FEATURE: 2025 Was Year of Rapidly Escalating Regulation for Shipping and Bunker Industries

An increase in regulatory paperwork is a prediction for 2026 all but guaranteed to come true. File Image / Pixabay

Despite the delay to the IMO's net-zero framework plans, 2025 was a year where a wave of new regulations hit the shipping and bunker industries.

While the unexpected spanner in the works at the IMO was undoubtedly the biggest story of the year, the trend more generally has been for increased regulatory complexity for these industries, at a time of uncertain global economic strength and a highly volatile geopolitical backdrop.

As 2025 draws to a close, many in the shipping and bunkering industries will be hoping for a quieter period at the start of next year to digest all of the changes seen in the previous one. 

GHG Regulation

GHG regulation starting to come to a head was a major theme of the year.

2025 started with the ratcheting-up of two key EU regulations: the next stage of the phasing-in of the EU emissions trading system, and the FuelEU Maritime regulation coming into effect.

For the EU-ETS, in 2024 ships had to purchase European Union allowances (EUAs) to cover only 40% of the emissions generated on intra-EU voyages, or half that amount for voyages between the EU and elsewhere. That figure stepped up to 70% in 2025.

With EUAs costing $74.50/mtCO2e at the start of 2025, this phasing-in amounted to an increase of $70.42 in compliance costs for every tonne of VLSFO consumed on an intra-EU voyage. 

September 30 also saw the first deadline for the surrendering of EUAs, for 2024's emissions, in some cases leading to a last-minute rush to buy the allowances in time.

FuelEU Maritime also came into force at the start of 2025, setting carbon intensity targets for marine energy consumption and imposing penalties on those who failed to reach them or purchase overcompliance from others.

While the target for 2025 is relatively easy to meet - amounting to just a 2% reduction in GHG intensity from the baseline level - this regulation, in combination with the EU-ETS, has been enough to stimulate significantly more interest in biofuel bunker blends at a range of IMO ports.

But moving beyond the regional level, the unpredictable course of events for global regulation at the IMO level represented a series of dramatic shifts for the shipping industry.

For supporters of global GHG regulation, the year had a relatively promising start as the IMO's MEPC meeting in April agreed on a preliminary basis to a new net-zero framework governing shipping's GHG emissions.

The framework was initially criticised for a lack of ambition, with many island member states in particular abstaining on the vote, as decarbonisation backers had largely hoped for a flat levy on shipping's GHG emissions of $100/mtCO2e or more. But this criticism was tempered with relief that the meeting had managed to agree to anything.

The deal would have set two tiers of GHG intensity thresholds for marine energy consumption for the years 2028 to 2035, with varying penalties for failing to meet each threshold, the ability to trade overcompliance and rewards handed out to those using zero- or near-zero GHG fuels.

After the agreement in April, an extraordinary MEPC session was arranged for October to vote on the deal's adoption.

But as it turned out, over the April-October period opponents of the NZF took the time to put together an effective strategy to stymie the deal.

The US under the Trump Administration was the NZF's most significant opponent, characterising it as a global climate tax imposed by the UN. Of particular concern to the US was the possibility of a UN body managing the funds raised by penalties charged under the framework.

But by the end of a fraught week of negotiations at the extraordinary MEPC meeting in October, a wide range of countries - including those like Singapore that backed the framework itself - came to support a delay on the adoption vote by a year, some in the expectation that this would be the only hope of preventing a vote against the framework.

At the end of 2025, the timeline for global GHG regulation for shipping is now firmly in disarray, with the initial plan for the NZF to go into effect in 2028 now highly unlikely to come to fruition, and no firm idea of what changes might be needed for the deal to pass late next year.

But the general trend for more GHG regulation for shipping remains unchanged. The UK is now bringing into force its own ETS for shipping, at first for domestic voyages from the middle of 2026 and then for international voyages from 2028.

Turkey also has similar plans, and a range of other countries are now considering their own measures. The slowdown in regulation at the global level is likely to lead to further proliferation of national and regional systems.

Digitalisation

But GHG emissions have not been the only area for increased maritime regulation in 2025. 

Regulatory change is also bringing about the digitalisation and general modernisation of the bunker industry.

Singapore's mandate requiring e-BDNs for all bunker deliveries came into effect at the start of April, setting the global industry on a path towards electronic documentation becoming the norm in the years to come.

By October, Ofiniti estimated as much as 28% of global bunker deliveries were being made with the use of e-BDNs.

Singapore's lead on mass flow meters - having been the first hub to make the measurement systems mandatory for bunkering from 2017 - was also showing signs of being followed elsewhere in the world in 2025.

The Northwest European ports of Rotterdam and Antwerp-Bruges were preparing for the introduction of their MFM mandate from the start of 2026, and the Port of Ceuta announced its own mandate from February 2025. South Korea is reported to be considering an MFM mandate from 2027, while Hong Kong has said it will require the measurement systems for methanol deliveries.

2025 also saw the launch of the Bunkering Services Initiative at the ARA hub, with a range of suppliers, buyers and other stakeholders coming together to set group standards for fully digitalised, transparent and MFM-enabled bunkering in Northwest Europe.

Med ECA

In a quieter year, the introduction of the Mediterranean 0.1% sulfur emission control area (ECA) would have been enough to dominate the headlines for months.

In comparison to the reduction of the sulfur cap in Northwest Europe to 0.1% in 2015, the Mediterranean ECA's launch in May passed almost without comment, despite being a change of similar magnitude.

The change has shifted considerable amounts of VLSFO demand in and around the Mediterranean to MGO, as well as encouraging the uptake of scrubbers to enable HSFO consumption in the area and the emergence of ULSFO supply.

Data from testing firm VPS's samples at the top ten Mediterranean ports show in the period from May to October 2025, VLSFO took up about 30% of demand, HSFO 29%, MGO 30%, ULSFO 8% and biofuels 4%. This compares to respective shares of 53%, 28%, 16%, 2% and 1% in the six months before.

Geopolitics

Finally, 2025 for the shipping industry has been characterised overall by almost unprecedented levels of geopolitical turmoil.

The biggest factor here has been the Trump Administration's tariff policy, setting into play trade tensions between the US and a wide range of countries and threatening to cut growth in shipping demand.

In terms of bunker sales, the impact of this has fallen thus far most significantly on markets in the Americas, with the US Gulf, Panama, New York and LA/Long Beach markets all showing year-on-year declines by the third quarter.

Houthi attacks on shipping around Yemen's waters, and the resulting diversions of ships away from the Red Sea and Suez Canal, were another significant area of disruption in 2025.

While the frequency of these attacks dropped sharply this year, most shipping firms took a conservative approach over returning to the region. By the end of the year CMA CGM and Maersk were reported to be formulating plans for a return to the use of Suez, but no clear timeline has yet emerged for when this will happen at scale.

Diversions away from the Red Sea to favour longer voyages around Africa have added significantly to global bunker demand over the past two years, and the end of this phenomenon will be a significant event for the market when it happens

The Russia-Ukraine war is another part of the picture of geopolitical disarray in 2025.

Economic measures against Russia in response to the war have been steadily ratcheted up, including putting pressure on the remaining buyers of its oil to find supplies elsewhere.

An end to the war raises the prospect of Russian oil starting to return to Western markets if sanctions are lifted - a possibility of particular interest to the bunker industry, given Russia's high fuel oil production.

At the end of the year, some signs are showing on both sides of the war of willingness to negotiate a peace deal, but the pathway to achieving this looks highly uncertain in the short term.