Ship CII Rating, EU ETS and FuelEU Cost 2026–2030

Forecast ship CII ratings, EU ETS allowance costs and FuelEU GHG penalties through 2030. Dated rules, separate reporting and surrender years, and annual rating boundaries.

#CII #EU ETS #FuelEU Maritime #MARPOL Annex VI #MEPC.400(83) #Ship emissions

Use this CII rating calculator to compare a ship’s operational carbon intensity with the IMO limits for 2026–2030, then estimate EU ETS allowance costs and FuelEU Maritime GHG penalties alongside it. It is intended for marine engineers, ship operators, students and analysts preparing an annual compliance budget or testing a decarbonisation trajectory. The EU cost estimate supports ordinary bulk carriers, tankers and container ships on commercial service above 5,000 GT. Statutory CII ratings require separate applicability under MARPOL Annex VI regulation 28.

First select CII applicability. Regulation 19 excludes ships sailing solely in their own flag State’s waters and exempts Polar Code category A ships from CII. Excluded ships receive N/A ratings and no regulatory corrective-action warning; numerical CII curves remain reference benchmarks. Domestic flag-state requirements may still apply. EU scope is assessed independently.

Start with the 2026 inventories. Enter certified summer deadweight and worldwide annual CO₂ and distance for a basic attained CII. Distance is entered as a length: multiply nautical miles by 1.852 to obtain kilometres. The metric/US switch converts the physical inputs; CII itself retains its regulatory g CO₂/(t·NM) convention. If voyage adjustments or capacity corrections apply, select the verified corrected CII option instead. An annual percentage reduction projects attained CII forward without assuming that a CII improvement automatically delivers an equivalent FuelEU benefit.

The EU ETS shipping cost calculation takes covered CO₂, methane and nitrous oxide separately. Apply geographical coverage and applicable exemptions before entering these totals. Ordinary scope is 100% of intra-EEA and port emissions and 50% of extra-EEA voyage emissions. The forecast includes all three gases from 2026 emissions and uses your chosen EUR/EUA scenario price. Reporting and surrender years are deliberately visible: the 2026 surrender bill covers 70% of the separate 2025 CO₂ inventory, while 2026 emissions require 100% surrender in 2027.

For the FuelEU penalty calculator, enter scoped annual energy and the achieved well-to-wake GHG intensity from the FuelEU assessment. These are different quantities from ETS emissions. Energy efficiency reduces the amount exposed to a penalty; lower lifecycle intensity reduces the intensity gap itself. The GHG limit is 89.3368 g CO₂e/MJ through 2029 and 85.6904 in 2030. The tool applies the statutory energy-equivalent penalty and the linear increase for consecutive penalty years, resetting the count after a compliant year.

Read the annual tables and curves together: the same attained CII can receive a worse rating as the required CII falls. Costs are reporting-year exposures settled in the following year, with the legacy 2026 ETS surrender shown separately. They exclude fuel purchases, pooling prices, banking, borrowing and shore-power port-call penalties.

Rules were checked on 29 October 2026. The IMO Net-Zero Framework remains outside this estimate; its resumed extraordinary session is scheduled for 4 December 2026, subject to MEPC 85 confirmation. Recheck the instruments in force before using the forecast for a compliance submission.

How it is calculated

Dated rule set — checked 29 October 2026

CII applicability: MARPOL Annex VI regulations 19 and 28 (MEPC.328(76), adopted 17 June 2021; attached s13 pp.34–35 and 45) determine whether a statutory CII rating applies. The applicability selector controls regulatory ratings and corrective-action advice. Where excluded, ratings are N/A and the displayed curves and numerical CII values are reference benchmarks only; no statutory corrective-action warning is issued.

CII: MEPC.352–355(78), adopted 10 June 2022, with reduction factors amended by MEPC.400(83), adopted 11 April 2025. For the basic AER method, CIIatt=MCO2,g/(DWTtDNM)CII_{att}=M_{CO_2,g}/(DWT_t D_{NM}). One international nautical mile is exactly 1,852 m; the distance input is a convertible length. Normalising grams, tonnes and nautical miles gives the conventional regulatory index displayed as g CO₂/(t·NM).

