EU ETS 2026 for LSPs: How to Explain the New Emissions Surcharges to Your Customers

From 1 January 2024, shipping was pulled into the EU Emissions Trading System (EU ETS). In 2025, most LSPs saw the first “EU ETS / Emissions surcharge” lines appear on carrier invoices and tried to pass them through as cleanly as possible.

In 2026, this stops being experimental.

The phase-in reaches full coverage for in-scope ship types: EU guidance and carrier advisories align on a three-step ramp-up – 40% of verified maritime emissions in 2024, 70% in 2025, and 100% from 2026 onward for the ships currently under scope.
The ETS still applies to 100% of emissions on intra-EU voyages and 50% on EU–non-EU legs, plus emissions at berth in EU ports.
Methane (CH₄) and nitrous oxide (N₂O) are added to the ETS scope from 2026 for covered ships, increasing the emissions baseline behind the surcharge.

Carriers are already signalling material increases in ETS surcharges for 2026, reflecting both higher emissions coverage and movements in EUA prices.

For LSPs, 2026 is the year where ETS becomes:

a standard cost component in every EU-touching ocean quote,
a reconciliation problem on every carrier invoice,
and a conversation topic with customers who now see this line on every shipment into or via Europe.

This post focuses on that practical reality:

Why ETS costs are changing again
How surcharges are actually built (at a high level)
How to explain them to shippers without hype or hand-waving
What to change in your quoting, invoicing, and visibility processes for 2026

1. Why ETS Surcharges Change Again in 2026

You don’t need to become a carbon-market specialist to explain EU ETS. But you do need a simple narrative that matches what’s actually happening.

From partial coverage to “full” shipping coverage

In very simplified terms, the maritime ETS ramp looks like this for ships already in scope:

2024 – Shipping enters ETS. Around 40% of relevant emissions count toward allowances.
2025 – Coverage rises to around 70% of those emissions.
2026 – Coverage reaches 100% for the in-scope ship types.

On top of that, from 2026:

The ETS still applies route-based:
- 100% of emissions on voyages within the EU/EEA
- 50% of emissions on voyages between EU/EEA and non-EU ports
- Methane and nitrous oxide come into scope for ETS on shipping, not just CO₂.

For your customers, that means:

2025 surcharges were effectively based on partial coverage of a subset of emissions.
2026 surcharges are based on full coverage of those emissions plus a broader gas basket.
If EUA prices remain in the €70–80 band or rise, per-TEU ETS costs step up again, even if nothing else changes.

Carriers are treating ETS as a pass-through cost

Most major lines have now settled into a similar pattern:

They publish an ETS or “Emissions” surcharge per trade, per equipment size, often revised quarterly.
They calculate it from:
- Emissions per TEU / FEU / lane
- The share of each voyage that falls under ETS (100% or 50%)
- The applicable coverage factor (40 → 70 → 100%)
- A rolling EUA price

For 2026, some carriers have already announced:

Higher ETS factors per TEU on EU-linked lanes
Larger surcharge steps on long-haul routes that spend more time in ETS scope

From the LSP side, this shows up simply as: “ETS lines are bigger and change more often”.

2. How ETS Surcharges Are Built (Without Drowning in Formulas)

You do not need every carrier’s internal formula. But having a simple mental model helps you evaluate whether a surcharge is directionally reasonable.

At a high level, for one shipment:

ETS cost ≈ (Emissions per TEU on that voyage) × (Share of that voyage in ETS scope) × (Coverage factor for that year) × (EUA price) ÷ (How the carrier spreads the cost across TEUs / FEUs)

Three variables matter most for your customers:

Route geometry

A container doing Asia → North Europe (via EU port) will have:
- 50% of the Asia–EU leg in ETS scope
- 100% of emissions at berth in the EU port
A purely intra-EU loop has 100% of voyage emissions in scope.

Distance and vessel profile

Longer voyages in scope and more fuel-intensive ships = higher emissions per TEU.
Different carriers use different vessel mixes, which is why:
- Two similar routes, on different operators, can have different ETS surcharges.

EUA price and update frequency

ETS costs track the EUA carbon price, which trades on the market.
Most carriers update ETS surcharges quarterly or when EUA prices move sharply.

Your goal as an LSP is not to reverse-engineer every calculation. It’s to:

Understand why Asia–EU ETS is higher than a short-sea leg, and
Explain ETS as a mechanical cost driver, not as a mysterious extra margin.

3. What Your Customers Will Ask in 2026

By now, many shippers have accepted that “ETS” is real. The 2026 step-up will trigger more pointed questions. Most of them boil down to a few patterns:

“Why is this line so much higher than last year?”

Answer: Coverage has stepped up (partial → full), and EUA prices and vessel mixes have moved.

“Why is ETS different between two carriers on the same lane?”

Answer: Different calculation methods, vessel profiles, and scope assumptions. One line may use more conservative emission factors or a broader cost base.

“Is this a real cost or just a way to increase rates?”

Answer: The ETS framework and coverage percentages are defined by EU law; carriers must buy allowances. How aggressively they pass those costs through varies, but the structural driver is real.

“Can we do anything to reduce ETS costs?”

Answer: Sometimes. You can:
- Compare routes with fewer EU port calls or shorter ETS-covered legs
- Improve load planning and shipment consolidation
- Align with your customer’s broader emissions strategy

“Why is ETS separate from base freight?”

Answer: Because it’s a distinct, volatile cost driver. Keeping it separate is the cleanest way to adjust when EUA prices or coverage change.

A good 2026 ETS playbook equips your teams with simple language for these questions, backed by consistent data.

