Titan, part of Molgas, has analysed the role of LNG, bio-LNG, and e-methane in FuelEU Maritime compliance, as well as the performance of the regulation, particularly its pooling mechanism, so far.
The paper models compliance for an 8000 TEU containership operating a route spanning Rotterdam, Antwerp, Hamburg, and Algeciras using approximately 18 000 t of LNG-equivalent fuel annually, all within the scope of FuelEU Maritime. Three scenarios are shown: a fuel oil baseline, grey LNG, and a 30% bio-LNG blend.
The oil-fuelled vessel is in deficit in 2025, and penalty costs grow steeply from ~€2.2 million to ~€17 million by 2040 as targets tighten. With LNG, the containership generates overcompliance of 11 700 t CO2-e/y in 2025 and remains compliant through 2035. From 2040, a typical 15% bio-LNG blend restores compliance, and any extra bio-LNG generates surplus pooling value. Introducing a 30% bio-LNG blend can increase that surplus to over 34 000 t CO2-e/y. That rep-resents ~€3.4 million to ~€5.1 million/y in gross transferable compliance value.
The figures use FuelEU Maritime’s default well-to-wake emissions factor, covering the fuel’s full lifecycle, together with the published penalty rate of €2400/t VLSFO energy equivalent. Gross pooling values are indicative, based on a market range of €100 – US$150/ t CO2-e. The net commercial benefit will de-pend on the market compliance values negotiated and the cost premium of bio-LNG vs fossil LNG. For customers, Titan can model this precisely for each ship and supply scenario.
Grégoire Hartig, Commercial Director at Titan, commented: “Pooling effectively converts over-achieving emissions performance targets into a tradable or allocatable asset. This bridges the market and competition-based nature of maritime transport with the implementation of stringent greenhouse gas regulation. This has, in our view, proven to be a very efficient way to ensure the active participation and alignment of all stakeholders.
“In large part due to ship operators seeking FuelEU Maritime overcompliance, we have already recorded bio-LNG rising from 6.5% to 19.1% of our total delivered volume of methane from 2024 – 2025. Bio-LNG prices have been high in 2026 so far, we expect a better second half to the year. Let’s not forget, though, that 2025 has only been the first year where FuelEU pools have been implemented, and that, through iteration, the role of bio-LNG and its impact on compliance values will become clearer.”
Maro Varvate, Commercial Manager at Titan, added: "FuelEU offers a strategic, practical and cost-effective approach to decarbonisation and fleet renewal, which takes into account the lifecycle of maritime asset investment. If ship opera-tors are pooling their own ships, it allows them to target and sequence decarbonisation investments pragmatically, improving selected vessels first while maintaining compliance across their fleet.
“This targeted approach also makes sense from a fuel supply point of view. It allows LNG, and particularly bio-LNG as it continues to scale up, to be efficiently produced and supplied to one ship in one location, and yet the benefits can be shared over the wider shipping service. This also enables demand to incrementally scale up as profits are being made from over-compliant vessels.”
Beyond pooling, the paper argues that the EU’s well-to-tank default emissions factor for LNG is too high. It cites Rystad Energy’s LNG Well-To-Tank Emissions Assessment 2025 report, where the global well-to-tank emissions intensity of LNG used as bunker fuel in 2024 was shown to be 13.9 g CO2-e/MJ (LHV), below the current EU well-to-tank default of 18.5 g CO2-e/MJ.
Titan also discusses the journey that the LNG Industry has been on in reducing methane slip and upstream supply chain leakage. It calls on regulators to reward good performance and penalise poor performance, highlighting that the cur-rent generic default emissions factor offers almost no compliance or financial incentive for shipowners to choose engine technology with minimal slip and use LNG with lower-emission supply chains.