The reference line is CIIref=aC−cCII_{ref}=a C^{-c}. The ship-type coefficients and four rating multipliers come from attached s4 p.5 and s5 p.7. Bulk-carrier reference capacity is capped at 279,000 t; actual DWT stays in the attained-CII denominator. Required CII is (1−Z/100)CIIref(1-Z/100)CII_{ref}, with Z = 11%, 13.625%, 16.250%, 18.875%, 21.500% in 2026–2030 (s1 p.3). Multiply each year's required CII by the four ship-type multipliers for the A/B, B/C, C/D and D/E boundaries. Lower attained CII is better. Numerical equality takes the better band; this is an explicit boundary convention. The 2030 improvement result is the extra proportional cut from the projected 2030 attained CII to its C/D boundary.

ETS: Directive (EU) 2023/959, adopted 10 May 2023, and Commission ETS/MRV guidance dated 18 November 2025 (s7 pp.19–20, 45). Covered tonnes CO₂e = CO₂ + 28 CH₄ + 265 N₂O. Methane and N₂O enter ETS from the 2026 emissions year. Phase-in is 100% of emissions from 2026, surrendered by 30 September of the next year. Cost = unrounded planning EUAs × user price. The separate 2026 surrender bill is 0.70 × covered 2025 CO₂ × price; 2025 methane and N₂O are excluded. Quantities are shown before registry rounding and company aggregation.

FuelEU: Regulation (EU) 2023/1805, adopted 13 September 2023, applicable from 1 January 2025. Article 4 sets the 91.16 g CO₂e/MJ reference and 2% reduction through 2029, then 6% from 2030. With scoped Annex IV energy E in MJ and achieved intensity G, compliance balance CB=(Glimit−G)ECB=(G_{limit}-G)E. A negative CB is a deficit. Annex IV B gives P0=2400(−CB)/(G 41000)P_0=2400(-CB)/(G\,41000) EUR for a deficit, otherwise zero. The denominator is the ship's actual G, not the reference or target intensity. The 41,000 MJ/t and EUR 2,400/t energy-equivalent constants are from Annex IV. Article 23(2) applies P=P0[1+(n−1)/10]P=P_0[1+(n-1)/10] for n consecutive penalty reporting years. This is a linear surcharge, not compounded interest. Zero energy or zero achieved intensity gives no GHG penalty and resets the counter.

Annual percentage changes are compounded from 2026 independently for attained CII, covered ETS gas masses, FuelEU scoped energy and FuelEU achieved GHG intensity. All resulting steps remain visible so each inventory and conversion can be followed.

Assumptions

  • The combined EU cost estimate assumes an ordinary bulk carrier, tanker or container ship on commercial service above 5,000 GT, with mechanical propulsion. GT is a dimensionless size index, separate from DWT. This size/type screen alone does not establish CII applicability.
  • A statutory CII rating is assigned only when the ship is subject to MARPOL Annex VI regulation 28. Regulation 19.2.1 excludes voyages solely within waters under the sovereignty or jurisdiction of the ship's own flag State; regulation 19.3 exempts Polar Code category A ships from regulation 28. Select the appropriate exclusion, or other non-applicability, before interpreting results. Domestic flag-state requirements may still apply and are not modelled here.
  • Basic CII includes all annual CO₂ and distance without G5 corrections. For ice, voyage exclusions, cargo equipment, shuttle/STS or other corrections under MEPC.355(78), as amended, enter a verified corrected attained CII. The tool does not determine eligibility or reconstruct those corrections.
  • ETS gas masses are already geographically covered and adjusted for exemptions or eligible zero-rating, but not phase-in. FuelEU energy is separately scoped under its own rules. Do not apply a second 50% factor after entering covered totals. FuelEU and ETS geographical scope can differ.
  • The FuelEU input is the achieved Annex I intensity and Annex IV compliance energy after eligible rewards and adjustments. The RFNBO-weighted intensity denominator need not equal the compliance-energy total. Fuel pathways, fuel certification, methane slip and reward eligibility are assessed outside this tool.
  • No pooling, banking, borrowing, sale of surplus, fuel premium, capex, transaction fee, interest or shore-power non-compliance penalty is included. A positive FuelEU balance has zero penalty, not an assumed cash credit.
  • The 2025 penalty-history switch means an actual residual GHG deficit/penalty after any 2025 flexibility mechanisms. Subsequent forecast years apply no flexibility mechanisms.
  • Defaults are an illustrative 62,000 t DWT vessel and inventory, not a named ship. EUR 80/EUA is a user planning assumption as of 29 October 2026, not a sourced spot price. Price is constant in nominal EUR; no discounting is applied.
  • Forecasts share a fixed ship type and DWT. Independent percentage trends represent scenarios, not a physical fuel-switch or propulsion model.

