If your contract lets a carrier bill both a quarterly fuel adjustment and an emergency fuel surcharge, the containers to audit first are the ones priced after the fuel formula reset while the emergency charge stayed on. Each line can match its own notice, and the pair can still recover the same fuel months.
The question is live again. Xeneta figures reported by FreightWaves on 9 November put average fuel surcharges on long-term contracts across four major Asia trades at $820 per FEU, up 42%. CMA CGM raised its emergency levels from 1 October and ONE raised its own from 1 November. Two fuel charges on one container justify a question. Whether they overlap depends on the fuel window behind the formula and the costs the emergency charge is meant to cover.
How the Same Fuel Can Be Billed Twice
A standard bunker adjustment factor (BAF) is indexed to fuel prices and usually recalculated each quarter from a fixed reference window. Xeneta says carriers typically adjust fuel surcharges on a 30 to 60 day lag behind bunker spot prices. When the Global 4 Ports average VLSFO price rose from $506 per tonne on 27 February to $961.50 on 19 March, Q2 BAF levels had not caught up. Carriers covered the gap with emergency surcharges.
Drewry’s concern is what happens at the next reset. The emergency charge recovers the higher fuel cost immediately, and the same cost can be recovered again once those prices enter the quarterly BAF calculation. Our July explainer on Hapag-Lloyd’s fuel charges covers how the two charges are built.
| Quarter | Standard BAF | BAF plus emergency surcharge |
|---|---|---|
| Q1 2026 | $419 | Not reported |
| Q2 2026 | $406 | $798 |
| Q3 2026 (June projection) | $696 | $1,088 |
In Q2, the $406 BAF still reflected pre-war fuel, so the emergency layer did the catching up. Drewry projected the Q3 BAF rising $290 to $696 as the formula absorbed the spring spike, with an emergency layer of about $392 still on top, the same size as in Q2.
Carriers Handled the Overlap Differently
Hapag-Lloyd withdrew its ocean emergency surcharge when its formula reset. CMA CGM and ONE kept theirs running alongside their regular fuel mechanisms and raised them in Q4. The shipment event that decides which charge lands on a container also varies by carrier, as our post on cargo receipt dates explains.
| Carrier | Emergency charge (long-haul headhaul, dry) | Applied by | Later changes |
|---|---|---|---|
| Hapag-Lloyd | Emergency Fuel Surcharge (EFS), for costs outside its Marine Fuel Recovery (MFR) | Sailing date from 23 March; FMC scope, gate-in from 8 April | Discontinued 1 July as Q3 MFR took effect. Q4 MFR from 1 October. |
| CMA CGM | EFS, $150 per TEU from 16 March | Loading date | $150 per TEU from 1 August. $265 per TEU dry, $320 reefer from 1 October. |
| Maersk | Emergency Bunker Surcharge (EBS), $400 per 40ft from 25 March; FMC scope from 9 April | Price calculation date | Described as temporary and non-refundable. Fossil Fuel Fee (FFF) reset 1 July and 1 October. |
| ONE | EFS, $120 per TEU from 1 May | Not stated in the EFS notices | $120 per TEU from 16 September. $150 dry, $190 reefer from 1 November. Bunker Surcharge (OBS) reset 1 October. |
Hapag-Lloyd tied the withdrawal to its Q3 MFR reflecting the current fuel-cost environment, and says it remains committed to avoiding duplicate recovery of the same fuel cost elements. Put that standard to every carrier on your contracts. Maersk describes its EBS as responding to fuel availability, cost and mix, which is a case it can make. To test it, you need the calculation basis of both charges.
Where to Look on Your Containers
Maersk publishes the fuel window behind each quarterly FFF, which makes it the clearest worked example. Its Q3 FFF for contracts over three months took effect on 1 July and was built from fuel prices between 11 February and 10 May. That window includes the March spike. On Far East Asia to North Europe, the Q3 FFF was $595 per 40ft dry container.
A Q3 container that also carried an EBS line paid a formula that had already priced in the spike, plus the emergency charge introduced for the same disruption. Those containers are the first sample to query.
Q4 points the other way. The Q4 FFF took effect on 1 October, uses prices from 11 May to 10 August, and came in at $570 on the same lane. It can’t reflect fuel bought after 10 August, so an emergency charge billed in Q4 has a stronger claim to covering costs the formula missed. Ask for the calculation anyway.
ONE gives a second set of dates to check. Its OBS reset on 1 October for the quarter to 31 December, and its long-haul headhaul EFS rose to $150 per TEU dry from 1 November. Shipments priced after 1 November can carry both the revised OBS and the higher EFS.
