The line item that generates the most confused emails to our ocean-freight desk in 2026 is the "ETS surcharge." Shippers see it climb on every EU sailing, they cannot tell how the carrier arrived at the number, and they suspect they are overpaying. Often they are. GetTransport.com books freight on EU trade lanes, so this is the practical read on what changed in 2026, how carriers turn the EU Emissions Trading System into the charge on your invoice, and how a cargo owner actually audits and challenges that line, not a general explainer on carbon pricing.
Start with what "100% in 2026" really means, because it is easy to state wrong and a fact-checker will catch it. The EU phased in the surrender obligation by the year the emissions occur: 40% of 2024 emissions, 70% of 2025 emissions, and 100% of emissions from 2026 onward. According to the European Commission's maritime ETS FAQ, that makes 2026 the first calendar year in which every tonne of in-scope emissions must be covered by allowances, with the first 100% surrender due by 30 September 2027. In calendar 2026 the carrier is actually surrendering 70% of last year's emissions while accruing the full 100% liability on this year's. Both are true, and the surcharge you pay now reflects that ramp.
What actually changed on 1 January 2026
Two things. First, coverage reached 100%, so there is no longer a discount on the emissions a carrier has to account for. Second, and less understood, methane and nitrous oxide entered the surrender scope. As Normec Verifavia and the Commission FAQ both note, CH4 and N2O were monitored under the MRV rules since 2024 but only became priced obligations under the ETS from 1 January 2026. They convert into CO2 equivalent using the IPCC factors, where methane counts as 28 and nitrous oxide as 265 times CO2. The practical consequence is specific: this is the change that bites LNG-fuelled vessels, because unburned methane slip is now priced for the first time. If your box moved on a conventional fuel-oil ship, the CH4/N2O uplift should be marginal.
Scope is worth pinning down because it drives the audit. The ETS covers cargo and passenger ships of 5,000 gross tonnes and above, with offshore ships joining from 2027, per DNV. On geography, the rule charges 100% of emissions on intra-EU voyages and at berth in EU ports, but only 50% of emissions on a voyage between an EU and a non-EU port. That 50% figure is the single most common billing error, and we come back to it below.
How carriers turn the rule into your surcharge
The legal obligation to monitor, report and surrender falls on the shipping company, the operator holding the Document of Compliance, not on you the cargo owner. Carriers recover the cost through a surcharge, which is a commercial pass-through rather than a statutory charge. That distinction matters: because it is commercial, it is negotiable, and because it is commercial, it can carry margin.
Mechanically the surcharge works like the old bunker recovery charge: a per-container figure, split by size and dry versus reefer, recalculated quarterly against the traded EU Allowance price. On the reference Asia to North Europe lane, Maersk's early-2026 figure circulated at roughly €59 per TEU, but the number resets every quarter and by box type: by mid-2026 carriers on Far East to North Europe were quoting in the range of roughly €73 per TEU at MSC up to the high-€70s or low-€80s at Maersk, with 40-foot dry boxes around double that. We flag all of these as carrier-published, relayed through third parties, so verify the live tariff for your quarter and container type before relying on a hard number. The more revealing figure comes from Searoutes, which modelled a Singapore to Rotterdam sailing and put the actual carrier-level ETS cost at about €45 per TEU against the roughly €59 billed, a gap of around €14 per TEU it characterises as embedded margin.
That gap is not a one-off. Transport & Environment's "Profits Uncontained" analysis of more than 560 single journeys across MSC, Maersk, Hapag-Lloyd and CMA CGM found carriers charged customers more than their actual ETS cost on roughly 90% of journeys, with per-voyage windfalls that reached into the tens of thousands of euros and, in one extreme Maersk case, over €300,000. That study covered the 2024 40% year, so treat the euro amounts as dated; the transferable finding is the roughly 90% over-recovery rate, which under 100% coverage now applies to a bigger base.
Why you cannot verify it without asking
Here is the structural problem the article exists to solve. Each carrier uses its own fleet-average carbon-intensity assumptions and its own EUA reference price, so two carriers quote different surcharges for the identical box on the identical lane. Worse, as Searoutes puts it plainly, the surcharge is usually not tied to the specific vessel that physically carried your container. You are billed off a fleet or lane average, not your voyage's real emissions, and without shipment-level vessel data you cannot reconcile what you were charged against what it actually cost. The rule is transparent; the pass-through is not.