Where it applies

Valid for reporting years 2026–2030 and the three stated ship types, within the input ranges. Check against the regulations and guidance in force, the ship's verified records and the administering authority's interpretation before submission.

Statutory CII ratings and corrective-action advice are restricted to ships subject to regulation 28 after applying regulation 19. Own-flag-state-waters-only ships and Polar Code category A ships must use an excluded applicability option. They receive N/A ratings and no regulatory corrective-action warning; any remaining numerical CII curves or boundaries are non-regulatory benchmarks. Regulation 19.2.1 anticipates appropriate domestic measures, so check flag-state requirements separately. Non-mechanically propelled ships and platforms are also excluded from chapter 4 and outside this combined tool's operating assumptions. ETS and FuelEU applicability is independent of this MARPOL selection.

CII is a supply-based annual indicator, not EEOI or actual cargo efficiency. For applicable ships, a single E or three consecutive D ratings triggers corrective-action planning; this calculator does not reconstruct pre-2026 rating history. It does not certify compliance, select exemptions or calculate G5 adjustments. Self-unloading bulk carriers, LNG/gas carriers, ro-ro and passenger ships are outside the coefficient set.

ETS totals are cost exposures, not a registry instruction: aggregate and round at company level as required. Main cost charts use the emissions/reporting year and settle in the next year, so 2030 exposure includes settlement in 2031. The separate calendar-year ETS table stops at 2030.

FuelEU results cover only the GHG-intensity penalty before flexibility mechanisms. Container ships also face shore-power requirements from 2030 in relevant ports; assess Article 6 obligations and port-call penalties separately. All-electric or zero-intensity scenarios return no GHG penalty.

FuelEU scope in Norway and Iceland was still delayed in the Commission notice dated 18 December 2025; verify incorporation status and future route exemptions when preparing scoped inventories. No fixed country-membership assumption is embedded in this calculator.

Regulatory snapshot: 29 October 2026. The IMO Net-Zero Framework is not included as an adopted cost regime. IMO's MEPC 84 outcome schedules the resumed extraordinary session for 4 December 2026, subject to confirmation by MEPC 85. Future amendments, review outcomes and market prices may change these scenarios.

