A trade report on 3 August said carriers are beginning to shift some container calls away from Algeciras toward Tanger Med to reduce exposure to the EU Emissions Trading System. If you move boxes through the Strait of Gibraltar, that raises a practical question about your own routing.
The answer has less to do with your invoice than the framing suggests. A rule adopted in 2023 already means a Tanger Med call does not count when the start and end points of an ETS voyage are worked out. What the hub swap changes is the emissions treatment of the vessels and port calls involved, where your container physically sits, and how much you can see while it sits there.
What EU ETS Covers on a Mediterranean Leg
The system is voyage-based and flag-neutral. What matters is each ship’s previous and next qualifying ports of call, not who owns or registers the ship and not the container’s complete door-to-door itinerary.
| Leg type | Example | Share of emissions covered |
|---|---|---|
| Voyage between two EU ports | Algeciras to Barcelona | 100% |
| Emissions inside an EU port | At berth and manoeuvring at Valencia | 100% |
| Voyage from an EU port to a non-EU port | Rotterdam to Shanghai | 50% |
| Voyage from a non-EU port to an EU port | Shanghai to Rotterdam | 50% |
Two lines in that table drive Mediterranean routing economics. Emissions inside an EU port count in full, including time at berth. So does a feeder voyage between two EU ports, while a voyage between an EU and non-EU port counts at half.
Coverage has also been ramping toward full strength, which is why surcharge lines keep moving:
- 2024 emissions: 40% covered, surrendered by 30 September 2025
- 2025 emissions: 70% covered, surrendered by 30 September 2026
- 2026 emissions onward: 100% covered, surrendered by 30 September of the following year
Methane and nitrous oxide entered the ETS surrender obligation in 2026, widening the emissions base behind carrier compliance costs. For the customer-facing version of that explanation, see our earlier guide on explaining EU ETS surcharges to customers.
Why a Tanger Med Call Does Not Reset the Voyage
The obvious way to shrink an ETS bill would be to break a long voyage with a stop just outside EU jurisdiction, turning one long covered voyage into a shorter one. Brussels anticipated this.
Implementing Regulation (EU) 2023/2297, adopted on 26 October 2023, designates Tanger Med in Morocco and East Port Said in Egypt as “neighbouring container transhipment ports.” Stops by containerships at those two ports are excluded from the definition of a port of call, so they do not count when determining where an ETS voyage starts or ends.
A port qualifies for that list on three tests: transshipment exceeds 65% of its total container traffic over the most recent twelve months, it sits outside the EU but within 300 nautical miles of a member state port, and its country applies no equivalent carbon measure. The Commission’s first implementation report put Tanger Med and East Port Said at roughly 70% of transshipment activity across non-EU Mediterranean countries.
The practical consequence depends on the vessel movement rather than the box alone. If the same containership sails from Asia through Tanger Med and then continues to an EU port, the Tanger Med stop does not shorten that ship’s voyage for ETS purposes. The covered voyage runs from the previous qualifying port to the EU port, and emissions released during the Tanger Med stop remain part of that voyage.
If the container is transferred to another vessel at Tanger Med, however, each vessel’s voyage is assessed separately. The container does not carry one continuous ETS obligation across its full Asia-to-Europe itinerary. The treatment of the feeder depends on its own previous and next qualifying ports.
What the Hub Swap Still Changes
Moving a relay from Algeciras to Tanger Med can still reduce carrier ETS exposure. It removes a 100%-covered EU port stay from that service pattern. Emissions during the Tanger Med stop are not exempt, but they are included in the surrounding voyage and may therefore be covered at 50% rather than treated as emissions within an EU port.
The feeder structure can change too. A relay through Algeciras may create a 100%-covered voyage between two EU ports. Moving the transfer to Morocco may replace that with an EU–non-EU voyage covered at 50%. The precise result depends on the previous and next qualifying ports for every vessel involved, so it cannot be calculated from the container routing alone.
Those are carrier economics. What reaches your desk is different, and it lands on the part of the journey that was already the hardest to see.
Transshipment can create some of the longest gaps in container tracking. A box discharged at a relay hub may sit for days or weeks with no new milestone posting while it waits for a feeder, and the onward ETA can move repeatedly during that gap. We documented that pattern, including at Tanger Med, in our guide to why container tracking goes silent during transshipment.
When the relay point moves, the feeder network behind it moves too. Different terminal, different yard dwell profile, different connection frequency onward to Barcelona, Genoa or Marseille. A routing your customer was quoted six months ago may now transit a hub nobody on either side has named out loud.
If your Mediterranean legs are moving between hubs and milestone events go quiet during the transfer, walk through how ops teams set up transshipment exception alerts across carriers.