On US-regulated trades, the FMC states that the applicable tariff rate or charge is the one in effect when the carrier or its agent receives the cargo, including where a service contract incorporates the tariff. Keep cargo-receipt records with each invoice you query.
If your team is matching fuel lines to loading and sailing dates container by container across several carriers, see how ops teams pull shipment events for every container into one view.
What to Check on Each Contract
- Read the fuel clause. Find out whether the rate is all-inclusive or allows added fuel charges, then locate the BAF, MFR, OBS or FFF formula, its index and its reference window. Xeneta’s guidance is that a shipper holding an all-inclusive rate has grounds to question an added emergency charge.
- List every fuel line by container. Record the standard ocean fuel charge, any emergency fuel or bunker surcharge, and inland fuel fees. Keep inland charges out of the ocean overlap test.
- Match each charge to its shipment event. Loading, sailing, gate-in, cargo receipt or price calculation date, whichever the notice and your contract use.
- Line up the fuel windows. Flag containers where an emergency charge was billed under a formula whose reference window already covered the same fuel months. Maersk’s Q3 containers are a ready example.
- Ask what the emergency charge covers, in writing. Request the calculation method and the incremental costs it recovers beyond the standard formula. Keep the invoices, rate sheets, notices and your questions together.
- Ask what happens at the Q1 2027 reset. Drewry advises confirming that emergency surcharges are removed once the underlying BAF has adjusted to market conditions.
- Carry the terms into your next tender. For any emergency surcharge you accept, Xeneta recommends a measurable trigger, a defined end date, a disclosed method and no overlap with fuel mechanisms you already pay.
Further Reading
- Are you overpaying? Why shippers should revisit emergency fuel surcharges now (FreightWaves, Drewry analysis, 22 June 2026)
- The Impact of the Iran Conflict on BAF (Drewry, via Hellenic Shipping News, 30 June 2026)
- Asia-U.S. West Coast ocean container spot rates up 343% since start of Iran war, says Xeneta (FreightWaves, 9 November 2026)
- Middle East conflict FAQs (Xeneta)
- Volatility, Invoiced: Why Every Disruption Now Comes with a Surcharge (Xeneta, via Hellenic Shipping News, 24 September 2026)
- Implementation of Emergency Fuel Surcharge (Hapag-Lloyd, March 2026)
- Marine Fuel Recovery Q3 2026 and withdrawal of ocean EFS (Hapag-Lloyd)
- Marine Fuel Recovery Q4 2026 (Hapag-Lloyd)
- Advisory #7: Middle East Emergency Fuel Surcharge Implementation (CMA CGM, 10 March 2026)
- Advisory #12: Middle East Emergency Fuel Surcharge Implementation (CMA CGM, 21 July 2026)
- Situation in the Middle East: Emergency Fuel Surcharge Update (CMA CGM, via AJOT, 18 September 2026)
- Emergency Bunker Surcharge (EBS) Global (Maersk, 10 March 2026)
- Emergency Bunker Surcharge, FMC scope update (Maersk, 11 March 2026)
- Fossil Fuel Fee for Contracts over 3 Months Validity, Q3 2026 (Maersk)
- Fossil Fuel Fee for Contracts over 3 Months Validity, Q4 2026 (Maersk)
- Update on Emergency Fuel Surcharge, effective 1 May (ONE)
- Update on Emergency Fuel Surcharge, effective 16 September (ONE, 17 August 2026)
- Update on Emergency Fuel Surcharge, effective 1 November (ONE, 1 October 2026)
- ONE Bunker Surcharge update, effective 1 October 2026 (ONE, 31 August 2026)
- Commission Statement Regarding Strait of Hormuz Surcharges (U.S. Federal Maritime Commission, 11 March 2026)
BAF averages are Drewry’s East-West headhaul figures per 40ft dry container, published in June 2026, with Q3 figures as projected at publication. The VLSFO prices are Drewry’s, citing Ship & Bunker data. The $820 per FEU figure is Xeneta’s, as reported by FreightWaves on 9 November 2026, and comes from a different dataset than Drewry’s averages. Carrier surcharge levels, application rules, fuel reference windows and dates come from the Hapag-Lloyd, CMA CGM, Maersk and ONE notices listed above, reviewed on 10 November 2026. Confirm current levels and the terms that apply to your shipments against your service contract and the carrier’s live tariff. This post is general information, not legal advice.
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