References

  • IMO MEPC.352(78), CII G1, adopted 10 June 2022, attached s3 pp.5–6: https://wwwcdn.imo.org/localresources/en/KnowledgeCentre/IndexofIMOResolutions/MEPCDocuments/MEPC.352%2878%29.pdf
  • IMO MEPC.353(78), CII G2 reference lines, adopted 10 June 2022, attached s4 p.5: https://wwwcdn.imo.org/localresources/en/KnowledgeCentre/IndexofIMOResolutions/MEPCDocuments/MEPC.353%2878%29.pdf
  • IMO MEPC.354(78), CII G4 rating boundaries, adopted 10 June 2022, attached s5 p.7: https://wwwcdn.imo.org/localresources/en/KnowledgeCentre/IndexofIMOResolutions/MEPCDocuments/MEPC.354%2878%29.pdf
  • IMO MEPC.355(78), CII G5 corrections (eligibility assessed externally), adopted 10 June 2022, attached s6: https://wwwcdn.imo.org/localresources/en/KnowledgeCentre/IndexofIMOResolutions/MEPCDocuments/MEPC.355%2878%29.pdf
  • IMO MEPC.400(83), adopted 11 April 2025, Annex 4 Table 1, attached s1 p.3: https://wwwcdn.imo.org/localresources/en/KnowledgeCentre/IndexofIMOResolutions/MEPCDocuments/MEPC.400%2883%29.pdf
  • ClassNK, CII worked example and reduction trajectory, attached s2 pp.14–15: https://www.classnk.com/hp/pdf/activities/statutory/seemp/CII_en.pdf
  • Directive (EU) 2023/959, 10 May 2023, maritime ETS phase-in and scope: https://eur-lex.europa.eu/eli/dir/2023/959/oj/eng
  • European Commission, ETS and MRV Maritime general guidance, 18 November 2025, attached s7 pp.19–20 and 45: https://climate.ec.europa.eu/document/download/31875b4f-39b9-4cde-a4e2-fbb8f65ee703_en?filename=policy_transport_shipping_gd1_maritime_en.pdf
  • Regulation (EU) 2023/1805, 13 September 2023, Articles 4 and 23(2), Annex IV: https://eur-lex.europa.eu/eli/reg/2023/1805/oj/eng
  • European Commission FuelEU Q&A, Articles 4, 20–23, accessed 29 October 2026: https://transport.ec.europa.eu/transport-modes/maritime/decarbonising-maritime-transport-fueleu-maritime/questions-and-answers-regulation-eu-20231805-use-renewable-and-low-carbon-fuels-maritime-transport_en
  • BetterSea, Case Study VIII, 2025 HFO baseline: https://www.bettersea.tech/post/onshore-power-supply-under-fueleu-maritime-and-eu-ets
  • IMO MEPC 84 outcomes, 27 April–1 May 2026, Net-Zero Framework status: https://www.imo.org/en/mediacentre/meetingsummaries/pages/temporary-mepc-84th-session.aspx
  • European Commission FuelEU page, Norway/Iceland delay notice dated 18 December 2025, accessed 29 October 2026: https://transport.ec.europa.eu/transport-modes/maritime/decarbonising-maritime-transport-fueleu-maritime_en
  • MARPOL Annex VI regulations 19.2.1, 19.3 and 28, MEPC.328(76), adopted 17 June 2021, attached s13 pp.34–35 and 45: https://wwwcdn.imo.org/localresources/en/KnowledgeCentre/IndexofIMOResolutions/MEPCDocuments/MEPC.328%2876%29.pdf

