On 1 January the EU Emissions Trading System reached 100% coverage of verified shipping CO₂. It was 40% in 2024 and 70% in 2025, so this is the third and final step of a phase-in that has been quietly repricing every European booking for two years. Hapag-Lloyd told customers to expect its surcharge to rise by around 45%.
If you last checked one of these lines in detail in 2025, the arithmetic underneath it has changed twice since.
What is in scope, and the half that catches people out
Voyages between two EU ports are covered at 100% of emissions. Voyages between an EU port and a non-EU port are covered at 50%.
That 50% is where most invoice disputes start. It is half the emissions of the whole voyage, not the emissions of the leg inside EU waters. A Shanghai–Rotterdam sailing is charged on half of everything burned from Shanghai, not on what was burned after the ship entered European waters. The number is therefore much larger than people expect, and it scales with routing.
Which produces a consequence worth sitting with: the Cape of Good Hope diversion increased ETS exposure on Asia–Europe cargo, because it added sea days to a voyage that is charged on half its total emissions. Loops returning through Suez are cutting that back. If your Asia–Europe surcharge falls this quarter without the allowance price moving, that is probably why.
How the number is actually built
Three inputs, and every carrier combines them slightly differently.
The emissions figure comes from the ship's verified fuel consumption on that voyage, allocated across the cargo on board. The allowance price is the market price of EUAs at the point the carrier hedges or buys. And the coverage factor is the 100% or 50% above.
Most carriers now fold FuelEU Maritime into the same line rather than showing it separately. FuelEU is a different instrument — it sets a greenhouse-gas intensity limit on energy used, and penalises falling short of it — but from your side it arrives as part of one combined environmental surcharge.
That consolidation is convenient and slightly unhelpful. It means a single number on your invoice is now driven by two regimes with different triggers, and you cannot tell from the line which one moved.
Checking a line you think is wrong
Ask for the components. A carrier that cannot break the surcharge into emissions basis, allowance price and coverage factor is not in a position to defend it, and most will produce the breakdown when asked.
Check the coverage factor first, because it is the most common error and the easiest to prove. Anything routed EU to non-EU should be at 50%. If a Rotterdam–New York booking is being charged as though it were intra-EU, that is a doubling.
Check the allowance price date next. Surcharges are usually set on a rolling reference period and published in advance. A surcharge quoted in July applied to an October sailing should be using the reference price for the announced period, not a spot price on the day of invoice.
Then check whether the routing changed. If your loop moved from the Cape back to Suez mid-quarter, the voyage emissions dropped and the surcharge should follow — carriers do not always reprice as fast as the routing changes.
One thing not worth doing is disputing the allowance price itself. It is a market price, it is public, and no carrier is setting it.
The part that is still moving
Allowance prices have risen, and that increase is inside the 45% Hapag-Lloyd flagged rather than separate from it. The coverage factor is now fixed at its ceiling, so from here the surcharge moves with fuel, routing and the EUA market only. That is the first year since 2023 where the regulatory input is a constant.
Which makes this a good quarter to build the check into your invoice audit properly rather than eyeballing it. If you are reconciling emissions cost against actual voyages, the routing and transit data is the input you need, and the emissions view will get you the voyage basis.
For 2027 the thing to watch is scope. The current design covers CO₂ on ships above 5,000 gross tonnes; the direction of travel on both vessel size thresholds and additional gases has been one way for several years.
