Maritime ETS Evasion Risks and Regulatory Proposals in 2026

EU Shipping ETS

Report warns of future ETS evasion risks for ships

Analysis examines evasive port calls to cut carbon costs

Proposes expanding rules to smaller vessels via fuel

Stock video by bellergy via Pixabay

Mar 18, 2026

Maritime ETS Evasion Risks and Regulatory Proposals in 2026

Maritime ETS Evasion Risks and Regulatory Proposals

A briefing from Transport & Environment examines potential carbon leakage in the maritime Emissions Trading System (ETS) and suggests regulatory adjustments. The analysis focuses on evasive port calls, where vessels might add a stop at a non-EU port to shorten the ETS-covered part of a journey and lower their compliance costs.

Initial analysis led by the European Commission in March 2025 did not find systemic evidence of such behaviour, but monitoring continues. Overall observed traffic patterns since ETS implementation do not indicate systemic or structural evasive port calls. Analysis comparing pre-ETS (2023) and post-implementation (2024) traffic across Atlantic, Mediterranean, and North European regions reveal mixed trends. While certain routing adjustments are observable, they do not constitute clear evidence of widespread systematic ETS-driven evasion.

Regional evidence is mixed and inconclusive regarding deliberate evasive port calls. In 2024, Atlantic EU ports saw fewer overall calls but more direct arrivals from distant, low-risk non-EU ports, suggesting no systematic addition of ports calls in nearby non-EU ports to evade the ETS. In the Eastern Mediterranean, there is some evidence of changes to port stop patterns, though rerouting linked to Red Sea disruption is a credible alternative explanation. In both the Western Mediterranean and North European ports, routing patterns remained broadly stable despite a slight decline in overall voyage numbers, with no clear evidence that ships made new evasive port calls. Although these changes do not prove evasion, they indicate that incentives may emerge in the future.

The briefing also proposes expanding the ETS to include smaller vessels through a simplified reporting framework. This would involve splitting the reporting between ETS 1 and ETS 2 based on operational patterns, such as placing smaller ships predominantly operating within the EU under a second tier. For these vessels, compliance responsibility could shift upstream to fuel suppliers to minimise administrative burden. A simplified monitoring and reporting system focused on annual fuel consumption and CO2 emissions is recommended to ensure proportionality while preserving environmental integrity.

1. INTRODUCTION

Making Data-Driven Decisions to Grow Your Business
1. REPORT DESCRIPTION
2. RESEARCH METHODOLOGY AND THE AI PLATFORM
3. DATA-DRIVEN DECISIONS FOR YOUR BUSINESS
4. GLOSSARY AND SPECIFIC TERMS
2. EXECUTIVE SUMMARY

A Quick Overview of Market Performance
1. KEY FINDINGS
2. MARKET TRENDS This Chapter is Available Only for the Professional EditionPRO
3. MARKET OVERVIEW

Understanding the Current State of The Market and its Prospects
1. MARKET SIZE: HISTORICAL DATA (2012–2025) AND FORECAST (2026–2035)
2. CONSUMPTION BY COUNTRY: HISTORICAL DATA (2012–2025) AND FORECAST (2026–2035)
3. MARKET FORECAST TO 2035
4. MOST PROMISING PRODUCTS FOR DIVERSIFICATION

Finding New Products to Diversify Your Business
- This Chapter is Available Only for the Professional EditionPRO
1. TOP PRODUCTS TO DIVERSIFY YOUR BUSINESS
2. BEST-SELLING PRODUCTS
3. MOST CONSUMED PRODUCTS
4. MOST TRADED PRODUCTS
5. MOST PROFITABLE PRODUCTS FOR EXPORT
5. MOST PROMISING SUPPLYING COUNTRIES

Choosing the Best Countries to Establish Your Sustainable Supply Chain
- This Chapter is Available Only for the Professional EditionPRO
1. TOP COUNTRIES TO SOURCE YOUR PRODUCT
2. TOP PRODUCING COUNTRIES
3. TOP EXPORTING COUNTRIES
4. LOW-COST EXPORTING COUNTRIES
6. MOST PROMISING OVERSEAS MARKETS

Choosing the Best Countries to Boost Your Export
- This Chapter is Available Only for the Professional EditionPRO
1. TOP OVERSEAS MARKETS FOR EXPORTING YOUR PRODUCT
2. TOP CONSUMING MARKETS
3. UNSATURATED MARKETS
4. TOP IMPORTING MARKETS
5. MOST PROFITABLE MARKETS
7. PRODUCTION

