend are needed to avoid FuelEU penalties, and whether the bio-LNG premium is cheaper than the €2,400/tCO₂e penalty cost. VEMO FuelIQ models any fossil/bio blend scenario against your FuelEU annual position, GFS 2028 levy exposure, and Sea Cargo Charter alignment simultaneously — so the bunkering decision is based on compliance arithmetic, not estimates.
WtW emission factors and methodology basis available in the Methodology Reference.
The North American ECA (40 CFR Part 1042) applies NOx Tier III limits within 200 nautical miles of the US coastline for engines with a build date from 2016. California's CARB OGV Regulation adds a 24-nautical mile sulphur restriction and shore power requirements at Los Angeles, Long Beach, Oakland and other major California ports. Non-compliance at port state control inspection is a detention trigger. CARB violations carry penalties up to $10,000/day. LNG vessels running Otto-cycle engines are automatically compliant with both NOx Tier III and CARB SOx limits — the flag is informational for vessels with mixed fuel capability or high-pressure MEGI engines.
| Fuel | NOx Tier III (ECA) | CARB SOx (24nm) |
|---|---|---|
| LNG (Otto-cycle) | ✓ Auto-compliant | ✓ 0.0% sulphur |
| LNG (MEGI high-pressure) | SCR may be needed | ✓ 0.0% sulphur |
| LSMGO / MDO | Engine-dependent | ✓ 0.1% sulphur |
| VLSFO | Engine-dependent | ✗ 0.5% — switch fuel |
| HFO | ✗ Non-compliant | ✗ 2.5% — prohibited |
LNG is the only fuel that is automatically compliant with every US ECA requirement — NOx, SOx, and CARB — with no switching, scrubber, or SCR required.
Request a demonstration using a real LNG voyage scenario. We will walk through the compliance frameworks relevant to your fleet — EU ETS, FuelEU, CII, BOG guarantee, and Sea Cargo Charter. A 30-minute session is sufficient to assess fit for your operations and reporting obligations.
Every major maritime compliance obligation handled automatically from your voyage data. Click any regulation to see what it means, what it costs, and how VEMO solves it.
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