Inputs

InputSymbolUnitDefault
Reporting year for result cards
All forecasts start from the 2026 inventory. ETS surrender and FuelEU payment follow in the next calendar year.
yr_sel2026
CII ship type
Ordinary bulk carriers, tankers and container ships only. Self-unloading bulk carriers and other ship types need different provisions.
vesselBulk carrier
Gross tonnage (GT)
Gross tonnage is a dimensionless vessel-size index, not a mass. This combined calculator assumes a commercial ship above 5,000 GT.
gross_tonnage33000
Summer deadweight (DWT)
Use certified deadweight, not cargo carried. Applicability requires a commercial ship above 5,000 GT; GT is not DWT.
capacityt62000
CII applicability under MARPOL
Confirm applicability with the flag Administration. Regulation 19 excludes solely own-flag-state waters and exempts Polar Code category A from CII. Domestic requirements can still apply. ETS and FuelEU scope is assessed separately.
cii_scopeSubject to regulation 28
CII inventory methodcii_modeAnnual CO₂ and distance; no G5 corrections
Worldwide annual CO₂
All annual tank-to-wake CO₂ for the CII inventory, including port use. This is separate from ETS covered CO₂.
co2_worldt16500
Annual distance over ground
Enter the full annual distance as a length: 60,045 NM = 111,203.34 km. Supported range: 1–555,600 km. The metric/US switch converts the length; CII retains g CO₂/(t·NM).
dist_yearkm111203.34
Verified corrected CII
Enter the regulatory index exactly as verified, including applicable G5 voyage adjustments and capacity corrections. This conventional index keeps its official units.
cii_verifiedg CO₂/(t·NM)4.43
Annual attained CII reduction (%)
Compounded change from 2026; positive reduces CII, negative increases it. This does not automatically alter either EU inventory.
r_cii0
ETS covered CO₂ in 2026
Enter geographical coverage and exemptions already applied, before the annual phase-in. Typically 100% intra-EEA and berth emissions plus 50% extra-EEA voyages. Do not enter all worldwide emissions.
co2_etst12000
ETS covered CH₄ in 2026
Mass of methane, including slip, after geographical scope. Enter CH₄ tonnes, not CO₂ equivalent tonnes.
ch4_etst0.2
ETS covered N₂O in 2026
Mass of nitrous oxide after geographical scope. GWP values are 28 for CH₄ and 265 for N₂O.
n2o_etst0.7
Annual covered gas reduction (%)
The same compounded change is applied to the three covered gas masses. Use a separate run if the gas mix changes.
r_ets0
EUA planning price (EUR/EUA)
User scenario price, not a live market quotation. One EUA covers one tonne CO₂ equivalent. The same price is used in every forecast year.
eua_price80
ETS covered CO₂ from 2025
Separate historical inventory, after geographical coverage and exemptions but before phase-in. 70% is surrendered in 2026; CH₄ and N₂O do not apply to 2025 emissions.
co2_2025t12000
FuelEU scoped energy in 2026
Annual energy after FuelEU geographical weighting and exemptions, including relevant shore electricity. Use the verified Annex IV compliance energy, which may differ from the Annex I intensity denominator.
energy_2026GJ150000
FuelEU achieved WtW GHG intensity
g CO₂ equivalent/MJ of scoped energy. Use the certified FuelEU result including upstream emissions, methane slip and any eligible rewards; do not substitute ETS tank-to-wake intensity.
ghg_2026g/MJ91.7442
Annual scoped energy reduction (%)
Energy efficiency lowers the compliance balance and penalty magnitude but does not by itself lower GHG intensity.
r_energy0
Annual FuelEU intensity reduction (%)
Compounded reduction in achieved lifecycle GHG intensity from 2026. Independent from energy savings and from the CII forecast.
r_ghg0
FuelEU GHG penalty applied for 2025
A 2025 penalty starts 2026 at the second consecutive penalty year if still in deficit. A year with no deficit resets the counter. No banking, borrowing or pooling is modelled.
penalty_2025true

Results

With the default inputs above, the calc gives:

ResultValue
Selected statutory CII ratingC
Attained CII4.4322 g CO₂/(t·NM)
Required CII, applicable ships4.4133 g CO₂/(t·NM)
Selected emissions year ETS exposure975,288 EUR
Selected year FuelEU GHG penalty253,443 EUR
Selected year combined exposure1,228,731 EUR
Settlement year for selected exposure2027
2026 ETS surrender bill: 2025 emissions672,000 EUR
Extra statutory CII reduction to C in 2030 (%)6.9
Total reporting-year exposure, 2026–20306,897,535 EUR

Checked against sources

Each case below was calculated by this calc and agrees with the value from its source (within the tolerance where one is shown).

ClassNK 62,000 DWT bulk carrier, 2026 trajectory

Source: ClassNK CII_en.pdf, slide 15, independently published 2026 values. Use its 17,447 t CO₂ and 60,045 NM (111,203.34 km). Slide 14 instead prints 17,477 t while retaining 4.687; that mass gives 4.69460 and is inconsistent. This case follows the internally consistent slide 15; no formula is changed.

Inputs: Worldwide annual CO₂ = 17,447 t; the others as above.