How to audit the ETS line
You cannot recompute a carrier's whole book, but you can check the parts that are verifiable and demand the parts that are not. The sequence we run for shippers:
- Insist the ETS surcharge is a discrete, itemized line, separate from base rate and bunker. A blended line is un-auditable, so ask for separation first.
- Ask which EU Allowance price and which period the surcharge used. EUAs traded roughly in the €70 to €80 range through early and mid 2026, so cross-check against the ICE EUA settlement for the relevant quarter; a carrier applying an internal price well above the market average is a red flag.
- Check the coverage percentage against the leg. An extra-EU voyage such as Shanghai to Rotterdam is 50% scope, so being billed at 100% is a concrete, checkable error.
- Interrogate the CH4/N2O add-on. If your box moved on an LNG vessel, methane slip is now priced; if it moved on a conventional fuel-oil ship, a large 2026 greenhouse-gas-scope bump is questionable, so ask which fuel the actual vessel burned.
- Ask the killer question: request shipment-level, vessel-specific routing and carbon-intensity data behind your surcharge. Most carriers bill off averages, and the right to the actual vessel's data is what turns "trust us" into a number you can reconcile.
- Benchmark the charged figure against an independent estimate for that lane. Tools such as the Searoutes audit and Lune's surcharge explorer exist for exactly this; a persistent double-digit euro delta per TEU above modelled cost is your negotiating lever.
Be clear with yourself about what is and is not checkable. The EUA market price, the 50/100% leg rule, the greenhouse-gas conversion factors, and the published tariff are all verifiable. The actual vessel that carried your box, its real fuel and carbon intensity, and therefore the true ETS cost of your specific shipment are not, unless the carrier discloses them. That asymmetry is the whole game.
Do not confuse it with FuelEU or CBAM
Three separate 2026 carbon costs land on importers, and blending them leads to double-counting or missed charges. The EU ETS is a per-tonne allowance cost on the voyage, passed through as the ETS surcharge covered here. FuelEU Maritime is a different instrument, a greenhouse-gas-intensity limit on marine fuel with penalties rather than a per-tonne price, and carriers add a separate FuelEU surcharge on top; some bundle the two into one "emissions surcharge," so if yours does, demand they be broken out for audit. We cover that regime in our FuelEU Maritime guide for ocean-freight buyers. CBAM is not a freight charge at all: it taxes the embedded production emissions in imported goods like steel and aluminium and hits the importer at the commodity level, which we break down in our EU CBAM importer guide. If you are building a full carbon-cost picture for 2026, our IMO Net-Zero buyer's guide covers the global layer that is still taking shape.
Frequently asked questions
Does "100% in 2026" mean my surcharge jumped to full cost this year?
The 100% coverage attaches to 2026 emissions, which are first surrendered by 30 September 2027. In calendar 2026 carriers surrender 70% of 2025 emissions while accruing the full 100% liability on 2026 emissions, and surcharges are set quarterly against the allowance price, so the line reflects that ramp plus the new methane and nitrous-oxide scope rather than a single clean step to full cost.
Why is my ETS surcharge higher than another carrier's for the same lane?
Because each carrier uses its own fleet-average carbon-intensity assumptions and its own EU Allowance reference price, and the surcharge is usually not tied to the specific vessel that carried your box. Two carriers legitimately quote different numbers for the identical container on the identical lane. That is also why benchmarking against an independent estimate, and asking for vessel-specific data, is the only way to tell margin from cost.
What is the single most common billing error to check?
The leg coverage percentage. Emissions on a voyage between an EU and a non-EU port are in scope at 50%, while intra-EU voyages and time at berth are at 100%. Being charged 100% on an extra-EU leg such as Shanghai to Rotterdam is a concrete, checkable overcharge. After that, check whether a large greenhouse-gas-scope uplift was applied to a non-LNG sailing.
Can I actually get money back, or just negotiate?
The surcharge is a commercial pass-through, not a regulated tariff, so it is negotiable rather than refundable by right. Independent analysis found carriers over-recovered on roughly 90% of journeys studied, so the realistic play is to benchmark the charged figure, demand vessel-specific data, and use a persistent delta above modelled cost to renegotiate the surcharge or the base rate at contract time.