The Latest Trends and Insights into The Industry
1. PRODUCTION VOLUME AND VALUE: HISTORICAL DATA (2012–2025) AND FORECAST (2026–2035)
2. PRODUCTION BY COUNTRY: HISTORICAL DATA (2012–2025) AND FORECAST (2026–2035)
8. IMPORTS

The Largest Import Supplying Countries
1. IMPORTS: HISTORICAL DATA (2012–2025) AND FORECAST (2026–2035)
2. IMPORTS BY COUNTRY: HISTORICAL DATA (2012–2025) AND FORECAST (2026–2035)
3. IMPORT PRICES BY COUNTRY: HISTORICAL DATA (2012–2025) AND FORECAST (2026–2035)
9. EXPORTS

The Largest Destinations for Exports
1. EXPORTS: HISTORICAL DATA (2012–2025) AND FORECAST (2026–2035)
2. EXPORTS BY COUNTRY: HISTORICAL DATA (2012–2025) AND FORECAST (2026–2035)
3. EXPORT PRICES BY COUNTRY: HISTORICAL DATA (2012–2025) AND FORECAST (2026–2035)
10. PROFILES OF MAJOR PRODUCERS

The Largest Producers on The Market and Their Profiles
- This Chapter is Available Only for the Professional EditionPRO
11. COUNTRY PROFILES

