
In 2026 the FuelEU baseline is 89.34 gCO2e/MJ. As we all know by now, fuel used on EU/EEA voyages and port calls counts 100%; on mixed EU/non‑EU voyages it counts 50%.
Under FuelEU’s default factors MGO scores 90.77 gCO2e/MJ.
Plug that into the penalty formula and you land at roughly €39.5 per tonne of FuelEU‑covered MGO. Or approximately €645 per tonne of compliance deficit CO2e.

FuelEU Maritime pins ultimate responsibility on the ISM company. However, charterers can influence outcomes through bunker choices and charter terms. Practical decisions land on cash, paperwork, and how much administrative headache you’ll tolerate.

Pooling isn’t some button you press on a platform. It’s paperwork, timing, and a verifier signing off. The legal actor is the ship’s FuelEU “company” - usually the ISM.
Brokers and platforms make introductions and draft contracts. But they don’t log anything in the FuelEU database or replace the verifier.
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