IMO and EU GHG Compliance Cost Calculator

GHG regulation for the global shipping industry is advancing at pace.

First came the addition of shipping to the European Union's emissions trading system (EU-ETS) in 2024. The FuelEU Maritime regulation then added further complexity at the EU level in 2025, and then the International Maritime Organization (IMO) developed a net-zero framework setting out plans to charge shipping for its emissions at the global level from 2028.

Ship & Bunker has developed this calculator to help shipping companies and other maritime stakeholders estimate the compliance costs for these three regulations for their chosen energy mix for the years 2028-2035.

Click on the tabs above to learn more about each regulation.

The Calculator

To use the calculator, select a voyage type - to determine to what extent EU regulations should be considered - and enter the quantity in metric tonnes of each type of fuel to be used on the voyage.

The user can either set their own estimated values for carbon intensity, energy density, IMO surplus unit value, the average EUA price and FuelEU Maritime surplus value under the pooling system, or alternatively use the defaults provided. The calculator will generate a summary of costs from each regulation for each year between 2028 and 2035.

Fuel Type Quantity (mt) Carbon Intensity (gCO2e/MJ) Energy Density (MJ/kg)
VLSFO
HSFO
MGO
B100
LNG
Bio-LNG
Biomethanol
Ammonia
Default: $300/mtCO2e
Default: $0/mtCO2e
Default: $80/mtCO2e
Default: $300/mtCO2e

Methodology, Assumptions and Caveats

The biggest assumption in the Ship & Bunker calculator is that the IMO's and EU's emissions regulations will exist simultaneously, with penalties and rewards from each system stacking on top of each other - a highly uncertain prospect.

The EU is in the process of reviewing its maritime emissions regulations, and has in the past expressed willingness to amend or remove its regional regulations if a satisfactory regulation is imposed at the global level. But in practice, the loss of revenues to the EU from removing these regulations would be significant, so the issue remains politically contentious for now.

Default GHG intensity and energy density numbers for the purposes of IMO 2028 and FuelEU Maritime compliance have been estimated by Ship & Bunker based on figures that might be achievable for a majority of ships using these fuels by 2028, rather than historical default values set out in regulations. The IMO is in the process of setting its own default values, which are due to be in place before the framework comes into effect.

Default values for tank-to-wake GHG intensity for the purposes of EU-ETS compliance have been taken from the EU MRV regulation, with additional estimates made for bio-LNG, biomethanol and ammonia.

The calculator assumes that the IMO's $380/mtCO2e and $100/mtCO2e remedial unit charges will remain at those prices throughout, while in practice they are set to be revised after 2030 and presumably will be set at higher levels.

The assumed IMO surplus unit value is set as a constant throughout the years 2028-2035. In practice this price will change over time, based on the cost of the cheapest means of generating surplus units, and should face pressure to rise over time as the carbon intensity thresholds are lowered. The maximum price for surplus units will be equal to the IMO's remedial unit cost for base target compliance. 

The value of ZNZ rewards under the IMO system has also been set as a constant throughout the years 2028-2035, while in practice this number will change over time. The calculator sets a default value of 0 for these rewards initially, reflecting current uncertainty over how this reward system will work, but users have the option to set a value based on their own assumptions.

The default average EUA price is based on market prices as of June 2025 and applied as a constant throughout the years 2028-235. In practice this a floating price that will change considerably over those years, and is likely to be significantly higher than prices in 2025 because of the reduction in EUAs issued by the EU.

The assumed FuelEU Maritime surplus unit value has also been set as a constant throughout the years 2028-2035, while in practice this number will change over time. The maximum value for this will be equal to the penalty cost under the FuelEU Maritime Regulation.

Glossary

A range of different terms are in use around the IMO's decarbonisation plans. The following are explanations for some of the most common ones:

  • IMO 2028: Ship & Bunker uses this term for the IMO deal, for simplicity and brevity. 2028 refers to the first year in which shipping will be charged for its emissions under this structure.
  • NZF: The IMO refers to its deal as the net-zero framework (NZF). 
  • GFI: Greenhouse gas fuel intensity (GFI) is the metric set by the IMO for net GHG intensity of energy used on board ships.
  • ZNZs: The IMO uses the term zero or near-zero fuels (ZNZs) to describe fuels with sufficiently low GHG intensity to be rewarded under its framework.

This page will be updated periodically to reflect changes in regulations and our evolving assumptions on how the regulations will work and interact. To provide feedback on the calculator or suggest additions, email editorial@shipandbunker.com.