Insights · Emissions
EU ETS voyages run berth to berth: where anchorage and port time belong
What counts as a port of call, why time at anchor before berthing belongs to the voyage, and what the noon reports need to show.
Under the EU ETS, what you pay depends on where each hour belongs: to a voyage counted at 50%, to a voyage counted at 100%, or to a stay in an EU port, counted at 100%. The rules are simple to state and easy to get wrong in the data.
Ports of call, and stops that are not
A port of call is a port where the ship stops to load or unload cargo, or to embark or disembark passengers. Stops for the sole purpose of refuelling, obtaining supplies, relieving the crew, going into dry-dock or making repairs are not ports of call, and neither are stops for shelter or assistance, or ship-to-ship transfers outside ports. A bunkering-only stop in an EU port therefore does not end the voyage: it continues to the next port where cargo is worked.
50% or 100%
Voyages between two ports in the EU or EEA, and emissions within an EU port, are counted at 100%. Voyages between an EU port and a port outside the EU, in either direction, are counted at 50%.
Anchorage belongs to the voyage
The European Commission’s guidance treats entry into and exit from port, before and after the port of call, as part of the voyage. Guidance on the MRV rules states plainly that anchoring while waiting to enter port is part of the voyage, and so is drifting. The port stay starts when the ship is all fast and ends when she casts off.
This can move a lot of time. On our pilot vessel, one arrival at an EU port spent 78 hours between the end of sea passage and first berthing, almost all of it at anchor. Arriving from a port outside the EU, those hours are counted at 50% as part of the voyage, not at 100% as part of the port stay. Measuring the stay from the arrival report would have overstated it.
What the noon reports need to show
- The time of cast off and of all fast at every port of call, reported as events, in UTC or with the time zone stated.
- Anchorage, drifting and shifting hours reported the same way every time, either per report or cumulative.
- The purpose of each stop, so that bunkering or crew-change stops are not taken for ports of call.
- Remaining on board at each event, so that fuel can be split between voyage and port without guessing.
2026: the full share
From 2026 the EU ETS covers methane and nitrous oxide as well as CO2, and 100% of the reported emissions. The 2026 emissions must be verified by 31 March 2027, and the allowances surrendered by 30 September 2027.
How Noon Report Analysis handles it
The program reads the berthing events in the noon reports, falls back to other sources only when an event is missing, and shows the source of every time before you issue a statement. A port stay that has not ended is shown as still alongside, never with an invented departure.