From 2026, European maritime transport will face a 45% increase in its emissions surcharge (EMS/ESS), resulting from the obligation to declare 100% of emissions under the EU ETS, a fixed cost of 130 USD/FEU unavoidable for Spanish routes with the EU.
We recommend three key cost mitigation strategies: rigorous budgeting of the new COGS surcharge, evaluation of Green Hedging services (ECO Delivery) to obtain credits against the surcharge, and negotiation of clauses indexed to the actual price of emissions allowances (EUAs) with shipping lines to manage volatility risk.
Questions answered in this article
- Why is the emissions surcharge (EMS/ESS) increasing in 2026, and what is the regulatory basis for this cost?
- What is the EU ETS, and how does it require the maritime sector to bear the costs of pollution?
- How does the EU ETS surcharge affect Spanish imports and exports, especially on intra-EU routes?
- What is the estimated cost of the surcharge per 40-foot dry container (40’ DRY) on the Asia-Mediterranean route for Q1 2026?
- What cost management strategies (budgeting, green hedging, indexing) can be applied to mitigate the financial impact of the EU ETS?
The unavoidable fixed cost: 100% EU ETS coverage
The problem
European regulations are about to impose a substantial increase in maritime operating costs, a reality that will directly impact your supply chain. From January 1, 2026, shipping companies will be required to declare 100% of their verified CO2 emissions for voyages within the European Union (EU).
Why does this happen, and what is the root of the problem?
The origin of this cost lies in the legislation of the EU Emissions Trading System (EU ETS), the European Union’s key tool for achieving climate neutrality by 2050 (The regulatory shock: a new fixed cost). This mandate stems directly from the European Green Deal, a regulatory framework that leaves no room for evasion.
- What is the EU ETS? It is a cap-and-trade mechanism designed to force the maritime sector to bear the cost of its own pollution, incentivizing investment in cleaner fuels to avoid the purchase of expensive emission allowances (EUAs).
- The 100% jump: The factor driving up the cost in 2026 is precisely the final phase of implementation of the regulations, which requires increasing reporting coverage to 100% for intra-EU routes. This represents a considerable jump from the 70% in 2025 and the 40% applied in 2024.
- Expanded scope: It’s not just CO2; the scope will be expanded to include the monitoring of methane (CH4) and nitrous oxide (N2O) emissions (Maersk confirms this in its surcharges). Furthermore, these surcharges also cover the costs of complying with the FuelEU Maritime regulation.
How does this affect Spain?
The impact is immediate and quantifiable: the emissions surcharge (EMS/ESS) is expected to increase by approximately 45% in 2026 (Hapag-Lloyd anticipates this in its press releases).
Spain is intrinsically linked to this cost. Given its dependence on maritime traffic with the EU/EEA, your company will face these surcharges on all its maritime operations with European ports.
- Impact on the Asia-Mediterranean route: For the first quarter of 2026, the projected cost for a standard 40-foot dry container (40’ DRY) on the Asia-Mediterranean route is $130 USD (approximately €112) (Shipping line surcharge rates are estimated).
- Unavoidable cost: This surcharge is non-negotiable. Even if you can obtain lower base freight rates, the total cost per unit will be inflated by this surcharge. This directly impacts your Cost of Goods Sold (COGS) and can significantly reduce your margins if it is not budgeted for carefully.
Mitigation strategies for your business
At AGC Newtral, we don’t just report the problem. Action is our response. We can’t prevent regulation, but we can help you mitigate its impact on your logistics profitability. Here are three essential strategies your team should implement immediately:
- Rigorous Budgeting
- What does it involve? Treat the $130 USD/FEU surcharge as an unavoidable fixed cost. You must include it in the Cost of Goods Sold (COGS) calculation for all your key imports from Asia (a crucial figure for COGS).
- Why does it work? Only absolute budgeting accuracy guarantees a genuine protection of your profit margin. By internalizing this cost from the outset, you avoid surprises later on that could compromise your profitability.
- Green Hedging
- What does it involve? Evaluate purchasing “green” shipping services from carriers, such as Ship Green or ECO Delivery. These programs utilize alternative, low-emission fuels.
- Why does it work? These programs often offer direct credits against the mandatory surcharge, making the sustainability of an expense a direct cost management tool. Thus, investing in sustainability reduces your financial exposure to the EU ETS, protecting your margins.
- Indexed Clauses
- What does it involve? Negotiate surcharges with shipping lines based on floating factors, such as Hapag-Lloyd’s ETS Adjustment Factor. These factors adjust to the actual price of emission allowances (EUAs), rather than being based on fixed, pre-established rates.
- Why does it work? This indexation is smart risk management. It protects you from the volatility of the carbon market. If emission allowance (EUA) prices fall, your company benefits directly.
At AGC Newtral, we know that logistics doesn’t wait. We want to be clear with you about the imminent 45% increase in the European Maritime Emissions Surcharge (EMS/ESS). This change, far from being a rumor, is a fixed, unavoidable cost that your business will have to absorb starting in 2026. The question is no longer whether it will happen, but how you will mitigate its impact on your profitability.