ResultSourceThis calc
2026 attained CII4.687 g CO₂/(t·NM)4.687 g CO₂/(t·NM)
2019 CII reference line4.959 g CO₂/(t·NM)4.959 g CO₂/(t·NM)
Selected required CII4.413 g CO₂/(t·NM)4.413 g CO₂/(t·NM)
CII ratings, A=1 through E=5 [1]44

Commission MRV example: 200 t MDO and non-CO₂ gases

Source: European Commission ETS/MRV maritime guidance, 18 November 2025, p.45, Example 1: 641.2 t CO₂ + 0.28 t CO₂e methane + 9.54 t CO₂e N₂O = 651.02 t CO₂e. Treat the published gas inventory as already covered and use the 2026 full phase-in.

Inputs: ETS covered CO₂ in 2026 = 641.2 t; ETS covered CH₄ in 2026 = 0.01 t; ETS covered N₂O in 2026 = 0.036 t; the others as above.

ResultSourceThis calc
2026 covered direct GHG emissions651 t651 t
EUAs required (unrounded planning quantity) [1]651651

BetterSea HFO baseline: FuelEU penalty and 2025 ETS

Source: BetterSea Case Study VIII (2025), https://www.bettersea.tech/post/onshore-power-supply-under-fueleu-maritime-and-eu-ets : 10,000 t HFO, 91.74420 g CO₂e/MJ, EUR 70/EUA, published FuelEU penalty EUR 622,000 and ETS EUR 1,525,860. HFO LCV 40.5 GJ/t (Reg.2023/1805 Annex II) converts its inventory to 405,000 GJ. Reproduce the first-penalty-year FuelEU result in 2026: the 2% limit is unchanged from 2025 and the history switch is off. Computed EUR 622,088 is within EUR 1,000 of the rounded publication; the separate 2026 surrender card correctly reproduces the 2025 ETS obligation.

Inputs: FuelEU scoped energy in 2026 = 405,000 GJ; FuelEU GHG penalty applied for 2025 = no; ETS covered CO₂ from 2025 = 31,140 t; EUA planning price (EUR/EUA) = 70; the others as above.

ResultSourceThis calc
Selected year FuelEU GHG penalty622,000 ± 1,000 EUR622,088 EUR
2026 ETS surrender bill: 2025 emissions1,525,860 EUR1,525,860 EUR

IMO adopted 2026–2030 CII reduction factors

Source: IMO MEPC.400(83), adopted 11 April 2025, Annex 4 Table 1, attached s1 p.3; checks the adopted factors rather than an extrapolated linear schedule.

Inputs: the default inputs above.

ResultSourceThis calc
CII reduction from 2019 (%) — adopted 11 April 2025 [1]1111
CII reduction from 2019 (%) — adopted 11 April 2025 [2]13.62513.625
CII reduction from 2019 (%) — adopted 11 April 2025 [3]16.2516.25
CII reduction from 2019 (%) — adopted 11 April 2025 [4]18.87518.875
CII reduction from 2019 (%) — adopted 11 April 2025 [5]21.521.5

MARPOL regulation 19: own-flag-state waters excluded

Source: MARPOL Annex VI regulation 19.2.1, MEPC.328(76), attached s13 p.34: ships sailing solely within their own flag State's waters are excluded from chapter 4. In the default 2030 benchmark D case, no statutory CII rating or corrective-action advice applies. Domestic requirements are assessed separately.

Inputs: CII applicability under MARPOL = Own flag State waters only; Reporting year for result cards = 2,030; the others as above.

ResultSourceThis calc
Statutory CII applicability indicator00
Statutory CII corrective-action review indicator00

MARPOL regulation 19: Polar Code category A excluded

Source: MARPOL Annex VI regulation 19.3, MEPC.328(76), attached s13 p.35: Polar Code category A ships are exempt from regulation 28. Thus the default benchmark D result must not trigger statutory CII rating advice.

Inputs: CII applicability under MARPOL = Polar Code category A; Reporting year for result cards = 2,030; the others as above.

ResultSourceThis calc
Statutory CII applicability indicator00
Statutory CII corrective-action review indicator00

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