The Largest Markets And Their Profiles
This Chapter is Available Only for the Professional Edition PRO
1. 11.1
  United States
  - Market Size
  - Production
  - Imports
  - Exports
2. 11.2
  China
  - Market Size
  - Production
  - Imports
  - Exports
3. 11.3
  Japan
  - Market Size
  - Production
  - Imports
  - Exports
4. 11.4
  Germany
  - Market Size
  - Production
  - Imports
  - Exports
5. 11.5
  United Kingdom
  - Market Size
  - Production
  - Imports
  - Exports
6. 11.6
  France
  - Market Size
  - Production
  - Imports
  - Exports
7. 11.7
  Brazil
  - Market Size
  - Production
  - Imports
  - Exports
8. 11.8
  Italy
  - Market Size
  - Production
  - Imports
  - Exports
9. 11.9
  Russian Federation
  - Market Size
  - Production
  - Imports
  - Exports
10. 11.10
  India
  - Market Size
  - Production
  - Imports
  - Exports
11. 11.11
  Canada
  - Market Size
  - Production
  - Imports
  - Exports
12. 11.12
  Australia
  - Market Size
  - Production
  - Imports
  - Exports
13. 11.13
  Republic of Korea
  - Market Size
  - Production
  - Imports
  - Exports
14. 11.14
  Spain
  - Market Size
  - Production
  - Imports
  - Exports
15. 11.15
  Mexico
  - Market Size
  - Production
  - Imports
  - Exports
16. 11.16
  Indonesia
  - Market Size
  - Production
  - Imports
  - Exports
17. 11.17
  Netherlands
  - Market Size
  - Production
  - Imports
  - Exports
18. 11.18
  Turkey
  - Market Size
  - Production
  - Imports
  - Exports
19. 11.19
  Saudi Arabia
  - Market Size
  - Production
  - Imports
  - Exports
20. 11.20
  Switzerland
  - Market Size
  - Production
  - Imports
  - Exports
21. 11.21
  Sweden
  - Market Size
  - Production
  - Imports
  - Exports
22. 11.22
  Nigeria
  - Market Size
  - Production
  - Imports
  - Exports
23. 11.23
  Poland
  - Market Size
  - Production
  - Imports
  - Exports
24. 11.24
  Belgium
  - Market Size
  - Production
  - Imports
  - Exports
25. 11.25
  Argentina
  - Market Size
  - Production
  - Imports
  - Exports
26. 11.26
  Norway
  - Market Size
  - Production
  - Imports
  - Exports
27. 11.27
  Austria
  - Market Size
  - Production
  - Imports
  - Exports
28. 11.28
  Thailand
  - Market Size
  - Production
  - Imports
  - Exports
29. 11.29
  United Arab Emirates
  - Market Size
  - Production
  - Imports
  - Exports
30. 11.30
  Colombia
  - Market Size
  - Production
  - Imports
  - Exports
31. 11.31
  Denmark
  - Market Size
  - Production
  - Imports
  - Exports
32. 11.32
  South Africa
  - Market Size
  - Production
  - Imports
  - Exports
33. 11.33
  Malaysia
  - Market Size
  - Production
  - Imports
  - Exports
34. 11.34
  Israel
  - Market Size
  - Production
  - Imports
  - Exports
35. 11.35
  Singapore
  - Market Size
  - Production
  - Imports
  - Exports
36. 11.36
  Egypt
  - Market Size
  - Production
  - Imports
  - Exports
37. 11.37
  Philippines
  - Market Size
  - Production
  - Imports
  - Exports
38. 11.38
  Finland
  - Market Size
  - Production
  - Imports
  - Exports
39. 11.39
  Chile
  - Market Size
  - Production
  - Imports
  - Exports
40. 11.40
  Ireland
  - Market Size
  - Production
  - Imports
  - Exports
41. 11.41
  Pakistan
  - Market Size
  - Production
  - Imports
  - Exports
42. 11.42
  Greece
  - Market Size
  - Production
  - Imports
  - Exports
43. 11.43
  Portugal
  - Market Size
  - Production
  - Imports
  - Exports
44. 11.44
  Kazakhstan
  - Market Size
  - Production
  - Imports
  - Exports
45. 11.45
  Algeria
  - Market Size
  - Production
  - Imports
  - Exports
46. 11.46
  Czech Republic
  - Market Size
  - Production
  - Imports
  - Exports
47. 11.47
  Qatar
  - Market Size
  - Production
  - Imports
  - Exports
48. 11.48
  Peru
  - Market Size
  - Production
  - Imports
  - Exports
49. 11.49
  Romania
  - Market Size
  - Production
  - Imports
  - Exports
50. 11.50
  Vietnam
  - Market Size
  - Production
  - Imports
  - Exports
LIST OF TABLES
1. Key Findings In 2025
2. Market Volume, In Physical Terms: Historical Data (2012–2025) and Forecast (2026–2035)
3. Market Value: Historical Data (2012–2025) and Forecast (2026–2035)
4. Per Capita Consumption, by Country, 2022–2025
5. Production, In Physical Terms, By Country: Historical Data (2012–2025) and Forecast (2026–2035)
6. Imports, In Physical Terms, By Country: Historical Data (2012–2025) and Forecast (2026–2035)
7. Imports, In Value Terms, By Country: Historical Data (2012–2025) and Forecast (2026–2035)
8. Import Prices, By Country: Historical Data (2012–2025) and Forecast (2026–2035)
9. Exports, In Physical Terms, By Country: Historical Data (2012–2025) and Forecast (2026–2035)
10. Exports, In Value Terms, By Country: Historical Data (2012–2025) and Forecast (2026–2035)
11. Export Prices, By Country: Historical Data (2012–2025) and Forecast (2026–2035)
LIST OF FIGURES
1. Market Volume, In Physical Terms: Historical Data (2012–2025) and Forecast (2026–2035)
2. Market Value: Historical Data (2012–2025) and Forecast (2026–2035)
3. Consumption, by Country, 2025
4. Market Volume Forecast to 2035
5. Market Value Forecast to 2035
6. Market Size and Growth, By Product
7. Average Per Capita Consumption, By Product
8. Exports and Growth, By Product
9. Export Prices and Growth, By Product
10. Production Volume and Growth
11. Exports and Growth
12. Export Prices and Growth
13. Market Size and Growth
14. Per Capita Consumption
15. Imports and Growth
16. Import Prices
17. Production, In Physical Terms: Historical Data (2012–2025) and Forecast (2026–2035)
18. Production, In Value Terms: Historical Data (2012–2025) and Forecast (2026–2035)
19. Production, by Country, 2025
20. Production, In Physical Terms, by Country: Historical Data (2012–2025) and Forecast (2026–2035)
21. Imports, In Physical Terms: Historical Data (2012–2025) and Forecast (2026–2035)
22. Imports, In Value Terms: Historical Data (2012–2025) and Forecast (2026–2035)
23. Imports, In Physical Terms, By Country, 2025
24. Imports, In Physical Terms, By Country: Historical Data (2012–2025) and Forecast (2026–2035)
25. Imports, In Value Terms, By Country: Historical Data (2012–2025) and Forecast (2026–2035)
26. Import Prices, By Country: Historical Data (2012–2025) and Forecast (2026–2035)
27. Exports, In Physical Terms: Historical Data (2012–2025) and Forecast (2026–2035)
28. Exports, In Value Terms: Historical Data (2012–2025) and Forecast (2026–2035)
29. Exports, In Physical Terms, By Country, 2025
30. Exports, In Physical Terms, By Country: Historical Data (2012–2025) and Forecast (2026–2035)
31. Exports, In Value Terms, By Country: Historical Data (2012–2025) and Forecast (2026–2035)
32. Export Prices, By Country: Historical Data (2012–2025) and Forecast (2026–2035)

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