4. A Simple Framework to Explain ETS to Customers

When you strip away the jargon, ETS for shipping can be explained in five building blocks.

1. What is in scope?

Ships ≥ 5,000 GT calling EU/EEA ports (plus gradual extensions to offshore and smaller general cargo in later years).
100% of emissions for intra-EU voyages.
50% of emissions for voyages between EU and non-EU ports, in both directions.
Emissions at berth in EU ports are also in scope.

2. What is the phase-in schedule?

For currently covered ships:

2024: 40% of verified maritime emissions
2025: ~70%
2026: 100%

This is why ETS lines looked modest in early 2025 and will feel heavier in 2026.

3. How does it show up on a freight invoice?

Carriers calculate an ETS surcharge per trade, generally per:
- TEU/FEU
- Equipment type (standard, reefer, etc.)
They publish these surcharges as:
- A separate “ETS / Emissions surcharge” line
- Updated periodically (often quarterly)

You can tell customers:

“This line reflects the allowances carriers must buy for the EU-covered part of your voyage. It is separate from base freight so it can move with the carbon price and regulation.”

4. Why does it differ by lane?

Because the ETS cost depends on:

How much of the voyage is under ETS scope (e.g. intra-EU vs Asia–EU via one EU port)
Distance within that scope
Vessel and fuel characteristics on that service

Short-sea EU loops and long-haul routes touching multiple EU ports will behave differently.

5. Why does it differ by carrier?

Carriers make different choices on:

Emission factors and modelling approaches
How they spread costs across TEU/FEU, trades, and equipment types
Whether they absorb part of the cost or pass it through fully

You may not be able to compare them perfectly, but you can compare lane-by-lane ETS levels and watch for outliers.

5. How LSPs Should Quote ETS in 2026

In 2025, some LSPs treated ETS as a footnote. In 2026, that approach will break. You need a disciplined quoting and invoicing pattern.

Keep ETS as a separate line in your quotes

For every EU-touching movement:

Show base ocean freight and ETS surcharge as separate lines.
Where possible, copy the carrier’s naming convention (e.g. “EU ETS” or “Emissions Surcharge”) to avoid confusion.
Make clear in your T&Cs that ETS surcharges may be revised with:
- Carrier updates
- EUA price changes
- Regulatory changes

This avoids hiding ETS in base freight and getting caught when surcharges move mid-contract.

Version-control surcharges by carrier and lane

Build a simple internal structure:

For each carrier and lane:
- Current ETS surcharge per container size/type
- Effective dates
- Source document (advisory, tariff file)

Make it accessible to:

Sales and pricing teams (for quoting)
Operations (for booking)
Finance (for invoice checking and pass-through)

This reduces the number of times someone accidentally uses an outdated ETS figure in a quote.

Use conservative assumptions in longer-term bids

For tenders stretching across 2026:

Use conservative ETS assumptions:
- Current carrier levels
- Reasonable buffer for EUA price volatility
Be explicit about:
- What ETS assumptions you used
- How and when you will true-up vs actual carrier surcharges

This is more credible than promising fixed, ultra-tight all-in rates on EU-touching lanes and absorbing ETS volatility yourself.

6. Reconciling ETS Surcharges with Reality

Because ETS is a regulated cost, some shippers will expect auditable logic behind the surcharges. LSPs that can reconcile quickly will look more credible.

Use your visibility and routing data

If you have a visibility platform that tracks:

Actual port calls
Voyages and transhipment hubs
Dwell and time at berth

you can:

Identify whether a given shipment:
- Was intra-EU
- Was EU–non-EU
- Called extra EU ports that changed ETS exposure
- Group shipments by lane to estimate average ETS intensity per TEU

You don’t need perfect modelling. Even rough lane-level benchmarks can help you spot:

Obvious over-billing or under-billing
Mis-aligned surcharges vs the mix of EU vs non-EU legs in your portfolio

Align reconciliation with your finance workflows

Give your finance team:

A clear ETS charge table by carrier and period
A way to match ETS lines on invoices to shipments (via B/L or container IDs)
Simple tolerance bands:
- “If carrier ETS per TEU on this lane deviates by more than X% from our reference, flag it.”

This shifts ETS from “mysterious line item” to a normal controllable cost.

7. Using ETS to Have Better Routing and ESG Conversations (Without Greenwashing)

ETS costs are ultimately linked to emissions intensity and routing choices. For customers with ESG targets or simply high cost sensitivity, you can turn this into a concrete conversation.

Examples:

Comparing two routings:
- An Asia → EU shipment via multiple EU transshipment ports
  vs
- A routing with a single EU gateway and non-EU hub elsewhere
Looking at:
- ETS exposure (how much of the voyage is in scope)
- Total lead times
- Reliability and port congestion risk

You’re not promising zero-carbon shipping. You’re helping customers understand:

Where their ETS exposure is baked in (e.g. unavoidable EU legs)
Where they might have some flexibility (e.g. choice of gateway port or service)

That kind of grounded, lane-by-lane discussion is far more useful than generic “green routing” marketing—even though it’s powered by the same underlying ETS data.

Conclusion: Make ETS Boring, Not Mysterious

By 2026, ETS for shipping will no longer be new. It will be:

A normal, regulated cost driver in every EU-touching supply chain
A line item that shippers expect to see and question
A signal about emissions intensity and routing that ESG teams care about

For LSPs, the goal is not to turn into carbon traders. It is to:

Quote ETS separately and consistently
Understand why surcharges differ by lane and carrier
Reconcile what carriers charge with what actually happened on the water
Explain it to customers in plain language, with no hand-waving

If you can make ETS boring and predictable for your shippers—even as coverage and EUA prices move—you turn a potential friction point into a proof of competence.