PortXchange managing director and co-founder Sjoerd de Jager. Image Credit: PortXchange

• PortXchange says the Dutch-first RED III rollout shows what happens when fuel rules differ "next door"
• Rotterdam's conventional sales fell to 1.58 million mt in Q1, the lowest since at least 2010; Q2 total sales were down 26.7% on the year
• Belgium has delayed its equivalent rule and Germany has left international shipping out, so volume moved there
• Spain's Royal Decree 611/2026 makes it the second country to regulate the supplier, though only for cabotage
• IMO Net-Zero Framework vote due December 4

The EU's country-by-country rollout of decarbonisation obligations on marine fuel suppliers is a live pilot of the fragmentation IMO member states are trying to avoid, and Rotterdam's lost bunker volumes show how it plays out, according to PortXchange.

The Rotterdam-based port emissions data company made the argument in an emailed press release on Tuesday, ten weeks before the IMO's resumed vote on its Net-Zero Framework, and as Spain becomes the second EU country to place a binding greenhouse gas intensity obligation on fuel suppliers rather than on the ships they serve.

Since the Dutch transposition of RED III came into force on January 1, 2026, requiring suppliers to cut the GHG intensity of bunker fuel sold in the Netherlands, Rotterdam's conventional bunker sales fell to 1.58 million mt in the first quarter, down 28.1% on the year and 27.2% from the previous quarter, and the lowest quarterly total since at least 2010, or 1.69 million mt including biofuel blends, down 26.8% on the year.

Second-quarter sales of 1.75 million mt including biofuels were down 26.7% on the year, though 4% up on the first quarter, while neighbouring Antwerp-Bruges sold about 2 million mt in the same period, up 5.5%.

Volume Moved

PortXchange's argument is that because Belgium has delayed its equivalent rule and Germany has so far left international shipping out of its own transposition, the volume that left Rotterdam has gone to ports with no such obligation rather than being decarbonised, an outcome Peninsula predicted to Ship & Bunker earlier this year.

The company says it puts Rotterdam's compliance-driven price premium over its nearest competitor at $20-25/mt by September.

Ship & Bunker data show Rotterdam VLSFO has averaged $13.50/mt above Antwerp so far this month, reaching $26.50/mt on September 11, having traded at parity with Antwerp through the last quarter of 2025.

"Netherlands played it straight. Belgium delayed. Germany opted out. And the volume did exactly what volume does when the rules aren't the same next door: it moved," said PortXchange managing director and co-founder Sjoerd de Jager.

"Spain's next. The real question is who else is willing to go first without checking whether anyone's coming with them."

Second Country

Spain's Royal Decree 611/2026, published on July 23, applies the same principle, setting a GHG intensity reduction curve for fuel suppliers rising from 6.5% in 2027 to 33% in 2040, with a renewable fuel sub-target rising from 2% to 20% over the same period.

There is one significant difference from the Dutch rule, however: the Spanish obligation applies only to fuel supplied for domestic cabotage, not to international shipping bunkering at Spanish ports, so the exposure of hubs such as Algeciras and Barcelona is not the same as Rotterdam's.

IMO Timing

With another vote on the Net-Zero Framework due later this year, PortXchange argues that what has happened at Rotterdam is evidence IMO member states should weigh before deciding whether they can agree a single global measure.

Adoption of the framework was put off for a year at an extraordinary session in October 2025, when member states voted 57-49 to adjourn, and it returns to the table with an intersessional working group on November 23-27, MEPC 85 from November 30 and the resumed extraordinary session on December 4.

"Two governments have now shown what happens when the transition isn't coordinated: the tonnes move, the emissions don't," de Jager said.

"The industry doesn't need another debate about who regulates first. It needs ports, suppliers and regulators acting together before December, not after. That's not a policy preference. It's a survival strategy."