The Numbers Behind the Shift
| Port | 2025 container throughput | Change vs 2024 |
|---|---|---|
| Tanger Med | 11,106,164 TEU | +8.4% |
| Algeciras | 4.74m TEU | +0.5% |
Tanger Med grew 8.4% across its four container terminals in 2025, driven in part by the commissioning of the APM Terminals TC4 extension. It handled 1,319 vessel calls from ships over 290 metres, up 8.4% on the year, even as total calls fell.
Algeciras grew 0.5%. The composition matters more than the headline: the port authority reported growth in import and export containers set against a slight decline in transshipment traffic. Total throughput across all cargo fell 3.2% to 100.7 million tonnes.
Attributing that divergence to carbon cost alone would overreach. Terminal capacity coming online at one port and not the other explains part of the gap, while Red Sea disruption and wider service-network changes have also affected Mediterranean port calls. What the numbers show is that relay volume at the EU side of the Strait is not growing, while capacity on the non-EU side is expanding.
What Changes Over the Next Two Years
The Commission published a revision proposal on 17 July 2026 that would tighten the transshipment rules in three ways. The designated-port list would be reviewed annually by 31 December rather than every two years. The transshipment share threshold would fall from 65% to 50%. A new infrastructure test would also capture ports within 150 nautical miles of a member state port where draught exceeds 11 metres, berth length exceeds 250 metres and suitable ship-to-shore cranes are available.
The proposal also offers relief in the other direction. Until the end of 2035, containerships of 10,000 TEU and above arriving from a non-EU port on voyages longer than 300 nautical miles could surrender fewer allowances. The reduction would be based on the share of containers discharged at the EU port solely for transfer to another ship sailing from that same EU port to a non-EU destination.
That provision is designed to reduce the cost disadvantage faced by EU relay hubs. It would not apply to every container unloaded for transshipment, and it would not reduce the obligation for boxes transferred onto another intra-EU service.
None of it is law yet. The proposal has to clear the European Parliament and the Council, so treat it as direction of travel rather than a planning date.
One more variable arrives sooner. Nador West Med, Morocco’s second deepwater Mediterranean port, is scheduled to begin operations in the fourth quarter of 2026. Morocco has announced an initial overall handling capacity of five million containers a year.
Its container facilities include a terminal held through a joint venture between Marsa Maroc and MSC’s Terminal Investment Limited, designed for 3.4 million TEU at full capacity with its first phase scheduled for early 2027. A second terminal operated through a Marsa Maroc and CMA Terminals joint venture is designed for 1.8 million TEU annually and is also expected to become operational from 2027.
Nador West Med is not on the current designated-port list. Under the existing rules, designation would require recent operating data showing that transshipment exceeds 65% of total container traffic. The Commission’s proposed infrastructure test could create a separate route to designation if the revision becomes law.
What to Check Now
- Pull your last quarter of Mediterranean bookings and confirm which relay hub each one actually transited, not which one the original routing named.
- Ask carriers whether any Med string you use has changed its transshipment point in 2026, and get the changeover sailing date.
- Check how long your milestone events go quiet at each relay hub you use, and whether that gap has widened since the routing changed.
- Reconcile ETS surcharge lines against each vessel’s qualifying voyage rather than assuming the container has one continuous ETS treatment.
- If you quote Med transit times to customers, re-baseline them against the feeder frequency at the hub currently in use.
Need help interpreting this disruption or your shipment?
For a quick question, chat with Tradlinx on WhatsApp. For a deeper discussion, book a time below.
Prefer email? Contact us directly at min.so@tradlinx.com (Americas), sondre.lyndon@tradlinx.com (Europe), or henry.jo@tradlinx.com (EMEA/Asia).
Further Reading
- FAQ: Maritime transport in the EU Emissions Trading System, European Commission
- FAQ: Monitoring, reporting and verification of maritime emissions, European Commission
- Commission Implementing Regulation (EU) 2023/2297 identifying neighbouring container transhipment ports, EUR-Lex
- Proposal COM(2026) 616 amending the EU ETS Directive, European Commission via EUR-Lex
- EU ETS costs shift transhipment flows from Algeciras to Tangier Med, WorldCargo News (subscriber access)
- Port of Algeciras completes a decade of consistent throughput, Container News
- Port Activity Report 2025, Tanger Med Port Authority
- Marsa Maroc and TIL partnership at Nador West Med, Marsa Maroc
- Marsa Maroc and CMA Terminals agreement at Nador West Med, CMA CGM
Coverage percentages and port-of-call definitions reflect European Commission guidance. Throughput figures are full-year 2025 as published by Tanger Med Port Authority and the Port of Algeciras. The Commission’s 17 July 2026 ETS revision is a proposal and has not completed the legislative procedure; its provisions may change. Nador West Med’s five-million-container figure refers to the announced capacity of the overall port at opening, while the 3.4-million-TEU and 1.8-million-TEU figures refer to separate container terminals expected to begin operations from 2027. Confirm ETS surcharge mechanics and any routing change against your own carrier tariff and contract terms.
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